brentwood.gov.uk

Object

Representation ID: 936

Received: 02/10/2013

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Objections to the Plan, on the basis that it is unsound as currently drafted, for the following reasons:
1.The absence of an appropriate, comprehensive and up-to-date evidence base. A robust and credible evidence base must inform the content of the emerging local plan. Local plan policies must be justified by evidence in order to be considered sound. Failure to publish these and other technical documents will deprive interested persons of the opportunity to comment upon them and fully to comprehend how the preferred spatial growth strategy has been decided.
2.The emerging plan does not propose to meet its full objectively assessed needs (OAN) as advised in the NPPF. Seeking to meet such needs is part of the soundness test of being positively prepared (paragraph 182 of the Framework). Proposed provision of 3,500 new dwellings to be built in the Borough between 2015-2030, at an average annual rate of 233 dwellings per annum, is woefully inadequate to meet the needs of Brentwood over the next 15 years. Various studies commissioned by the Council place the housing need target closer to 5000 - 5500 (331 - 362 dwellings per annum) whilst the ONS/CLG projections point to a need for 6000 new dwellings over the plan period (400 per annum).
3.There is no explanation given as to how the shortfall in housing would be addressed. In such circumstances the NPPF advises local planning authorities to accommodate unmet need which cannot wholly be met within their own areas, under a 'duty to cooperate" but there is no evidence that this action has been progressed.