Comment
Strategic Growth Options
Representation ID: 7782
Received: 23/03/2015
Respondent: Billericay Action Group
An OAN can take no account of Green Belt, however it is also clear that Green Belt constraint on meeting an OAN and that a sub-OAN Housing Target should be standard practice where GB does act as a constraint. Unfortunately the current Plan not only presents an unnecessarily high OAN, it intends to meet it in full; the Green Belt has not been treated as a constraint. Brentwood has not explained which 'exceptional circumstances' apply to justify building 3000 houses on Green Belt. If it is a need to meet the OAN, then NPPG(quoted above) makes it clear that this does not qualify as such a justification. The Green Belt has five purposes (Para 80 NPPF). Green Belt achieves these aims by keeping the land 'permanently open' (Para 79 NPPF), and it is hoped that this document makes clear that there is no requirement in the NPPF or elsewhere, for LA's to remove land from the Green Belt. To summarise: De-designating Green Belt is a choice, not an obligation.
Representation consists of the Comments below, plus the attached document.
"Billericay Action Group objects to the three areas chosen
Under the NPPF and associated Guidance it is clear that building on Green Belt is a choice, not an obligation.
Furthermore, Brentwood has enough Brownfield sites to comfortably satisfy its own Natural Growth requirements.
The proposed developments would impact the environment and infrastructure of both towns and our attached document shows that this level of development is unnecessary"