Appendix 2 - Proposed Housing Delivery
Comment
Draft Local Plan
Representation ID: 13894
Received: 06/04/2016
Respondent: Mr Ian Blackburn
Housing densities at West Horndon should be greater than the 29 dwellings/hectare in order to retain a greater proportion of land for business use thus reducing proposed release of Greenfield sites for business eleswhere. The site at West Horndon are ideally placed for such higher densities having a rail link and being close to the centre of the village.
See attached.
Comment
Draft Local Plan
Representation ID: 13951
Received: 23/03/2016
Respondent: Mr Anthony Field
Agent: Sworders
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
We object to the policy to deliver only the minimum objectively assessed need for the Borough. Firstly, the objectively assessed need should be a minimum requirement. Secondly, the policy should identify sufficient sites to not only meet, but exceed, this requirement. Finally, we do not consider that the housing trajectory supporting this policy demonstrates sufficient deliveries over either the first five years of the plan period or the entire plan period.
Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. It expects the identification of key sites which are critical to the delivery of the housing strategy for the Borough over the plan period.
Paragraph 47 goes on to identify the requirement for sufficient specific deliverable sites to be identified to meet five years worth of the housing requirement. It is expected that a buffer of 5% is added to the supply of deliverable sites to ensure choice and competition in the market for land. A greater buffer of 20% is required if there has been a persistent pattern of under-delivery. The NPPG is clear that any backlog in delivery must also be made up within the first five years of the plan, where possible.
Beyond year five, it is expected that developable sites are identified to meet the need for at least a further 5 years, but ideally for a further ten years.
As such, unless the Plan identifies sufficient land to deliver the five year housing land requirement, it will fall foul of NPPF paragraph 47 and cannot be considered sound under NPPF paragraph 182.
The objectively assessed need should be a minimum requirement, in order to satisfy the requirement of NPPF paragraph 47 to boost significantly the supply of housing.
The table included with policy 5.2 summarises how the objectively assed need will be met. This demonstrates only how it will be met, with no contingency or reserve sites to either exceed this need or replace any identified sites which do not deliver.
The windfall allowance is used to meet the need, not provide a contingency. We do not consider that relying on almost 1,000 windfall deliveries is a sound approach. Paragraph 5.44 of the Draft Plan states that the Council are "keen not to be reliant on windfall to meet needs", suggesting agreement with this concern. The Council intend to address this through delivering higher densities which we do not consider to be a robust solution.
Allocations should seek to deliver the highest densities appropriate from the outset, particularly given the Green Belt status of much of the Borough.
Draft policy 7.3 deals with density and sets out a density of 30 dph or higher, other than where the special character of the surrounding area suggests lower densities. It also expects higher densities of 65 dph in town and district centres.
The supporting text to policy 7.3 suggests that the highest densities possible have been assumed in site allocations and the housing trajectory. It states that efficient use of land and development at the highest densities possible to avoid pressure to release more Green Belt is critical to delivery of the Plan.
If the Plan relies on the highest densities possible or appropriate being used for the allocated sites it cannot be a sound approach to include the potential for higher densities as the only contingency in housing numbers.
It does not appear that any non-implementation allowance is included so in order to meet the objectively assessed need every single extant consent, allocation, permitted development and windfall allowance must come forward during the plan period in order to meet the minimum need requirement.
As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF.
We do not consider that the Housing Trajectory which supports this policy accurately underpins the numbers reported in policy 5.2. It does not demonstrate a five year supply, or indeed, sufficient deliveries to meet the Borough need as set out in policy 5.2.
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
There are further discrepancies between the phasing contained in appendix 2 and housing trajectory contained in appendix 3.
The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory. For example, in appendix 2 site 22 is stated as delivering 250 dwellings in 0-5 years. In the housing trajectory deliveries are spread over 6 years starting in 2018 which is 5 years after the start date of the plan and 1 year after the proposed adoption date of Q2 2017 according to the Local Development Scheme. Similarly, sites 20, 21 and 152 are phased for 5-10 years under appendix 2, but deliveries are spread over 10 years. Dunton Hills Garden Village is shown in the trajectory as delivering for 14 years from 2019 to 2033 whereas appendix 2 phases it for 5-15 years.
