Policy 5.2: Housing Growth
Comment
Draft Local Plan
Representation ID: 15537
Received: 24/03/2016
Respondent: Greater London Authority
The Mayor welcomes the Borough's approach to meeting its housing need and agrees with its conclusion for further work related to London. The Council may also wish to assure itself that proposals for a garden village are congruent with national policy on Green Belt development.
Thank you for giving the Mayor of London the opportunity to comment on your Draft Local Plan.
The Council's most recent evidence is focusing on the tightly defined area of the Borough despite significant interrelationships with its neighbours including London. These are demonstrated in particular through the significant proportion of commuting into the capital (almost 15,000 per day). This underscores the importance of collaboration and the Duty to Co-operate.
The Mayor welcomes the Borough's approach to meeting its housing need and agrees with its conclusion for further work related to London. The Council may also wish to assure itself that proposals for a garden village are congruent with national policy on Green Belt development.
In terms of employment, the Brentwood Enterprise Park is expected to make a significant contribution towards meeting the Borough's need. In the light of its proximity to London, close cooperation with the relevant neighbouring authorities is required. Also, given the Borough's good access to the strategic road network (via M25/A12/A127), it would also be useful to understand better your thoughts on the future consideration of land specifically for industry and logistics, and related opportunities that could potentially arise from the promotion of growth and development across London and its Opportunity Areas in particular.
With regards to retail we would support a town centre first approach and the need to work closely with neighbouring authorities including London on the potential impact of new larger-scale retail development on the vitality and viability of neighbouring centres.
From a transport perspective Brentwood has a very high level of car ownership compared to the national average. Without alternative means of transport the use of cars will continue to be an essential factor in access to services, employment and leisure. Therefore the delivery and encouragement of sustainable transport alternatives is essential.
The Mayor welcomes the Council's corridor-based approach and the consideration of transport implications beyond its boundaries. The arrival of the Elizabeth Line (formely Crossrail) in 2019 at Brentwood and Shenfield will improve the existing metro service and connectivity to Stratford as well as Central London, although the potential longer-term capacity is still under consideration (please see Transport for London's response for further details). Within this context, the Councils may wish to look at growth options close to these train stations and their catchment areas. The Mayor also supports the principle of improvements to the Greater Eastern Mainline between London and Norwich through Brentwood and would welcome policy support for it.
Support
Draft Local Plan
Representation ID: 15559
Received: 18/03/2016
Respondent: Epping Forest District Council
Support the aim of Brentwood Borough Council to make provision for its full Objectively Assessed Housing Needs (7,240 new houses) entirely within its own area.
On 15th March this Council's Neighbourhoods and Communities Select Committee considered a report on Brentwood Council's Draft Local Plan Consultation. The Committee agreed the following recommendations as this Council's formal response:
a) To support Brentwood Borough Council's spatial strategy which
i) concentrates new housing and employment development in the A12 and A127 corridors; and
ii) allows for limited release of Green Belt for development, and limited development, including infilling, within rural villages;
b) To support the aim of Brentwood Borough Council to make provision for its full Objectively Assessed Housing Needs (7,240 new houses) entirely within its own area;
c) To suggest that the final version of the Local Plan should include
i) direct reference to the Duty to Co-operate and related future arrangements with neighbouring authorities; and
ii) consideration of the potential for joint working with neighbouring authorities to make sufficient provision for the needs of the travelling community, with particular reference to paragraphs 4(d), 10© and 16 of "Planning policy for traveller sites" (2015).
Comment
Draft Local Plan
Representation ID: 15564
Received: 10/05/2016
Respondent: Mr Lee O'Connor
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.
See attached
Object
Draft Local Plan
Representation ID: 15567
Received: 10/05/2016
Respondent: Mr Lee O'Connor
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.
See attached
Comment
Draft Local Plan
Representation ID: 15611
Received: 10/05/2016
Respondent: Tony Hollioake
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.
See attached
Object
Draft Local Plan
Representation ID: 15613
Received: 10/05/2016
Respondent: Tony Hollioake
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.
See attached
Comment
Draft Local Plan
Representation ID: 15753
Received: 11/05/2016
Respondent: National Highways
It is considered that the provision of a number of strategic residential and employment locations in or close to the town centre could help to encourage sustainable travel and reduce the pressure on the highway network, which is welcomed. In particular, development located in close proximity to Brentwood Rail Station is welcomed as it could encourage long distance trips to shift away from private car use. The A12 highway corridor also runs alongside the railway corridor and therefore the railway provision could help reduce the reliance of new residents and employees on private vehicle use.
