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

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Object

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

Plan Period and Review

Representation ID: 24164

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed period runs until 2033. Assuming - optimistically - adoption in 2019 this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption. Given that Brentwood is predominantly Green Belt, failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required, contrary to the NPPF and undermining permanence of the Green Belt.

Attachments:

Object

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

Local Housing Need

Representation ID: 24165

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Government now confirms that the 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method, which result in a requirement of 452 dwellings per annum as a minimum. NPPF sets out that Local Plans should take into account:
- sufficient flexibility to be able to respond to rapid change
- ensure that the revised Green Belt can endure beyond the plan period
- unmet needs of neighbouring authorities.
Brentwood proposed annual housing targetis only fractionally above the minimum housing requirement derived from the Standard Method, and does not consider any of the above.

Attachments:

Object

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

Local Housing Need

Representation ID: 24166

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The NPPF confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years. Using the 2014-based subnational household projections and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.

Attachments:

Object

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

Local Housing Need

Representation ID: 24167

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Failed to demonstrate a five-year housing land supply ('HLSS'). The Borough's most recent reported 5YHLS (Five Year Housing Land Supply Statement, November 2018) is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need. It includes sites without detailed planning permission and without evidence such sites will be delivered within five years. The figure of 653 dwellings may overstate housing supply. Compared to a requirement of 2,712 it represents a 1.2-year housing land supply.

Attachments:

Object

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

Appendix 1: Local Development Plan Housing Trajectory

Representation ID: 24168

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Dunton Hills Garden Village (DHGV) is projected to delivery housing completions within the first five years of the plan. This is a major strategic development, delivery will require significant amount of work, time and coordination and input of stakeholders. before development can even begin. Therefore, it is totally unrealistic to project that 100 homes will be completed at DHGV as early as 2022/23.

Attachments:

Object

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

Specialist Accommodation

Representation ID: 24169

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Lack of evidence of how the accommodation needs for older people have been assessed. The Plan proposes care homes through residential development within strategic housing allocations at Land at West Horndon Industrial Estate (Policy R02); Land north of Shenfield (Policy R03); Ford Headquarters and Council Depot (Policies R04 and R05). These would provide, in total, 180 beds of Use Class C2 accommodation. In the absence of an assessment of need, it is unclear if this will meet need in quantitative terms. In addition, all of these are strategic allocations, and will inevitably be relatively long lead-in times to delivery.

Attachments:

Object

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

Spatial Strategy Driving Factors

Representation ID: 24170

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Hutton is identified as Category 1 - Main Town. It is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. However, notwithstanding the above, the PSLP proposes to direct no housing growth to Hutton. This contrasts sharply with the proposed approach to the other settlements identified as Category 1.

Attachments:

Object

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

Housing Allocations

Representation ID: 24171

Received: 19/03/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

A considerable amount of technical work demonstrate that land at Rayleigh Road is sustainable, suitable, available and achievable site to help meet the Borough's housing need. Notably, the Council's evidence base supports the view that the Site is suitable, available and achievable for development. The SA commentary states that is heavily constrained in heritage terms; however no details are provided to explain in what way there fore the SA does not provide a justified reason for the rejection of the Site.

Attachments:

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