Paragraph 7.37 is clear that the trajectory and delivery phasing is merely an estimate. "Delivery ultimately depends upon external factors such as finance availability for house builders, mortgage availability for purchasers, and landowner aspirations."
We contend that in order to be considered sound under NPPF paragraph 182, such issues should be resolved and underpinned by robust evidence prior to adoption of the Plan.
The housing trajectory does not demonstrate a five year supply. Assuming 2017-2021 is taken to be the relevant five year time period from adoption, those sites contained within the trajectory, plus extant permissions, class C2 completions, the permitted development allowance, and windfall allowance, total 1,737 dwellings. 200 of these deliveries would be from Dunton Hills Garden Village which we consider highly questionable (see below).
A simple multiplication of the 362 dpa figure by five years equates to 1,810 dwellings, rising to 1,900 dwellings with a 5% buffer or 2,172 dwellings with a 20% buffer. As such, the trajectory clearly does not demonstrate a five year supply.
Furthermore, we question whether the trajectory is deliverable due to the reliance on deliveries from Dunton Hills Garden Village. This strategic allocation is "critical to delivering the Plan's key development objectives" as set out in Policy 6.6 and supporting text and is crucial to the ability to demonstrate a five year supply on adoption of the Plan.
According to the trajectory, Dunton Hills Garden village needs to start delivering housing in 2019, only two years after adoption of the Plan and deliver 200 dwellings in the first five years following adoption. This is considered to be unrealistic given the scale of the site and its location in the Green Belt.
Large strategic sites, particularly those which require significant infrastructure investment, typically take considerably longer to deliver than smaller sites, as set out fully in our response to Policy 7.1.
If deliveries from Dunton Hills Garden Village are excluded or delayed, the housing trajectory falls considerably short of a five year supply.
Failing to meet the objectively assessed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.
Comment
Draft Local Plan
Representation ID: 13952
Received: 23/03/2016
Respondent: Mr Anthony Field
Agent: Sworders
Discrepancies between the phasing contained in Appendix 2 and housing trajectory contained in Appendix 3. The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory.
We object to the policy to deliver only the minimum objectively assessed need for the Borough. Firstly, the objectively assessed need should be a minimum requirement. Secondly, the policy should identify sufficient sites to not only meet, but exceed, this requirement. Finally, we do not consider that the housing trajectory supporting this policy demonstrates sufficient deliveries over either the first five years of the plan period or the entire plan period.
Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. It expects the identification of key sites which are critical to the delivery of the housing strategy for the Borough over the plan period.
Paragraph 47 goes on to identify the requirement for sufficient specific deliverable sites to be identified to meet five years worth of the housing requirement. It is expected that a buffer of 5% is added to the supply of deliverable sites to ensure choice and competition in the market for land. A greater buffer of 20% is required if there has been a persistent pattern of under-delivery. The NPPG is clear that any backlog in delivery must also be made up within the first five years of the plan, where possible.
Beyond year five, it is expected that developable sites are identified to meet the need for at least a further 5 years, but ideally for a further ten years.
As such, unless the Plan identifies sufficient land to deliver the five year housing land requirement, it will fall foul of NPPF paragraph 47 and cannot be considered sound under NPPF paragraph 182.
The objectively assessed need should be a minimum requirement, in order to satisfy the requirement of NPPF paragraph 47 to boost significantly the supply of housing.
The table included with policy 5.2 summarises how the objectively assed need will be met. This demonstrates only how it will be met, with no contingency or reserve sites to either exceed this need or replace any identified sites which do not deliver.
The windfall allowance is used to meet the need, not provide a contingency. We do not consider that relying on almost 1,000 windfall deliveries is a sound approach. Paragraph 5.44 of the Draft Plan states that the Council are "keen not to be reliant on windfall to meet needs", suggesting agreement with this concern. The Council intend to address this through delivering higher densities which we do not consider to be a robust solution.
