Comment

Representation ID: 35

Received: 11/08/2013

Respondent: Mrs Ann Cardus

Where is the definition of affordable?

Object

Representation ID: 232

Received: 29/09/2013

Respondent: Basildon Borough Council

The proposed delivery of 3,500 dwellings over the plan period in Brentwood Borough would also not support the adequate provision of affordable housing that the Borough requires, nor would it provide the level of homes required to support its local economy.

Basildon Borough is not within the same Strategic Housing Market Area as Brentwood Borough. Basildon Borough Council would therefore recommend that Brentwood's own Strategic Housing Market Areas be explored first to accommodate unmet need, in line with the NPPF. Subsequently, Basildon Borough Council strongly objects to accommodating Brentwood's unmet needs and therefore Brentwood Borough Council's preferred approach.

Comment

Representation ID: 325

Received: 02/10/2013

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

The objectives which underpin this policy and are NPPF compliant are supported. It is considered however that there is a potential conflict between this policy and DM24. Policy DM24 acknowledges that whilst a 35% affordable housing target is in place this target maybe be reduced and and in some cases dependent on a viability assessment it may not be possible to make any provision. This needs to be reflected in CP8 and the second paragraph should be amended as per representation. See attachment.

Support

Representation ID: 412

Received: 02/10/2013

Respondent: JTS Partnership LLP

Whilst we recognise the need to provide affordable housing within the Borough, we welcome the Council's understanding that such provision can potentially impact upon the viability of a scheme. Accordingly, JTS welcomes, and supports, the final paragraph of the policy.
We also consider that the policy should not seek any affordable housing provision on sites of less than 15 units. On smaller sites (14 units and below) it is often physically, or logistically, difficult, or financial disadvantageous, to include affordable housing on site. These problems become more acute, the smaller the site gets.

Support

Representation ID: 441

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

Whilst we recognise the need to provide affordable housing within the Borough, we welcome the Council's understanding that such provision can potentially impact upon the viability of a scheme. Accordingly, the company welcomes, and supports, the final paragraph of the policy.
We consider that the policy should not seek any affordable housing provision on sites of less than 15 units. On smaller sites (14 units and below) it is often physically, or logistically, difficult, or financial disadvantageous, to include affordable housing on site. These problems become more acute, the smaller
the site gets.

Object

Representation ID: 468

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

Whilst the Company recognises the need to provide affordable housing within the Borough, it welcomes the Council‟s understanding that such provision can potentially impact upon the viability of a scheme. Accordingly, it welcomes, and supports, the final paragraph of the policy. It also considers that the policy should not seek any affordable housing provision on sites of less than 15 units. On smaller sites (14 units and below) it is often physically, or logistically, difficult, or financial disadvantageous, to include affordable housing on site. These problems become more acute, the smaller the site gets.

Object

Representation ID: 533

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters recognise the need to provide affordable housing within the Borough and welcome the Council's acknowledgement that the provision of affordable housing can impact upon the economic viability of a development. Brentwood Council has chosen to adopt a low threshold for on-site provision (5 dwellings). It is considered that the minimum threshold should be maintained at 15.

It is often physically or logistically difficult or financial disadvantageous to include affordable housing on site. A greater flexibility should be written into the policy to enable, as an alternative, the provision of a financial contribution in lieu of on-site provision.

Object

Representation ID: 574

Received: 02/10/2013

Respondent: Hansteen Holdings Plc

Agent: McGough Planning Consultants

Policy DM24 requires developments of 15 or more houses within Brentwood urban area to make provision for 35% affordable housing. Para 4.110 refers to affordable housing thresholds and targets outside the Brentwood urban area. There is some ambiguity whether this encapsulates the LPA's preferred option for affordable housing outside the Brentwood urban area. Clarification is sought.

Support

Representation ID: 601

Received: 23/09/2013

Respondent: Ingatestone and Fryerning Parish Council

We welcome the fact that the Local Plan seeks to maximise affordable housing and this accords with the recommendations in the Village Design Statement and our views on the development of the Bell Mead site.

