Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

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Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Local Development Plan Housing Trajectory

Representation ID: 24268

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

A total of 7,752 dwellings be provided in the Borough between 2011-2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. The stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. Of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at DHGV and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at DHGV. The ability of larger strategic sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin Review (2018); and issues with their complexity, have been ably set out in the Lichfield's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. Therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

3.23

Representation ID: 24269

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

A total of 7,752 dwellings be provided in the Borough between 2011-2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. The stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. Of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at DHGV and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at DHGV. The ability of larger strategic sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin Review (2018); and issues with their complexity, have been ably set out in the Lichfield's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. Therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

4.23

Representation ID: 24270

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

4.22

Representation ID: 24271

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY SP04: DEVELOPER CONTRIBUTIONS

Representation ID: 24277

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY BE01: FUTURE PROOFING

Representation ID: 24287

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. It is suggested that Policy BE01 should be set out as supporting text rather than a specific policy.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY BE02: SUSTAINABLE CONSTRUCTION AND RESOURCE EFFICIENCY

Representation ID: 24291

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY BE20: ALLOTMENTS AND COMMUNITY FOOD GROWING SPACE

Representation ID: 24292

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY BE22: OPEN SPACE IN NEW DEVELOPMENT

Representation ID: 24293

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes.

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY HP01: HOUSING MIX

Representation ID: 24294

Received: 19/03/2019

Respondent: Strutt & Parker LLP

Agent: Strutt & Parker LLP

Representation Summary:

The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations.

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