Fig. 4. Developing the Spatial Strategy

Showing comments and forms 1 to 2 of 2

Object

Preferred Site Allocations 2018

Representation ID: 18067

Received: 06/03/2018

Respondent: mrs zoe chambers

Representation:

There seems little reference in your consultation to the fact that to build Dunton Garden Village it will destroy 257 hectares of Green Belt. Your consultation appears to be leading residents to support the DGS project without making this fact clear. you emphasise that 100% of your housing requirements will be met, along with traveller needs if this option is supported.

I find it pretty underhand in page 27 of 'our strategy for growth' (photo uploaded) that you state clearly "green belt land" in your list of areas.....other than 'Dunton Garden Village where you have labelled it 'strategic allocation'.

Full text:

There seems little reference in your consultation to the fact that to build Dunton Garden Village it will destroy 257 hectares of Green Belt. Your consultation appears to be leading residents to support the DGS project without making this fact clear. you emphasise that 100% of your housing requirements will be met, along with traveller needs if this option is supported.

I find it pretty underhand in page 27 of 'our strategy for growth' (photo uploaded) that you state clearly "green belt land" in your list of areas.....other than 'Dunton Garden Village where you have labelled it 'strategic allocation'.

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 18516

Received: 13/03/2018

Respondent: Mr Roland Lazarus

Representation:

This Draft Plan has lost sight of Green Belt fundamental aim. Much of the currently open Green Belt would be lost to housing despite NPPG advise. Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm. The Council do not have sufficient grounds to believe that the unmet need for housing or any other very special circumstances should apply here or could in combination constitute the very special circumstances required.

Full text:

Strategic Objectives
I agree with and support SO1, SO2 SO3, SO6, SO15, SO16, SO17, SO18 and SO22
I disagree with and object to SO4 and SO7

Housing Need
On page 18 the 2014 DCLG household projections reveals, when converted to dwellings, an increase from 322 to 348 net new dwellings is the starting point for the annual objectively assessed need for housing. This is lower than the 362 dwellings figure in the Draft Local Plan (2016).
Due to the worsening of the affordability ratio in Brentwood and the increased costs of rental levels, I conclude there is a need for a reasonable upwards move in the proportion of new dwellings that are affordable. The higher price of housing implies greater profits from developments. This allows for a higher percentage of affordable housing to be delivered. The exact figure needs to be tested for viability but I expect mixed housing at 50% or above affordable housing should be achievable on sites of 15 or more new homes qualifying for affordable housing delivery. There is a ready supply of housing currently available through estate agents that could be termed unaffordable housing for those on or below average pay. The need for affordable housing, rental and purchase, can more truly be called 'need'. As the proportion of affordable housing delivered through new housing developments increases the total number of new houses required to deliver the needed number of affordable new homes can be reduced. If, as many are predicting and is expected due to leaving the EU, housing costs starts to fall, the proportion of affordable housing delivered from new developments would have to fall but general affordability would be improving at the same time. I reject the DCLG proposed new standard formula for housing need. Government schemes boosting the supply of money for new houses, buy-to-let investment schemes and other investment vehicles (UK and foreign) have distorted the market for housing artificially inflating prices, I therefore reject the adoption of 380 dwellings per annum as the OAHN.
The OAHN of 348 dwellings per annum equates to 6,960 dwellings across the plan period (2013-33).
2,109 or 30% have already been built, have planning permission or are expected to come through windfall delivery.
1,732 or 25% can be built on urban and other brownfield sites.

Green Belt
On page 34 at 74 it says "Government policy states that Traveller sites (temporary or permanent) in the Green Belt are inappropriate development, which by definition is harmful to the Green Belt and should not be approved, except in very special circumstances. The PPTS states that Green Belt boundaries should be altered only in exceptional circumstances." This is the only reference to the need for exceptional circumstances in the document but paragraph 83 of the NPPF says "Once established, Green Belt boundaries should only be altered in exceptional circumstances" but we are not told what these are or if there any. Paragraph 87 makes it even clearer saying "As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."

Green Belt is meant to be a restraint. Paragraph 87 of NPPF states "The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." This Draft Plan has lost sight of this. Much of the currently open Green Belt would be lost to housing despite NPPG advise:-
In decision taking, can unmet need for housing outweigh Green Belt Protection? 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. Planning Practice Guidance, Housing and economic land availability assessment, Methodology - Stage 5: Final evidence base, 6 March 2014. Paragraph 034 Reference ID: 3-034-20141006 from the NPPG

The Council do not have sufficient grounds to believe that the unmet need for housing or any other very special circumstances should apply here or could in combination constitute the very special circumstances required.

Green Belt serves five purposes:
●● to check the unrestricted sprawl of large built-up areas;
●● to prevent neighbouring towns merging into one another;
●● to assist in safeguarding the countryside from encroachment;
●● to preserve the setting and special character of historic towns; and
●● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

To varying degrees at each site, now in Green Belt, there would be harm done to these purposes.

Green Belt is meant to direct development elsewhere. In this Draft Plan 4,327 new homes, or 70% of the 6,154 to be built, are to be directed to former Green Belt land. On top of this, employment site 187 south of East Horndon Hall, would also be lost from Green Belt. This is unrestrained growth, it negates the aim and purposes of Green Belt.

That said, the harm done to Green Belt is different at different sites. Brownfield development in Green Belt may not be inappropriate. It is true that many of the chosen sites are already compromised by some buildings on site or around it or proximity of the railway or A12.

I object to the 2,500 (potentially rising to 3,500) new homes at Dunton Hills.

I object to sites 076 and 077 at Blackmore and 075B and 194 at Kelvedon Hatch.