New Homes
Support
Draft Local Plan
Representation ID: 13134
Received: 20/02/2016
Respondent: Mr. Michael R. M. Newman
The policy for the building of new homes seems to be a sensible way forward, logical and evidence-based. It appears to make good use of the resources available, with as little detriment as possible to the green belt and character of Brentwood.
The policy for the building of new homes seems to be a sensible way forward, logical and evidence-based. It appears to make good use of the resources available, with as little detriment as possible to the green belt and character of Brentwood.
Comment
Draft Local Plan
Representation ID: 13135
Received: 20/02/2016
Respondent: Mr David Charles
The borough already has too many houses and the addition of low cost housing and particularly flats is changing the structure of the borough and will increase the population to uncomfortable levels. I do not support the planned annual increase in housing.
The borough already has too many houses and the addition of low cost housing and particularly flats is changing the structure of the borough and will increase the population to uncomfortable levels. I do not support the planned annual increase in housing.
Support
Draft Local Plan
Representation ID: 13232
Received: 07/03/2016
Respondent: Mr Colin Downey
yes
yes
Object
Draft Local Plan
Representation ID: 13677
Received: 23/03/2016
Respondent: Mr Sasha Millwood
The NPPF makes very clear that 'objectively assessed' need is not legally binding, and that green belt considerations take precedence (see particularly paragraph 34 of the Planning Practice Guidance). For this reason, I object to the simplistic and ruinous plan for 'New Homes' set out here. Greater consideration also needs to be given to having higher densities of housing (previous , and a presumption against allowing any developments of detached and semi-detached houses, since they are a very inefficient use of land.
There are significant concerns with the validity of 'objective' assessments -- in the case of Brentwood, the report makes clear that the housing completion rates during the recession were anomalously large due to the conclusion of several major projects that had started before the recession (see ยง5.28). This means that projections that may have been appropriate for other local authorities are likely to be overestimates in the case of Brentwood. Another suspect matter is the definition of appropriate housing densities in Brentwood's Strategic Housing Land Availability Assessment Main Report. In that report, dated October 2011, it is suggested that "in the current climate [flats/apartments] are not proving to be popular", and Table 3/1 consequently suggests that flats are appropriate only in "Brentwood centre, Shenfield centre plus sites on the main roads coming out of these centres". Even more suspect is the Table's suggestion that terraced houses can be suitable only in Brentwood, Shenfield, and the centres of a couple of select villages (Ingatestone, W. Horndon, and Doddinghurst). Given the popularity of less centrally located neighbourhoods such as Clement's Park, a mixed-density development that includes many blocks of flats and terraced houses, it is clear that the Housing Land Availability Assessment Report is underestimating the popularity and suitability of high- and mid-density development, which also has the advantage of facilitating viable and accessible public transport, such as bus services, an important consideration in view of the need to substantially reduce car usage. What this means in practice is that it is eminently feasible to develop a large number of homes on a much smaller plot of land than the one proposed, to the extent that any need for the green belt to be compromised can be obviated, given sufficient political will not to bow to the demands of estate agents and developers, who naturally prefer low-density development on greenfield sites due to their higher profitability, and who prioritise such profitability over the needs, wishes, and best interests of local residents. Even if the Objectively Assessed Housing Need were to be accepted on its current basis, it would not mandate the destruction of large swathes of green belt: there is considerable potential for high-density development on urban brownfield sites, and, legally speaking, the green belt takes precedence over development needs. Paragraph 34 of the Planning Practice Guidance stipulates that "Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the 'very special circumstances' justifying inappropriate development on a site within the Green Belt." Paragraphs 44 and 45 also make clear that Objectively Assessed Housing Need is not the only pertinent factor in determining housing targets, and the significant amount of green belt land in the Brentwood and Basildon districts would be sufficient justification to set housing targets at a lower level than that suggested by the Objectively Assessed Housing Need (Brentwood's green belt is, according to the council's own strategic growth options development plan, "the sixth highest in England by percentage of total area").
Object
Draft Local Plan
Representation ID: 13806
Received: 22/03/2016
Respondent: Mr Timothy Webb
- Policy should be determined according to the views/opinions/wishes of the residents, if necessary by holding a legally binding democratic referendum, and not by Central Government dictate
- The Draft Plan only addresses "supply" and ignores "demands". The overwhelming problem is over-population - neither the world as a whole, the UK, nor Brentwood Borough can absorb or accomodate ever increasing population
- The genuine concerns of existing residents should at all times take priority over the vested interests of developers.