Allocations should seek to deliver the highest densities appropriate from the outset, particularly given the Green Belt status of much of the Borough.
Draft policy 7.3 deals with density and sets out a density of 30 dph or higher, other than where the special character of the surrounding area suggests lower densities. It also expects higher densities of 65 dph in town and district centres.
The supporting text to policy 7.3 suggests that the highest densities possible have been assumed in site allocations and the housing trajectory. It states that efficient use of land and development at the highest densities possible to avoid pressure to release more Green Belt is critical to delivery of the Plan.
If the Plan relies on the highest densities possible or appropriate being used for the allocated sites it cannot be a sound approach to include the potential for higher densities as the only contingency in housing numbers.
It does not appear that any non-implementation allowance is included so in order to meet the objectively assessed need every single extant consent, allocation, permitted development and windfall allowance must come forward during the plan period in order to meet the minimum need requirement.
As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF.
We do not consider that the Housing Trajectory which supports this policy accurately underpins the numbers reported in policy 5.2. It does not demonstrate a five year supply, or indeed, sufficient deliveries to meet the Borough need as set out in policy 5.2.
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
There are further discrepancies between the phasing contained in appendix 2 and housing trajectory contained in appendix 3.
The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory. For example, in appendix 2 site 22 is stated as delivering 250 dwellings in 0-5 years. In the housing trajectory deliveries are spread over 6 years starting in 2018 which is 5 years after the start date of the plan and 1 year after the proposed adoption date of Q2 2017 according to the Local Development Scheme. Similarly, sites 20, 21 and 152 are phased for 5-10 years under appendix 2, but deliveries are spread over 10 years. Dunton Hills Garden Village is shown in the trajectory as delivering for 14 years from 2019 to 2033 whereas appendix 2 phases it for 5-15 years.
Paragraph 7.37 is clear that the trajectory and delivery phasing is merely an estimate. "Delivery ultimately depends upon external factors such as finance availability for house builders, mortgage availability for purchasers, and landowner aspirations."
We contend that in order to be considered sound under NPPF paragraph 182, such issues should be resolved and underpinned by robust evidence prior to adoption of the Plan.
The housing trajectory does not demonstrate a five year supply. Assuming 2017-2021 is taken to be the relevant five year time period from adoption, those sites contained within the trajectory, plus extant permissions, class C2 completions, the permitted development allowance, and windfall allowance, total 1,737 dwellings. 200 of these deliveries would be from Dunton Hills Garden Village which we consider highly questionable (see below).
A simple multiplication of the 362 dpa figure by five years equates to 1,810 dwellings, rising to 1,900 dwellings with a 5% buffer or 2,172 dwellings with a 20% buffer. As such, the trajectory clearly does not demonstrate a five year supply.
Furthermore, we question whether the trajectory is deliverable due to the reliance on deliveries from Dunton Hills Garden Village. This strategic allocation is "critical to delivering the Plan's key development objectives" as set out in Policy 6.6 and supporting text and is crucial to the ability to demonstrate a five year supply on adoption of the Plan.
According to the trajectory, Dunton Hills Garden village needs to start delivering housing in 2019, only two years after adoption of the Plan and deliver 200 dwellings in the first five years following adoption. This is considered to be unrealistic given the scale of the site and its location in the Green Belt.
Large strategic sites, particularly those which require significant infrastructure investment, typically take considerably longer to deliver than smaller sites, as set out fully in our response to Policy 7.1.
If deliveries from Dunton Hills Garden Village are excluded or delayed, the housing trajectory falls considerably short of a five year supply.
Failing to meet the objectively assessed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.
Comment
Draft Local Plan
Representation ID: 14054
Received: 11/04/2016
Respondent: J M Gillingham
Should the plan conclude that the Dunton Hills Garden Village development be allocated Housing densities should be greater than the 30-40 dwellings/hectare proposed. In fact the name and density proposed is further indication that the solution is not the right one to justify sacrificing Green Belt. If the Plan is serious in its aim to minimise loss of Green Belt it should be setting a far more aspirational vision than simply replicating a development type that has led to urban sprawl in the first place.
