brentwood.gov.uk

Chelmsford City Council objects to Brentwood's Spatial Strategy which places the protection of the Green Belt and the quality and character of the landscape above meeting objectively assessed need. BBC has rejected Alternative Option 1 which makes provisions for 4,960-5,600 dwellings (331 to 373 homes a year) which is BBC's identified objectively assessed need. Instead BBC has chosen to make provisions for 3,500 new dwellings which equates to only 60% of its objectively assessed need. This means 40% of the housing needs for the Borough will not be met.

BBC's argument for not meeting objectively assessed need is the protection of the Green Belt which they consider to be the top priority for its Local Plan along with protecting the quality and character of the Borough. By their own omission, the protection of the Green Belt and ensuring there is adequate infrastructure to serve residents precludes the accommodation of the totality of market demand. In the context of a national housing shortage, the City Council does not consider that the protection of the Green Belt overrides meeting the full housing needs of Brentwood Borough. Furthermore, where is the evidence to justify this approach? The Plan indicates that the Landscape and Green Belt Assessment is forthcoming. This is unacceptable. This is a crucial piece of evidence base work that should be made available as part of the current consultation. As raised by the City Council and many other authorities in attendance at the Duty to Co-operate meeting on 29th July 2013, by not undertaking a Green Belt review BBC is leaving itself extremely vulnerable at Examination.

At the same Duty to Co-operate meeting Basildon Borough Council asked how BBC can allocate sites for development without the need for a Green Belt review. BBC responded saying that their approach was one of capacity - environmentally sensitive landscapes, capacity of transport infrastructure, provision of services and facilities, etc. However, again there is no published evidence to support this approach. Paragraph 2.29 of the Plan indicates that the Landscape and Green Belt Assessment, Transport modelling, Utilities Study and SHMA update are all forthcoming. The City Council would question how BBC has established their approach to the growth and development of the Borough over the Plan period without the relevant evidence? Paragraph 158 of the NPPF clearly states that 'each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.'

For the reasons set out above, the City Council strongly objects to BBC's Preferred Strategy which includes the possibility of looking to Chelmsford to meet a proportion of Brentwood Borough's unmet housing need. Brentwood Borough is not unique in their circumstances of being constrained by the Green Belt and other landscape characteristics. Chelmsford also has large areas of Green Belt and other environmental and infrastructure constraints which influence the delivery of its own housing requirements. Therefore, it is unreasonable and unacceptable for BBC to expect Chelmsford to make provisions for a proportion of their growth when Chelmsford itself has similar constraints. The City Council already is, and will be expecting to continue, to meet the needs of the City over the Plan period and beyond, without importing or exporting any other growth to/from neighbouring authorities.

The National Planning Policy Framework gives local authorities the ability to review Green Belt boundaries where it would meet objectives of the Framework and this includes meeting objectively assessed need. The City Council considers a Green Belt review is imperative and to meet the needs of the Borough some revisions to Brentwood Green Belt boundaries may be necessary.