- Policy should be determined according to the views/opinions/wishes of the residents, if necessary by holding a legally binding democratic referendum, and not by Central Government dictate
- The Draft Plan only addresses "supply" and ignores "demands". The overwhelming problem is over-population - neither the world as a whole, the UK, nor Brentwood Borough can absorb or accomodate ever increasing population
- Any building should only be undertaken in the event of demonstratable need and not to satisfy pre-determined quotas
- In any case the Green Belt should be treated as irrevocably sacrosancts - in accordance with the original intentions of its founders
- No new building whatsoever should be permitted in rural/Green Belt locations - including on "brownfield" sites therein since this causes hideous impairment of the landscape viewable from many angles over considerable distance - as in Trueloves Lane
- Any compelling/imperative residential development should take place exclusively on "brownfield" sites such as redundant/obsolete industrial estates, eg. Water Way, West Horndon
- Any redundant/unoccupied offices and shops could be converted to residential use
- Town centre locations such as the Baytree Centre should be prioritised.
- Wherever possible, existing buildings (eg. shops) could be extended upwards with additional storeys to provide flats, residential accomodation
- Development/destruction/ruination of (inter alia) Officers Meadow should be eschewed in order to preserve green fields between existing communities
- The genuine concerns of existing residents should at all times take priority over the vested interests of developers
- All flora and fauna should be fully safeguarded at all times, in all circumstances, in all locations.
Object
Draft Local Plan
Representation ID: 14115
Received: 12/04/2016
Respondent: Mr Paul Hawkins
The proposal, for housing, caters for 80% of people that do not reside on this borough. There is absolutely no need to build on greenbelt and greenbelt is a constraint for housing targets..
The proposals are a full on assault on the greenbelt and creates a precedent for the greenbelt to be frittered away in subsequent LDP's ever 10-15 years. Be like Castle Point Castle, who have refused their proposed Local Development Plan, and fight for the wonderful environment current residents and I enjoy.
Please register my objection to your current consultation for the proposed Brentwood Local Development Plan for the following reasons;
1. The proposal, for housing, caters for 80% of people that do not reside on this borough.
2. There is absolutely no need to build on greenbelt and greenbelt is a constraint for housing targets..
3. There will be insufficient infrastructure for the dramatic increase in population that you are proposing. No new hospitals or hospital expansions are budgeted for planned. No new secondary schools are budgeted for or planned. No major road improvements are budgeted for or planned. More people will mean more congestion, more pollution and a serious degradation of quality of life for Brentwood residents.
4. The proposals are a full on assault on the greenbelt and creates a precedent for the greenbelt to be frittered away in subsequent LDP's ever 10-15 years
5. Be like Castle Point Castle, who have refused their proposed Local Development Plan, and fight for the wonderful environment current residents and I enjoy. You know you dont have to build on greenbelt so why are you proposing to do so?
I strongly object to Brentwoods proposed Local Development Plan
Object
Draft Local Plan
Representation ID: 14116
Received: 12/04/2016
Respondent: Mr Paul Hawkins
There will be insufficient infrastructure for the dramatic increase in population that you are proposing. No new hospitals or hospital expansions are budgeted for planned. No new secondary schools are budgeted for or planned. No major road improvements are budgeted for or planned. More people will mean more congestion, more pollution and a serious degradation of quality of life for Brentwood residents.
Please register my objection to your current consultation for the proposed Brentwood Local Development Plan for the following reasons;
1. The proposal, for housing, caters for 80% of people that do not reside on this borough.
2. There is absolutely no need to build on greenbelt and greenbelt is a constraint for housing targets..
3. There will be insufficient infrastructure for the dramatic increase in population that you are proposing. No new hospitals or hospital expansions are budgeted for planned. No new secondary schools are budgeted for or planned. No major road improvements are budgeted for or planned. More people will mean more congestion, more pollution and a serious degradation of quality of life for Brentwood residents.
