Comment

Representation ID: 14520

Received: 19/04/2016

Respondent: Home Builder's Federation

Agent: Home Builder's Federation

The OAN Assessment 2014 considers that no adjustment for market signals is warranted because prices in Brentwood are no worse than the national and local indicators. We question the Council's decision not to adjust its supply to help counter issues of affordability in view of the observation in the draft plan about the problems of housing affordability.

Object

Representation ID: 14549

Received: 19/04/2016

Respondent: Mr C Lonergan

Agent: Strutt & Parker LLP

The proposed plan does not account for migration from London. The 2014 PBA OAN Study confirms that it does not consider migration from London in identifying the OAN but supports an OAN of 360dpa. The Council should consider whether this is consistent with the NPPF.

Object

Representation ID: 14550

Received: 19/04/2016

Respondent: Mr C Lonergan

Agent: Strutt & Parker LLP

The starting point for Brentwood is to meet their lower OAN. Basildon Borough Council are also proposing to meet their lower OAN and may have unmet need over the plan period. The Plan should have a clear understanding of how housing need will be met within the SHMA area to ensure the plan is positively prepared in accordance with the NPPF.

Object

Representation ID: 14557

Received: 19/04/2016

Respondent: Mr Danny Barry

1. We don't have to build 5-6,000 houses on greenbelt and recent rulings reflect this

2. Brentwood cannot fulfill any alleged housing targets due to greenbelt constraints which are a material restriction as demonstrated in recent planning cases and, in January 2016, by Castle Point Council

3. 80% of Brentwood's growth, to 2033, is estimated to be from people moving into Brentwood Borough

3. Brentwood's Metropolitan greenbelt acts as a green lung to neighbouring London

4. London is a low density city able to withstand further growth

Support

Representation ID: 14664

Received: 20/04/2016

Respondent: Hermes Fund Managers Limited

Agent: McGough Planning Consultants

Insofar as this is consistent with the requirement to meet the full objectively assessed need for Brentwood

Comment

Representation ID: 14944

Received: 26/04/2016

Respondent: Crest Nicholson

Agent: AECOM

Our client supports the principle of development on land designated as a Strategic Site in Policy 7.1. Our client's site is capable of delivering approximately 200-250 new homes at a density of between 30-35 dwellings per hectare. Development on our client's site would represent almost 10% of supply for the entire Strategic Site. To deliver this level of growth over the plan period Policy 7.1 must be flexible and allocate sufficient land for the plan period.

Comment

Representation ID: 14966

Received: 26/04/2016

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Objectively Assessed Housing Need figure of 7,240 new residential dwellings to be built over the Plan period, at a rate of 362 dwellings per year, is supported as a minimum. Whilst there is also support for the distribution of housing, the deliverability of the Strategic Site within the Plan Period is questioned - see also response to Policy 7.1.

Comment

Representation ID: 14969

Received: 26/04/2016

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The deliverability of the Strategic Site within the Plan Period is questioned. Included within this is Windfall Sites which are identified within Policy 5.2 as contributing 14%. The text (page 47) makes it clear that windfall makes an allowance for small scale development.
Given the dwindling supply of brownfield land within the urban area and the inherent unpredictability of the availability of windfall sites, it is not necessarily appropriate to continue to predict the availability at historic rates of provision. Against the backdrop of a relatively high proportion of housing supply overall, greater emphasis should be placed within the Local Plan on the importance of all windfall sites, regardless of their size, acknowledging the cumulative effect that even the smallest of sites providing 1 or 2 units, will have on housing supply and achieving the growth set out within Policy 5.2.

Comment

Representation ID: 14974

Received: 26/04/2016

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The deliverability of the Strategic Site within the Plan Period is questioned. Included within this is Windfall Sites which are identified within Policy 5.2 as contributing 14%. The text (page 47) makes it clear that windfall makes an allowance for small scale development.
Given the dwindling supply of brownfield land within the urban area and the inherent unpredictability of the availability of windfall sites, it is not necessarily appropriate to continue to predict the availability at historic rates of provision. Against the backdrop of a relatively high proportion of housing supply overall, greater emphasis should be placed within the Local Plan on the importance of all windfall sites, regardless of their size, acknowledging the cumulative effect that even the smallest of sites providing 1 or 2 units, will have on housing supply and achieving the growth set out within Policy 5.2.