See attached
Object
Draft Local Plan
Representation ID: 15757
Received: 11/05/2016
Respondent: Persimmon Homes Essex
The latest AMR identifies a shortfall of 460 dwellings over the 2 year period, the Draft Plan does not appear to make any allowance for this shortfall which is not compliant with the NPPF.
See attached.
Support
Draft Local Plan
Representation ID: 15759
Received: 11/05/2016
Respondent: Essex County Council
Acknowledges that BBC are seeking to meet housing needs in full. Supports the 20 year plan period. Supports the prioritisation of bringing forward brownfield sites and all appropriate land within existing urban areas, and through maximising density where appropriate. However, any strategy will need to demonstrate that the level of growth can be accommodate by the existing and new social and physical infrastructure.
See attached
Comment
Draft Local Plan
Representation ID: 15764
Received: 11/05/2016
Respondent: Essex County Council
Should refer to the ECC Independent Living programme and its role in housing delivery should be considered in progressing the Plan.
See attached
Object
Draft Local Plan
Representation ID: 15855
Received: 11/05/2016
Respondent: Sammi Developments Ltd
Agent: Phase 2 Planning and Development Ltd
Provision of new dwellings in accordance with Objectively Assessed Housing Needs (OAHN) is supported. However The Plan relies heavily on one site (Dunton) which has no existing services and facilities whilst supporting infrastructure will take long time to deliver. This site should therefore be excluded from the Plan or reliance on the delivery of this site should be reduced.
The Council does not have a 5 year housing supply and the undersupply in year 1-3 will not be off-set by supplying over the minimum requirement in year 4-5. The Council needs to allocate additional sites at this stage to ensure that the 5 year requirement can be met.
See attached.
Comment
Draft Local Plan
Representation ID: 15857
Received: 23/03/2016
Respondent: Sainsbury's Supermarkets Ltd
Agent: Indigo Planning
Policy states that provision will be made for 7,240 new homes to be built in the borough between 2013-2033. Sainsburys Supermarkets Ltd welcome this proposed housing target which will help to address the borough's housing needs.
We write on behalf of our client, Sainsbury's Supermarkets Ltd (SSL), to submit
representations in relation to the draft Brentwood Local Plan, currently out on
consultation.
SSL currently operate a supermarket at William Hunter Way. As a result, they are keen to be involved in the Local Plan process.
Brentwood Draft Local Plan 2013-2033
Policy 4.2 states that provision will be made for 7,240 new homes to be built in the borough between 2013-2033. SSL welcome this proposed housing target which will help to address the borough's housing needs.
Policy 6.5 identifies Key Gateways and states that development proposals in the vicinity of these areas will contribute to enhancing a positive impression of the Borough. It should be recognised that there is a limitation to the extent to which some developments can contribute to enhancing the local area due to their nature and function.
Figure 6.1 identifies the location of these Key Gateways however it is of such a scale that it is not possible to clearly identify their boundaries. Each "Key Gateway" shown in this figure covers a wide area of land. A "Key Gateway"
should be a specific defined entrance or link, not an extensive wider area. This
figure should be amended accordingly.
It appears that the SSL site forms part of one of the Key Gateways. Given its
function as a supermarket and car park, much of which is set back from William
Hunter Way, SSL object to the store being included in the Key Gateway boundary and the boundary should be amended accordingly.
The boundary of the Brentwood Town Centre Conservation Area currently includes the southern frontage of William Hunter Way. This boundary should be
amended to exclude this area as there are no factors of special architectural or historic interest in this area that merit protection.
The requirements of Policy 10.3 in relation to Sustainable Construction and Energy are overly prescriptive. Whilst sustainability should be encouraged, policy should not be so prescriptive that it could comprimise the viability of new developments. Smaller scale developments such as extensions and small
refurbishements are unlikely to be able to achieve these targets. As such, a
flexible approach should be applied. The requirement to submit a Water Sustainability Assessment should be deleted as it places yet another unnecessary burden on developers.
There are a number of prescriptive design policies. These design policies should reflect the guidance set out in the NPPF on design in terms of contributing positively to making places better for people.