4. The proposals are a full on assault on the greenbelt and creates a precedent for the greenbelt to be frittered away in subsequent LDP's ever 10-15 years
5. Be like Castle Point Castle, who have refused their proposed Local Development Plan, and fight for the wonderful environment current residents and I enjoy. You know you dont have to build on greenbelt so why are you proposing to do so?
I strongly object to Brentwoods proposed Local Development Plan
Support
Draft Local Plan
Representation ID: 14143
Received: 12/04/2016
Respondent: Ms. Jean Dormer
In general overall comment is that I agree with the LDP. I would like to see the village primarily kept as a village, but would welcome something that would fit in IE perhaps some bungalows, an old peoples home or a small development. Also has the village got infrastructure?
See attached
Comment
Draft Local Plan
Representation ID: 14397
Received: 15/04/2016
Respondent: MRS LESLEY LYNN
While we support the plan NOT to build on the site behind Hatch Road and adjacent to beads Hall Lane, we wish you to consider the following in future as to why building on this land will never be acceptable (see attachment for list).
See attached.
Object
Draft Local Plan
Representation ID: 14513
Received: 19/04/2016
Respondent: Home Builder's Federation
Agent: Home Builder's Federation
Para 5.36 - The notion that Brentwood is a self-contained district really lacks credibility. The local plan and the OAN report attest to the district's strong inter-connectivity with London and Essex. The district is located within the London Arc as Figure 2.3 illustrates. Figure 8.1 illustrates the economic and transport links. The construction of Crossrail will only increase this connectivity with London and Essex (Chelmsford especially).
We consider that Brentwood should be considering a joint-SHMA based on an HMA with Basildon, Chelmsford and Epping Forest. Figure 2.3 shows strong commuting flows with Basildon and Chelmsford. An HMA based on this area could use a SHMA that applies consistent assumptions relating to migration to and from London, reflecting the Mayor of London's demographic assumptions that have shaped the London Plan. The local plan must make allowance for above trend household formation in Brentwood as a consequence of the London Plan.
See attached
Object
Draft Local Plan
Representation ID: 14516
Received: 19/04/2016
Respondent: Home Builder's Federation
Agent: Home Builder's Federation
Para 5.37 - The OAN figure has been prepared without the benefit of the DCLG 2012 Household Projections and therefore the Council is likely to need to do more work on the OAN, taking into account more recent household projections as well as the implications of the London Plan.
The 2012 SNPP does not provide adequate compensation for the Major's migration assumptions. Moreover, the projections are trend-based so there would still need to be an increase in supply above the trend level in Brentwood to compensate for potentially higher numbers of people moving to the borough as well as fewer people leaving to live in London.
See attached
Object
Draft Local Plan
Representation ID: 14517
Received: 19/04/2016
Respondent: Home Builder's Federation
Agent: Home Builder's Federation
Para 5.37 - Un-persuaded by the argument that the ONS has built-in a higher migration propensity. There is no evidence to support this claim. We note that neighbouring Basildon Council is not advancing this claim. Instead it has increased it OAN above the 2012 SNPP. We consider that Brentwood should do likewise.
Even if migration with London is accounted for by the latest projections, there is still the problem of London's unmet need.
Even if there is no agreement in place between London and the local planning authorities of the south east as to how this issue will be dealt with, it does not mean that the issue will go away. The paucity of supply in London relative to the need will mean that relatively more affluent households will move to Brentwood. As a consequence the local affordable housing need will probably increase more sharply than the SHMA evidence currently suggests.
See attached
Object
Draft Local Plan
Representation ID: 14541
Received: 19/04/2016
Respondent: Mr C Lonergan
Agent: Strutt & Parker LLP
Para 5.44 - The Council is 'keen not to rely on windfall'. However, the approach adopted within the DLP appears to do just that. The expectation of a high level of windfall is not based on evidence and not reasonable to predict a high supply of unallocated development to be delivered in later years. The Councils reliance on windfall is inappropriate and would not accord with the
NPPF.
See attached
Object
Draft Local Plan
Representation ID: 15330
Received: 05/05/2016
Respondent: Catesby Property Group
Agent: Strutt & Parker LLP
There is reference within the DLP to Brentwood Borough being considered to constitute a self-contained housing market area (paragraph 5.36) - a stance that is contradicted by numerous references within the DLP to the strong relationships between Brentwood and surrounding areas.
