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

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Object

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

POLICY NE13: SITE ALLOCATIONS IN THE GREEN BELT

Representation ID: 23891

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criterion A of this policy requires the delivery of significant community benefits and the wording of the supporting text advises that this is to 'repay' the loss of Green Belt. The release of these sites is to meet housing needs and therefore is self-evidently provide significant community benefits. The requirement for additional provision above and beyond this suggests that the developer has a choice of sites to develop, which is clearly not the case. This requirement is therefore unreasonable, unjustified and inconsistent with national policy.

Attachments:

Object

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

POLICY NE13: SITE ALLOCATIONS IN THE GREEN BELT

Representation ID: 23892

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criterion B advises that allocated sites 'will be' deallocated from the Green Belt. As the removal of land from the Green Belt can only come about through the preparation of a development plan this de-allocation must happen upon adoption of the plan and not presented as a future intention.

Attachments:

Object

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

POLICY SP01: SUSTAINABLE DEVELOPMENT

Representation ID: 23893

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

SP01, criterion D, sub-criterion d: The wording of criterion D(d) does not reflect the wording of the NPPF at paragraph 109, which reads: "Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe." It is therefore inconsistent with national policy. Criterion D(d) should be amended to read:
d. ensures the proposal would not give rise to an unacceptable impact on highway safety, or give rise to a severe residual cumulative impact on the road network

Attachments:

Object

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

POLICY SP02: MANAGING GROWTH

Representation ID: 23894

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The housing requirement set out in SP02 is based on an out-of-date method for calculating the LHN. The most recent advice is that the 2014 HHP should be used. The 2014 HHP with the 2017 affordability ratios applied reveal that the base need is 452, not 350. Although this is broadly similar to the 456 per annum figure in the policy, it does not allow for the buffer that the Council has considered necessary.
This raises potential consistency issues with national policy that may influence the ability of the plan to deliver the housing required to fulfil the identified need.

Attachments:

Object

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

POLICY SP03: HEALTH IMPACT ASSESSMENTS (HIAs)

Representation ID: 23895

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The policy presents an unnecessary burden on those developers bringing forward allocated sites where the infrastructure capacity on an area should have already been identified through the plan-making process. It is considered that HIA should be confined to strategic sites (500 units or more) to reflect the fact that they are required where significant impacts are anticipated. Other impacts referred to in the policy are a standard part of the development management process and do not warrant a further assessment to be included with the application.

Attachments:

Object

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

POLICY SP03: HEALTH IMPACT ASSESSMENTS (HIAs)

Representation ID: 23896

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criterion C places the burden of delivery of health and social care facilities on the developer who is unlikely to be a health and social care provider and therefore cannot reasonably be expected to deliver such facilities or to address existing deficiencies. It may be that such facilities are entirely absent in any area where development is allocated despite an existing need. In such case, the wording of the policy means that a developer could be required to provide more than is necessary to mitigate the impacts arising from the development. This conflicts with national policy and could prejudice deliverability.

Attachments:

Object

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

POLICY SP04: DEVELOPER CONTRIBUTIONS

Representation ID: 23897

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criterion A expects developers to guarantee the sustained provision of infrastructure. The responsibility for sustained provision rests with the infrastructure provider and this should not be transferred to the developer. Criterion F requires a Financial Viability Assessment where there is conflict with planning policy requirements. It does not specify which policy conflicts would trigger this need, so as currently written would apply to any such conflict. This presents an unreasonable and unnecessary burden for a developer where the conflict arises of feasibility rather than viability issues. There may also be sound material considerations for departing from a particular policy.

Attachments:

Object

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

POLICY SP06: EFFECTIVE DELIVERY OF DEVELOPMENT

Representation ID: 23898

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The policy does not define what it considers to be a 'large complex allocation site' and as such could impose a blanket requirement for the submission of a masterplan and a design code as part of the submission for all allocated sites. This is considered to be an unreasonable and unnecessary burden that is not supported by the NPPF or the PPG and is not justified by the individual site allocations. It also has the potential to slow down the delivery of sites, which for a borough with a poor track record of delivery is not sensible.

Attachments:

Object

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

R03 - Strategic Housing Allocation - Land north of Shenfield

Representation ID: 24172

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Redrow Homes

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The site is allocated for development and signposted in Policy SP02: Managing Growth. The site is currently in the Green Belt and the allocation anticipates the development of around 825 homes and associated infrastructure and facilities. The land to the east of the Chelmsford Road is in two ownerships, and both land promoters have agreed the principles of an overall master plan with Brentwood Borough Council. The Draft Local Plan anticipates that the homes will be delivered between 2023/24 and 2030/31; Redrow Homes is intending to see its portion of the new housing completed prior to this period, enabling it to contribute to the 5-Year Housing Land Supply. Redrow Homes, concerned to see its part of the Draft Plan implemented as quickly as possible, which requires the Draft Plan to be adopted equally soon, has considered the case made in the Draft Plan for the release of land from the Green Belt.

Object

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

3.23

Representation ID: 24173

Received: 19/03/2019

Respondent: Redrow Homes

Agent: Redrow Homes

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The NPPF 2018 has two main stipulations relating to alterations of Green Belt boundaries: "136. (part) Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries..." "137 (part) Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.." The second requirement should be conducted before the first. The Council's overall approach to site selection summarised in Figure 7 of that document and in para 3.23 of the Draft Plan. This sequential approach includes brownfield sites in the Green Belt but not greenfield sites in the Green Belt. Furthermore para 3.23 confuses a number of site selection criteria, for example proximity to transport facilities, as well as the key quality of the sites.

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