See attached.
Support
Draft Local Plan
Representation ID: 14158
Received: 24/03/2016
Respondent: Mrs Elizabeth Jones
Page 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 Approx. dwellings could be higher. Excellent use of land, more housing needed within Brentwood, wonderful to know it will be mixed therefore allowing a good mix to benefit the whole community.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrim Hatch supported.
Page 78 Site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Para 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Page 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 Approx. dwellings could be higher. Excellent use of land, more housing needed within Brentwood, wonderful to know it will be mixed therefore allowing a good mix to benefit the whole community.
Comment
Draft Local Plan
Representation ID: 14258
Received: 06/04/2016
Respondent: Mr Ian Blackburn
Should the plan conclude that the Dunton Hills Garden Village development be allocated Housing densities should be greater than the 30-40 dwellings/hectare proposed. The name and density proposed is further indication that the solution is not the right one to justify sacrificing Green Belt. To minimise Green Belt loss the Plan should be setting a far more aspirational vision than simply replicating a development type that has led to urban sprawl in the first place.
See attached.
Comment
Draft Local Plan
Representation ID: 14259
Received: 11/04/2016
Respondent: J M Gillingham
Should the plan conclude that the Dunton Hills Garden Village development be allocated Housing densities should be greater than the 30-40 dwellings/hectare proposed. The name and density proposed is further indication that the solution is not the right one to justify sacrificing Green Belt. To minimise Green Belt loss the Plan should be setting a far more aspirational vision than simply replicating a development type that has led to urban sprawl in the first place.
See attached.
Support
Draft Local Plan
Representation ID: 14339
Received: 14/04/2016
Respondent: Mr Venon Thomas
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Provides essential housing for the area on a site that would not be prone detrimental to the environment. Additionally would reduce commercial lorry traffic in the area.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14347
Received: 15/04/2016
Respondent: Mr Zak Harvey
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
I think Pilgrims Hatch area will benefit from more 3-4 bedroom houses.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14357
Received: 15/04/2016
Respondent: Mr Andrew Watson
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Need more affordable houses in Pilgrims Hatch area.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14366
Received: 15/04/2016
Respondent: Miss Tilly O'Leary
Support where the Sow N Grow site is listed no. 010. Approx. dwellings could be higher.
See attached.
Support
Draft Local Plan
Representation ID: 14375
Received: 15/04/2016
Respondent: Mr Dan Morrow
Support 010 Sow and Grow nursery. Dwelling density could be higher.
See attached
Support
Draft Local Plan
Representation ID: 14418
Received: 18/04/2016
Respondent: Mr Stanley Jopson
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
More homes needed in Brentwood, Essex.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14426
Received: 18/04/2016
Respondent: Mrs Rosa Dwyer
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Additional housing is required in this area. The proposal will provide much needed accomodation.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14431
Received: 18/04/2016
Respondent: MBE Roy Dyer
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Excellent idea. Much needed housing. A good site that fits in with local housing needs.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14436
Received: 18/04/2016
Respondent: Mr Robert Grey
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Would be good for the community and help with housing shortage in Brentwood.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14444
Received: 18/04/2016
Respondent: Mr Mital Patel
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
More dwellings are required to help support local business.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14448
Received: 18/04/2016
Respondent: Miss Lois Whitehead
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Better use of road.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14455
Received: 18/04/2016
Respondent: Mr Stephen Bunton
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
More dwellings in the area can proomote business for ourselves. Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14460
Received: 18/04/2016
Respondent: Mrs Judith Wright
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
More housing needed and traffic will be less.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14471
Received: 18/04/2016
Respondent: Mr Jason Paisley
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
More residents more work.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14480
Received: 18/04/2016
Respondent: Miss Deana Adansi
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
We need more houses in the local area.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Support
Draft Local Plan
Representation ID: 14487
Received: 18/04/2016
Respondent: Mr Chris Edwards
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
More affordable housing required in Brentwood.
