Object

Representation ID: 832

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

For the reasons set out in our response to Policy S1, a target of only 3,500 dwellings is considered fundamentally unsound as it does not meet OAN.
Paragraph 2.20 states that "Growth above a certain level would lead to significant impacts: notably harm to the landscape, Green Belt, settlement identity and character and town centre traffic congestion". While we acknowledge that the Local Plan must respond to the Borough's environmental characteristics, BBC as noted above 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. Given BBC's significant housing shortfall against OAN, it is recognised that Green Belt land will need to be released around Brentwood town as the largest settlement in the Borough. In addition to settlement specific housing needs to address localised affordability issues and retain the viability and vitality of local shops and services.