Support

Representation ID: 624

Received: 23/09/2013

Respondent: Ingatestone and Fryerning Parish Council

We note and agree with section a. which defines the number of affordable homes that will need to be built as part of the Bell Mead development (042).

Object

Representation ID: 796

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

By implementing this policy the West Horndon strategic allocation will deliver the equivalent of 525 affordable homes, which would only comprise a total of 2035 households once the allocation is built out, (26% of the village). This
seems disproportionately high and raises questions over the capacity of the newly provided infrastructure and services to accommodate this provision. Surely it would be more sustainable if the affordable provision was more proportionately distributed amongst Brentwood, Shenfield and Ingatestone in accordance with their size and opportunities for local employment, retail, leisure and education.

Object

Representation ID: 828

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The policy is very precise on smaller sites and the amount of affordable housing required.

Whilst we accept that the Borough has a high level of housing need, such a prescriptive policy for smaller development sites is likely to have an effect on development viability and may ultimately affect the delivery of smaller sites.

Similarly the requirement for 'at least' 35% affordable dwellings may cause viability problems for the delivery of some larger sites. Setting a 35% target for all sites of 15 dwellings or more would be more realistic and more effective in delivering housing sites across the Borough.

Object

Representation ID: 920

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Policy DM24 should allow for off-site contributions subject to a robust demonstration that such contributions would be necessary to mitigate the impact of development itself and a more viable option. This suggested approach would better accord with the NPPF (paragraph 187) in looking for solutions rather than problems, and working proactively to ensure developments improve the economic, social and environmental conditions of the area.

Support

Representation ID: 1119

Received: 03/09/2013

Respondent: Thriftwood Scout Campsite & Activity Centre

Request that a 'finger' of land at Thriftwood Scout Campsite be considered for the provision of new affordable housing (land which borders Beech Ave/Cherry Ave and Knights Way).

Comment

Representation ID: 1122

Received: 25/07/2013

Respondent: Mr. Chris Hart

What is the definition of affordable housing and what would the character of these properties be.

Object

Representation ID: 1195

Received: 02/10/2013

Respondent: Gladman Developments

Gladman note that the Council's proposed housing requirement will significantly constrain the scope for addressing affordable housing needs in Brentwood. This supports the need to increase the Council's overall housing requirement.

Object

Representation ID: 1209

Received: 01/10/2013

Respondent: Strutt & Parker LLP

This policy does not provide clarification on the level of contribution which would be required from schemes of 1-4 dwellings. The policy would seem to suggest that a unit could be provided on-site by such sized schemes. However, this contradicts the distinction placed on schemes of 5-7 units and those of 1-4 units. Furthermore, in terms of a financial contribution, it is not clear how this is to be calculated or determined. Without such information, this policy cannot be supported and is considered to be unsound. The policy should be amended to provide further clarification.

Object

Representation ID: 1271

Received: 01/10/2013

Respondent: Mr Richard Romang

DM24 / 25:- Focus on elderly housing provision. It has become noticeable at borough level and especially in relation to rural communities that there is a shortage of affordable housing for school leavers and elderly residents. The issue of accommodation for the elderly who are looking for smaller manageable dwellings has been compounded by the regular granting of planning permission to demolish existing bungalows ad develop on the land often replacing the bungalow with expensive houses. I feel that more provision should be made for the protection of dwellings suitable for elderly residents.

Object

Representation ID: 1586

Received: 16/09/2013

Respondent: Clearbrook Group Plc

Agent: Clearbrook Group Plc

Drop the need for an Affordable Housing contribution from retirement housing schemes so as to make them more financially viable.

Object

Representation ID: 1893

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

In line with the NPPF (paragraphs 50 and 159), the Policy appropriately identifies that viability, which should be supported by a toolkit appraisal, shall be taken into account in the negotiation of rates of affordable housing.
Furthermore, Policy DM24 should allow for off-site contributions subject to a robust demonstration that such contributions would be necessary to mitigate the impact of development itself and a more viable option. This suggested approach would better accord with the NPPF (paragraph 187).