brentwood.gov.uk

Object

Representation ID: 831

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

1. It is considered that the current wording of Policy S1 is unsound as it does not accord with NPPF. Policy S1 states that the Borough "aims to protect the Green Belt other than that required to accommodate a strategic allocation at West Horndon and minor changes to accommodate proposed development on existing development sites in the Green Belt, no change to Green Belt boundaries is envisaged". To date Brentwood Council have not conducted a review of their Green Belt, and given that there is an NPPF requirement to boost significantly the supply of housing, it is not sound or justified for BBC to state that no change to Green Belt boundaries is envisaged;
2. Furthermore, the overall housing strategy and target is heavily reliant on the 1,500 allocation in West Horndon. Such reliance on a single site within a Local Plan is not a sustainable approach;
3. Alternative Options. Policy S1 notes the 'alternative' options considered as part of the 2009 Issues and Options consultation and how it helped to form the basis for the selection of the 'Preferred Option' within S1. Given that the Issues and Options consultation occurred almost four years ago, we question whether this work can be considered up-to-date.
4. Para 2.2 notes the justification for the selection of the 'preferred option'. We agree with this approach based on OAN but do not consider that the method is accurately reflected within the Policy on housing figures;
5. We note that at the other villages (beyond those named specifically within Policy SP1) within the Borough "limited" development should take place at a level commensurate with services and facilities available and which maintains local amenity and distinctiveness. In the interest of clarity it is considered that the word "limited" be deleted to support the NPPF's goal to boost significantly the supply of housing. Accordingly, it is considered that the 'limit' for such development should be defined by OAN at a settlement specific level, as derived from the Government's population and household projection figures.
6. It is also considered that S1 should make reference to identifying and maintaining a 5 year supply of housing land as per the NPPF (paragraph 47);
7. Paragraph 2.9 suggests that 200 dwellings will be built in villages excluded from the Green Belt, other than West Horndon (which has a separate allocation of 1,500). Given that the Local Plan will have a 15 year scope this means that only 13.33 dwellings will be built per annum across all the eleven villages excluded from the Green Belt. It is considered that this figure of 200 units will not be sufficient to facilitate development to meet "local community needs" at a settlement specific level.
8. PINS have identified that LPAs should explore all reasonable options to fulfil OAN. Where constraints are not fixed (i.e. they are not physical constraints such as floodplain), LPAs should plan positively to overcome the identified constraints. It is therefore clear that unfixed constraints including transport capacity and landscape impact should not be used as reasons to limit growth below OAN.