Comment

Representation ID: 14988

Received: 26/04/2016

Respondent: Mrs N. Blake

There remain 928 dwellings to be provided under the "windfall" allowance, which in comparison the historic growth rates add up to a very large number of new sites of up to 10 homes to be allocated in the future and a very long list of sites in the current non-allocated housing sites. Will this not create a potential planning blight in these areas if it isn't made clear where the 928 houses are to go? Can the status of the non-allocated sites be made clearer? Will there be a pause in development for windfall sites whist the main plan areas for development are progressed to ease the period of uncertainty?

Support

Representation ID: 15139

Received: 28/04/2016

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Support the Council's approach to identifying its objectively assessed housing requirements. It demonstrates the council's approach to positively preparing the DLP. the council has recognised the need to provide housing on a range of sites, both within urban areas, where possible and in appropriate and sustainable locations within the Green Belt. We support the clear and integrated approach of selecting a range of sites which link back to the evidenced and justified spatial strategy in policy 5.1. This is noted in paragraph 5.41.

Object

Representation ID: 15143

Received: 28/04/2016

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

We would recommend that the policies relevant to housing in particular remain as flexible as possible and constantly under review. At the very least, policy 5.2 should be amended to ensure the provision of 7,240 new homes in the plan period and the annual average of 362 homes is recognised as a minimum. We suggest an amendment to the first paragraph as follows:
"Provision is made for a minimum of 7,240 new residential dwellings (net) to be built in the borough over the plan period 2013-2033 at a minimum annual average rate of 362 dwellings per year as follows..."

Support

Representation ID: 15188

Received: 29/04/2016

Respondent: Punch Taverns

Agent: Plainview Planning

It is essential that the policy makes it clear that the figure of 7,240 new residential dwellings to be built in the Borough is a minimum and does not represent a ceiling to housing growth.
Our client agrees that sites with potential capacity for 10 dwellings or more should be allocated as residential development sites.

Object

Representation ID: 15189

Received: 29/04/2016

Respondent: Punch Taverns

Agent: Plainview Planning

Object to the over reliance of windfall sites. The cited number of windfall sites is significant and has not been fully justified by the Council. It was based on the 'historic rate' that relies upon a period without an up to date local plan and where the housing target was suppressed.

Instead of the over reliance upon windfall sites, the Council should include more Greenfield urban extensions in the Green Belt.

Object

Representation ID: 15229

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Housing target should be increased because the "OAN" calculation fails to take account of market signals, affordable housing needs and the impact of crossrail.
Reccomended the Council works with its neighbours under the duty-to-cooperate to coordinate and fully understand local needs.
The Draft Local Plan should be positively prepared to take account of these factors. The housing target in Policy 5.2 is not fully justified, effective or consistent with national policy.

Object

Representation ID: 15234

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

There are 3 areas which the Council should consider in more detail in order to provide an assessment of the OAN need for market and affordable housing as required by the Framework. These are:
1. Market Signals. The PBA Study shows that housing delivery has exceeded past housing targets, and based on analysis of a range of indicators suggested that there was not automatically a basis for making an upward adjustment to figures to respond to market signals. We suggest that this is inconsistent with the evidence.
2. Affordable Housing Need. Council's evidence indicates 234 affordable homes per year. PPG makes it clear an increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes. There is limited evidence that the Council has considered this issue to prepare the Draft Local Plan.
3. Impact of Crossrail.

Object

Representation ID: 15251

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Recommended that the supply of sites is re-considered because the sites set out in Policy 5.2 are not deliverable over the plan period and therefore would not achieve the housing target. This means that assuming there is no change to the housing target, sites to deliver an additional 1,500 new dwellings must be identified.

Recommended that a 10% discount for non-delivery is applied to extant permissions, permitted development and windfall allowance. During the plan period only 50% of the strategic site can reasonably be expected to be delivered reducing supply from this source to 1,250 units.

Therefore recommended that the site at Sawyers Hall Lane is added to the Greenfield Urban Extensions in Green Belt sites to help meet the housing target. The Draft Local Plan should be positively prepared and the housing sites set out in Policy 5.2 must be effective.

Object

Representation ID: 15309

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The housing completions have been below target since 2012 and are unlikely to meet the new target until 2018, a projection that we would regard at best as hopeful. We believe the problem stems partly from promotion of sites by the Council through the Local Plan process that either have little hope of being implemented or at least are subject to serious constraints. We believe the Local Plan as it stands runs a serious risk of being found unsound against national policy as set out in the NPPF's paragraphs 14 and more recent Central Government advice.