The requirement to provide a thorough site and context appraisal for all developments is excessive. Any assessment of a development proposal against
policy should be proportionate to what is being proposed.
Policy 10.8 states that new development proposals are expected to provide functional on-site open space and/or recreational amenities or where appropriate, financial contribution towards new or improved facilities nearby with the amount and type of provision required being determined according to the size, nature and location of the proposal. The wording of this policy suggests that all development will be required to make some provision regardless of what type of development is proposed. Provision of open space or recreational amenities is not always appropriate or necessary in order to make development acceptable. As such, this policy should be re-worded to make clear that in the provision of open space will be required where Regulation 122 compliant.
We trust that these representations will be taken into account in the next iteration of the Local Plan, however should you have any queries please do not hesitate to contact me or my colleague Helen McManus.
Object
Draft Local Plan
Representation ID: 15858
Received: 11/05/2016
Respondent: Sammi Developments Ltd
Agent: Phase 2 Planning and Development Ltd
The Council should take account of previous under-delivery in identifying sufficient sites to meet housing requirements and also a 20% buffer in accordance with the NPPF.
The significant housing allocations at Dunton Hill Garden Village and West Horndon will contribute to the Basildon's housing market area to a greater extent than the Brentwood housing market area due to the location of these sites relative to the main urban areas. Sites on the edge of Brentwood and Shenfield can make a greater contribution towards meeting local need for housing within the Brentwood housing market area.
Additional sites on the periphery of the principal urban area of Brentwood and Shenfield should be allocated.
See attached.
Support
Draft Local Plan
Representation ID: 15894
Received: 12/05/2016
Respondent: Mr Adam Smith
Agent: Collins & Coward Ltd
Policy 5.2 makes a fair provision for windfall sites and it is our view that it would be unreasonable to allocate any higher allowance.
See attached.
Comment
Draft Local Plan
Representation ID: 15907
Received: 12/05/2016
Respondent: Kitewood
Agent: Kitewood
the best approach for the Council to maintain a deliverable five year housing land supply against the up-to-date OAN, is to ensure the release of a range of sites, of varying sizes, in several locations. To ensure delivery, especially within the first five years of the plan, strategic scale allocations should be balanced with smaller sites.
The current reliance on windfall sites is inappropriate and therefore not fulfilling the objectives of NPPF. The allocation of Dunton development appears to be risky strategy and could result in a significant shortfall in the supply of housing if it is proved undeliverable.
See attached.
Support
Draft Local Plan
Representation ID: 15965
Received: 13/05/2016
Respondent: St Modwen Properties PLC
Number of people: 2
Agent: Strutt & Parker LLP
The stated objective of the plan to meet full objectively assessed housing needs
is strongly supported. In order to satisfy the duty to cooperate the Council will need to liaise closely with its neighbouring authorities in relation to all strategic matters.
The provision of 362 dwellings per annum over the plan period is supported and the importance of strategic sites and jobs provision ill of course be particularly important to support such growth in
sustainable manner. In this context, deliverable and available sites within single ownership such as the Brentwood Enterprise Park will be especially important in order to provide for phased
delivery throughout the plan period.
See attached.
Object
Draft Local Plan
Representation ID: 16028
Received: 13/05/2016
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
Provision of new dwellings in accordance with Objectively Assessed Housing Needs (OAHN) is supported. However The Plan relies heavily on one site (Dunton) which has no existing services and facilities whilst supporting infrastructure will take long time to deliver. This site should therefore be excluded from the Plan or reliance on the delivery of this site should be reduced.
The Council does not have a 5 year housing supply and the undersupply in year 1-3 will not be off-set by supplying over the minimum requirement in year 4-5. The Council needs to allocate additional sites at this stage to ensure that the 5 year requirement can be met.
See attached.
Comment
Draft Local Plan
Representation ID: 16057
Received: 13/05/2016
Respondent: Martin Grant Homes
Agent: Pegasus Group
This Policy is considered too restrictive and does not actively encourage housing growth as required by the NPPF. Martin Grant Homes remain concerned with the strategy for housing growth across the Borough which is heavily rely on the development at Dunton and focuses on releasing small number of very large sites from the Green Belt. Should any of these sites are not delivered or developed less than planned it would have significant impact on housing delivery in the Borough.
The Borough is not meeting its current windfall allowance, demonstrated by the current shortfall in housing delivery. The Council is considered unrealistic to expect such high windfall allowance during the Plan period and the Council is urged to review this.
