brentwood.gov.uk

Object

Representation ID: 911

Received: 01/10/2013

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 the NPPF. Policy S1 states that the Borough "aims to protect the Green Belt" and that "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, as part of the emerging Local Plan process, 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. Policy S1 also notes the 'alternative' options considered as part of the 2009 Issues and Options consultation and helped to form the basis for the selection of the 'Preferred Option' within S1. We question whether this work can be considered up-to-date. In the interim between the Issues and Options document and the publication of the Preferred Options document, the NPPF has been published and the Regional Spatial Strategy revoked. Accordingly, it is argued that the alternative options should be reconsidered, particularly in relation to the increased emphasis that the NPPF places on housing and economic growth. Additionally, paragraph 2.2 notes that the justification for the selection of the 'preferred option'. Whilst we agree with this approach based on objectively assessed need, we do not consider that method is accurately reflected within the Policy on housing figures, as discussed in relation to paragraph's 2.9, 2.20, 2.26 and 2.37.