Support

Representation ID: 15344

Received: 05/05/2016

Respondent: Countryside Properties

Agent: Colliers International

We support the measures taken to address the housing needs of the Borough and acknowledge that a proportionate approach to Green Belt release has been taken.

Comment

Representation ID: 15361

Received: 06/05/2016

Respondent: Maylands Green Estate Co. Ltd

Agent: JTS Partnership LLP

OAN figure of 7,240 new residential dwellings to be built over the Plan period is supported. However there is a significant question mark over the deliverability of the Strategic Site at Dunton Hills and its ability to deliver within the Plan period.

Object

Representation ID: 15362

Received: 06/05/2016

Respondent: Maylands Green Estate Co. Ltd

Agent: JTS Partnership LLP

The Council's working draft Green Belt Assessment does not appear to have informed policy. No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated and whilst it is appreciated that some of those 50 sites within the 'Low' or 'Low to Moderate' criteria are not appropriate for housing development, being either in employment use, or having already been developed, the Council's failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15381

Received: 06/05/2016

Respondent: Robert Mulholland & Co Ltd

Agent: JTS Partnership LLP

OAN figure of 7,240 new residential dwellings to be built over the Plan period is supported. However there is a significant question mark over the deliverability of the Strategic Site at Dunton Hills and its ability to deliver within the Plan period.

Object

Representation ID: 15382

Received: 06/05/2016

Respondent: Robert Mulholland & Co Ltd

Agent: JTS Partnership LLP

The Council's working draft Green Belt Assessment does not appear to have informed policy. No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated and whilst it is appreciated that some of those 50 sites within the 'Low' or 'Low to Moderate' criteria are not appropriate for housing development, being either in employment use, or having already been developed, the Council's failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Object

Representation ID: 15400

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Para 5.9 states that: "it was proposed that the Borough [...] not meet the full objectively assessed housing need".

BBC must be satisfied that it has identified the full OAN for the Borough , before considering its ability to meet such need in respect of the NPPF policy constraints.

The Plan should positively seek opportunities to meet the development needs of its area. This is particularly important given that a number of surrounding authorities have confirmed, via representations to the previous iterations of the Local Plan, that they would not accept any shortfall from BBC within their own boundaries.

In this regard, BBC should be striving for as high levels of growth as possible.

Comment

Representation ID: 15409

Received: 06/05/2016

Respondent: JTS Partnership LLP

OAN figure of 7,240 new residential dwellings to be built over the Plan period is supported. However there is a significant question mark over the deliverability of the Strategic Site at Dunton Hills and its ability to deliver within the Plan period.

Object

Representation ID: 15410

Received: 06/05/2016

Respondent: JTS Partnership LLP

The Council's working draft Green Belt Assessment does not appear to have informed policy. No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated and whilst it is appreciated that some of those 50 sites within the 'Low' or 'Low to Moderate' criteria are not appropriate for housing development, being either in employment use, or having already been developed, the Council's failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15473

Received: 09/05/2016

Respondent: Mr Martin Morecroft

Agent: JTS Partnership LLP

OAN figure of 7,240 new residential dwellings to be built over the Plan period is supported. However there is a significant question mark over the deliverability of the Strategic Site at Dunton Hills and its ability to deliver within the Plan period.

Object

Representation ID: 15475

Received: 09/05/2016

Respondent: Mr Martin Morecroft

Agent: JTS Partnership LLP

The Council's working draft Green Belt Assessment does not appear to have informed policy. No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated and whilst it is appreciated that some of those 50 sites within the 'Low' or 'Low to Moderate' criteria are not appropriate for housing development, being either in employment use, or having already been developed, the Council's failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15486

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

OAN figure of 7,240 new residential dwellings to be built over the Plan period is supported. However there is a significant question mark over the deliverability of the Strategic Site at Dunton Hills and its ability to deliver within the Plan period.

Object

Representation ID: 15487

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

The Council's working draft Green Belt Assessment does not appear to have informed policy. No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated and whilst it is appreciated that some of those 50 sites within the 'Low' or 'Low to Moderate' criteria are not appropriate for housing development, being either in employment use, or having already been developed, the Council's failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.