Object

Representation ID: 305

Received: 11/09/2013

Respondent: Epping Forest District Council

(1) Epping Forest Council is not convinced that Brentwood Council has adequately justified its position that it is unable to make full provision for its objectively assessed housing needs - at the very least, it should undertake a comprehensive Green Belt boundary review and identify and assess in detail potential mitigation measures;
(2) The Preferred Options document makes no reference to joint working as encouraged by para 179 of the National Planning Policy Framework. Consequently there is no indication of how Brentwood intends to try to make provision for the outstanding number (2,100) of new dwellings outside the Borough boundary;
(3) Experience elsewhere has already shown that there is a greater risk of the Local Plan being challenged on soundness grounds, as it has not been "positively prepared" in accordance with para 182 of the National Planning Policy Framework;
(4) Because of the lack of justification and (a) the need to meet its own objectively assessed housing figure; (b) significant environmental and infrastructure constraints; and (c) being in a different Housing Market Area, Epping Forest Council is not in a position to make any provision for Brentwood's unmet housing needs;
5. Further traveller provision in the West Horndon area, as part of a mixed-use development, is noted.

Support

Representation ID: 769

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Para 2.20 highlights that the Council does not envisage meeting the full level of growth proposed due to significant constraints which would impact on the boroughs character. These findings may prove o be correct, however they should not be seen as a pre-determinant to the development plan process.

Paragraph 2.21 in turn, implies that the unmet need can be met through the duty to cooperate process in adjoining boroughs. This is fundamental in determining the councils housing land allocation, and accordingly this discussion should lead not follow the proposed growth option. In the event that adjoining boroughs can not assist in meeting Brentwoods growth, the borough need to ensure it has sufficient flexibility to meet its own housing growth. In our view additional development can be accommodated, without adverse environmental impact. An obvious approach is to rely on those gb incursions presently identified. However Brentwood is right that development should not come at any cost and therefore both existing and future allocations should be capable of demonstrating sufficient infrastructure can be brought forward to contribute to the overall improvement of Brentwood for residents and visitors alike.

Object

Representation ID: 904

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

1. Significant proportion- It is considered that paragraph 2.20, and the process it identifies to support the Local Plan is unsound as it does not accord with the key principles of the NPPF. Paragraph 2.20 states that "The preferred spatial strategy seeks to accommodate a significant proportion of this (objectively assessed) development need". This approach does not accord with the NPPF (paragraph 47), as Local Plans should plan to exceed housing targets, not simply accommodate a "significant proportion" of the identified housing need. The Plan makes provision for 3,500 dwellings over the plan period, however OAN, based on household and population projection figures, suggests this figure should be at least 5,600 dwellings. 3,500 dwellings only represents approximately 60% of OAN within BBC, and thus cannot be described as a 'significant' proportion.
2. Limits to Growth- While we acknowledge that the Local Plan must respond to the Borough's environmental characteristics, BBC have not yet carried out a Green Belt assessment, and to conclude that growth above a certain level would lead to "significant impacts" is entirely unjustified. The Plan appears to be based on an assertion-led strategy, with the evidence base still to be finalised after publication of key policies. Given the lack of transparency in the Plan preparation process, the 'preferred' growth strategy is based on constraints that have not been assessed. It instead represents an entirely new approach which has not been consulted on robustly at any of the previous consultation stages. Notwithstanding the lack of evidence explaining the reasoning behind the Plan's inability to meet OAN, PINS have outlined that the constraints identified by BBC should not be used to limit growth required to meet OAN. PINS have identified that LPAs should explore all reasonable options to fulfill OAN. Where constraints are not fixed (i.e. they are not physical constraints such as floodplain), LPAs should plan positively to overcome the identified constraints. It is therefore clear that unfixed constraints including transport capacity and landscape impact should not be used as reasons to limit growth below OAN.

Object

Representation ID: 1551

Received: 01/10/2013

Respondent: D. Lessons

a) The Brentwood Borough Plan with regard to West Horndon clearly has fundamental shortcomings. It does not, therefore, meet the criteria of being either "sound" or "robust".

b) There was no explanation of how this current Borough Plan was achieved, and why it should differ so dramatically from the one that was presented two years ago. The current plan fails the "soundness test" set out in NPPF, paragraph 182.

c. This plan cannot be said to respond to local needs without a further, in depth study of West Horndon, taking into account infrastructure.

Object

Representation ID: 1552

Received: 01/10/2013

Respondent: Mr. David Gale

The Brentwood Borough Plan with regard to West Horndon clearly has fundamental shortcomings. It does not, therefore, meet the criteria of being either "sound" or "robust".

a. There was no explanation of how this current Borough Plan was achieved, and why it should differ so dramatically from the one that was presented two years ago. The current plan fails the "soundness test" set out in NPPF, paragraph 182.

b. This plan cannot be said to respond to local needs without a further, in depth study of West Horndon, taking into account infrastructure.

Object

Representation ID: 1888

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

1. Significant proportion- It is considered that paragraph 2.20, and the process it identifies to support the Local Plan is unsound as it does not accord with the key principles of the NPPF. Paragraph 2.20 states that "The preferred spatial strategy seeks to accommodate a significant proportion of this (objectively assessed) development need". This approach does not accord with the NPPF (paragraph 47), as Local Plans should plan to exceed housing targets, not simply accommodate a "significant proportion" of the identified housing need. The Plan makes provision for 3,500 dwellings over the plan period, however OAN, based on household and population projection figures, suggests this figure should be at least 5,600 dwellings. 3,500 dwellings only represents approximately 60% of OAN within BBC, and thus cannot be described as a 'significant' proportion.
2. Limits to Growth- While we acknowledge that the Local Plan must respond to the Borough's environmental characteristics, BBC have not yet carried out a Green Belt assessment, and to conclude that growth above a certain level would lead to "significant impacts" is entirely unjustified. The Plan appears to be based on an assertion-led strategy, with the evidence base still to be finalised after publication of key policies. Given the lack of transparency in the Plan preparation process, the 'preferred' growth strategy is based on constraints that have not been assessed. It instead represents an entirely new approach which has not been consulted on robustly at any of the previous consultation stages. Notwithstanding the lack of evidence explaining the reasoning behind the Plan's inability to meet OAN, PINS have outlined that the constraints identified by BBC should not be used to limit growth required to meet OAN. PINS have identified that LPAs should explore all reasonable options to fulfill OAN. Where constraints are not fixed (i.e. they are not physical constraints such as floodplain), LPAs should plan positively to overcome the identified constraints. It is therefore clear that unfixed constraints including transport capacity and landscape impact should not be used as reasons to limit growth below OAN.