See attached.
Object
Draft Local Plan
Representation ID: 16102
Received: 16/05/2016
Respondent: EA Strategic Land LLP
Agent: Iceni Projects Limited
This policy is unsound as it is not justified or consistent with national policy. We do not consider the housing growth provision has been based on up-to date or reliable evidence. The Council should consider updating its SHMA and undertaking further work on the OAN in understanding further how the Council has arrived at this growth requirement.
A strategy which seeks to deliver 19% of its overall housing requirement on Windfall sites cannot be considered sound, in line with NPPF paragraph 48 which states that 'compelling evidence' to justify its inclusion has been identified.
We consider the reliance on a strategic site at Dunton Hills Garden Village for 2,500 units should be approached with caution as it is highly unlikely this will site will be delivered in the plan period and this is therefore not an
effective policy.
See attached.
Object
Draft Local Plan
Representation ID: 16108
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
At a very late stage in the preparation of the plan DHGV resulted from a failed attempt at cross boundary development with Basildon to create a large Garden Suburb. DHGV is not a realistic option for strategic growth. The site boundaries and details of the development proposed are not sufficiently distinct to identify the sustainability implications or allow meaningful comparison to be made with the alternatives for growth, such as land at West Horndon.
See attached
Object
Draft Local Plan
Representation ID: 16125
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
Providing jobs in line with the past long-term trends would generate a need for 411 dwellings per annum. This would represent a more appropriate OAN for Brentwood as it would align housing supply in accordance with the long term trends in the economy.
See attached
Comment
Draft Local Plan
Representation ID: 16162
Received: 16/05/2016
Respondent: Joy Fook Restaurant
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.
See attached
Object
Draft Local Plan
Representation ID: 16163
Received: 16/05/2016
Respondent: Joy Fook Restaurant
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.
See attached
Comment
Draft Local Plan
Representation ID: 16188
Received: 16/05/2016
Respondent: Mr Hugh Thomson
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.
See attached
Object
Draft Local Plan
Representation ID: 16189
Received: 16/05/2016
Respondent: Mr Hugh Thomson
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.
See attached
Object
Draft Local Plan
Representation ID: 16280
Received: 18/05/2016
Respondent: Margaret Noonan
Q2. Very dissatisfied that Brentwood Borough Council proposes to located over one third of its new housing on the edge of their border next to Basildon, with the effect that the burden (e.g. infrastructure) will fall on the Borough of Basildon.
Q3. Very dissatisfied with the way in which Brentwood Borough Council are proposing to spread housing need across the Borough.
See attached
Object
Draft Local Plan
Representation ID: 16340
Received: 18/05/2016
Respondent: Miss Elaine Heaps
Very dissatisfied that Brentwood Borough Council proposes to located over one third of its new housing on the edge of their border next to Basildon, with the effect that the burden (e.g. infrastructure) will fall on the Borough of Basildon.
Very dissatisfied with the way in which Brentwood Borough Council are proposing to spread housing need across the Borough.
See attached
Object
Draft Local Plan
Representation ID: 16346
Received: 18/05/2016
Respondent: Mrs R Nash
Very dissatisfied that Brentwood Borough Council proposes to located over one third of its new housing on the edge of their border next to Basildon, with the effect that the burden (e.g. infrastructure) will fall on the Borough of Basildon.
Very dissatisfied with the way in which Brentwood Borough Council are proposing to spread housing need across the Borough.
See attached
Object
Draft Local Plan
Representation ID: 16352
Received: 18/05/2016
Respondent: Mrs B.I. Staerck
Very dissatisfied that Brentwood Borough Council proposes to located over one third of its new housing on the edge of their border next to Basildon, with the effect that the burden (e.g. infrastructure) will fall on the Borough of Basildon.
Very dissatisfied with the way in which Brentwood Borough Council are proposing to spread housing need across the Borough.
See attached
Object
Draft Local Plan
Representation ID: 16365
Received: 18/05/2016
Respondent: Brooke Williams
Very dissatisfied that Brentwood Borough Council proposes to located over one third of its new housing on the edge of their border next to Basildon, with the effect that the burden (e.g. infrastructure) will fall on the Borough of Basildon.
Very dissatisfied with the way in which Brentwood Borough Council are proposing to spread housing need across the Borough.
See attached