The plan appears to seek to solely meet the OANs of Brentwood Borough, without consideration of any unmet needs of neighbouring
authorities. It is not clear to what extent authorities with whom Brentwood Borough has a connection have been engaged and are agreeable to such an approach. This issue is particularly pertinent given the strong relationship between Brentwood and London, and the latter's acute housing need. We question whether the approach currently being taken in the preparation of the Local Plan meets the Duty to Cooperate.
See attached.
Object
Draft Local Plan
Representation ID: 15331
Received: 05/05/2016
Respondent: Catesby Property Group
Agent: Strutt & Parker LLP
The Council has determined the objectively assessed housing need for the Borough to be 362 dwellings per annum, informed by the SHMA 2013 and OAHN 2014.
The OAHN for Brentwood, however, also considers the delivery of 411 dwellings per annum as a feasible housing target for the Borough. It is not clear on what basis this level of growth has subsequently been rejected by the Plan.
This contradicts with the NPPF which states that Local Plans should have regard to market signals, that Local Planning Authorities should seek to significantly boost the supply of housing, and that they should seek to meet unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
See attached.
Comment
Draft Local Plan
Representation ID: 15332
Received: 05/05/2016
Respondent: Catesby Property Group
Agent: Strutt & Parker LLP
Strategic objectives of the Plan include to maintain high and stable levels of economic growth; and economic development is one of the overarching priorities.
It should also be recognised that housing development has intrinsic economic benefits. This includes employment relating directly to the construction of the development, and jobs relating to the supply chain. Housing development also engenders local economic benefits relating to additional local expenditure. It is important that the economic growth aspirations of the Local Plan and the housing growth policy support, rather than contradict, one another.
See attached.
Comment
Draft Local Plan
Representation ID: 15901
Received: 12/05/2016
Respondent: Kitewood
Agent: Kitewood
It does appear that the starting point for Brentwood is to meet the lower OAN. It is not entirely clear from the OAN report how the Council decided to progress a housing target 362dpa and this should be clarified moving forward.
See attached.
Object
Draft Local Plan
Representation ID: 16141
Received: 16/05/2016
Respondent: EA Strategic Land LLP
Agent: Iceni Projects Limited
The draft plan states that the 'objectively assessed housing need' of the Borough is 362 homes per year, although there is no specific evidence source for this, only a vague assertion within Policy SP2. The only conceivable evidence source in the Council's possession for this figure is the "Objectively Assessed Housing Need" document dated December 2014. This document states that it:
"does not seek to promote a housing target for Brentwood [...] the housing target should be informed by a wider base of evidence than population, household and economic projections" and that "more work will be needed to confirm the final OAN once the 2012 CLG projections have been released and Essex Planning Officers Association (EPOA)have completed the final round of Essex wide analysis (EPOA Phase 7 by Edge Analytics)."
It does not appear that the additional work to form a final OAN has been undertaken.
See attached.
Object
Draft Local Plan
Representation ID: 16314
Received: 18/05/2016
Respondent: Dunton Community Association
Agent: Dunton Community Association
The Plan allocates 35% of the Authority's OAN to the Dunton area. Such a proposal is clumsy in the extreme and does not represent proper and thoughtful planning. Such a proposal is clumsy in the extreme and does not represent proper and thoughtful planning.
The Plan is unbalanced in that it fails to distribute the loss of Green Belt land evenly throughout the borough. The Authority allocates 63% of its Green Belt release at Dunton in the absence of Green Belt assessment.
The Authority has cynically offloaded its housing and other needs to an edge of the Borough where a neighouring borough will shoulder the infrastructure burden. Basildon Council, which the Authority sees fit to exploit, already faces insurmountable infrastructure problems. The landscape assessment of the area south of the A127 is misguided.
See attached.
Comment
Draft Local Plan
Representation ID: 16460
Received: 19/05/2016
Respondent: Joint Owners of Land at Coxtie Green Road Brentwood
Agent: Mr Michael Warner
There is a need for a higher proportion of two bedroom units. There is a substantial and continuing unmet need for low cost housing in the Brentwood area. Low cost housing is likely to be smaller one and two bedroom units. The delivery of these smaller units within the market sector will be important in addressing a more balanced type and size stock mix.
See attached.