Page 47 Use of Brownfield land in the Green Belt supported.
Para 7.36 proposal for Pilgrims Hatch supported.
Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.
Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.
Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.
Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.
Object
Draft Local Plan
Representation ID: 14689
Received: 20/04/2016
Respondent: Hermes Fund Managers Limited
Agent: McGough Planning Consultants
Objection related to the Council's new requirement that the phasing of development of Horndon Estate referred to in appendix 2.
The Council has two incompatible positions in respect of phasing the housing delivery on the Horndon Estate:
- The first is the housing contribution of the Horndon Estate identified as part of the current 5 year housing land supply
- The second is set out in the latest draft LDP, where appendix 2 shows the housing coming forward in the medium term i.e. after 5 years.
Our client has been working for some time on a planning application for the redevelopment of Horndon Estate. The new phasing requirement set out in the draft LDP does not appear to be underpinned by any assessment/ evidence and is unjustified. Consequently, our client objects to this policy and appendix 2.
See attached
Object
Draft Local Plan
Representation ID: 14697
Received: 20/04/2016
Respondent: Hermes Fund Managers Limited
Agent: McGough Planning Consultants
Re. Horndon Industrial Park. The allocations are welcomed, but as with previous drafts of the local plan the allowance of 500 dwellings continues to be unjustified. This figure is based on a simple density calculation that does not take account of the design constraints affecting the sites.
The supporting documents attached to this representation include draft masterplans and schedule of accommodation which have been subject to robust analysis of design, site and viability constraints - this has resulted in 324 houses and 63 flats.
See attached
Comment
Draft Local Plan
Representation ID: 14990
Received: 26/04/2016
Respondent: Ursuline Sisters
Agent: JTS Partnership LLP
Reference to Site Ref: 044 - Land at Priests Lane, appendix 2 identifies this combined site as being able to deliver approximately 130 dwellings. This is at a density stated in the Table to be 96dph. However as both sites making up this allocation total 5.35 hectares in area, density to achieve 130 dwellings would equate to approximately 24.3 dph.
Recommended correction: the table contained within Appendix 2 to the Draft Local Plan, should be corrected to read 24 dph.
See attached
Comment
Draft Local Plan
Representation ID: 15081
Received: 26/04/2016
Respondent: Ursuline Sisters
Agent: JTS Partnership LLP
Recommended Change: - The Phasing Estimate within the table at Appendix 2 to the Draft Local Plan should be amended to show delivery within the 0-5 years time period, at least for that part of the allocation within the Ursuline Sisters ownership (Site Ref: 044). The site is unused and unoccupied with no barriers to it being made available immediately. It would, thus, be deliverable within the 0-5 years phasing estimate.
See attached
Object
Draft Local Plan
Representation ID: 15262
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Notably the five year housing land supply assessment does not include the Strategic Site as it is
planned to come forward in years 5 to 10 (not the first five years). The Council cannot demonstrate a five year housing land supply and therefore the Draft Local Plan is not sound.
See attached
Comment
Draft Local Plan
Representation ID: 15951
Received: 12/05/2016
Respondent: CALA Homes
Agent: JB Planning Associates Ltd.
A development of 57 dwellings (41 dph) is considered to represent a more appropriate density for Site 079A, taking account of existing development in the local area; the site's sustainability and accessibility and the Council's aspiration to ensure the most efficient use of land is made
See attached.
Support
Draft Local Plan
Representation ID: 16318
Received: 12/05/2016
Respondent: Barwood Land and Estates Ltd
Agent: Chilmark Consulting Limited
Support the inclusion of Land at Honeypot Lane.
Appendix 2 identifies Honeypot Lane as providing a total of 250 dwellings in the first five years of the plan period and BLEL welcomes this identification of the opportunity to deliver housing on the site early in the plan period.
BLEL suggests that there should be some flexibility to the housing delivery phasing shown in the Draft Local Plan at Appendix 2 and 3 given the need to achieve detailed planning permission for the site in 2017 in order to allow time for the first phase of development to be completed in 2018.
See attached.