Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
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Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Plan Period and Review
Representation ID: 23662
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
The proposed PSLP 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 (paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption. This deficiency in the PSLP is of particular relevance given that the Borough is predominantly Green Belt, and 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.
Paragraphs 1.1 - 1.5 of the PSLP and all references throughout the PSLP including supporting text and Policies should be amended to refer to a period of at least 15yrs from date of adoption. It is suggested that this be at least 2016 - 2035. Policies SP02; HP07; and PC02 should be amended to refer to a minimum of 15yrs from date of adoption with all housing and land requirements adjusted accordingly.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
POLICY SP02: MANAGING GROWTH
Representation ID: 23663
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
Housing requirement needs to be recalculated, factoring in:
-PPG 's confirmation that 2014-based subnational household projections should be used;
- unmet needs of neighbouring authorities (potentially from Epping);
-potential development needs beyond Plan period by an additional two years' worth of development needs, that is to 2035, to ensure the Green Belt will endure beyond the plan period and allow sufficient flexibility.
Housing requirement number to be recalculated.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Local Housing Need
Representation ID: 23667
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
Brentwood's most recent five-year housing land supply, reported in the Five Year Housing Land Supply Statement 2018, is 4.1 years; however, this is predicated on outdated requirement, therefore, the actual housing land supply is considerably less. The HLSS includes sites without detailed planning permission and without evidence they will be delivered within five years, these cannot be considered deliverable for the purposes of the five-year housing land supply. The acute housing land supply shortage underlines the importance of allocating sites that can deliver early in the plan period and avoiding over reliance on large strategic sites.
Aditional non-strategic sites are required. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings).Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Appendix 1: Local Development Plan Housing Trajectory
Representation ID: 23671
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
There is a long process before development on larger sites can begin, which render their ability to come forward quickly uncertain; therefore, it is totally unrealistic to project that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23, or for strategic sites are expected to deliver 1,555 dwellings within 5yrs of adoption. It would not be justified to rely on these sites to meet short term housing delivery.
Appendix 1 should be amended to reflect the evidence provided by available evidence on the delivery of major developments. Additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Local Housing Need
Representation ID: 23672
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
The Plan specifies that windfall sites will deliver 41 units/year in the last 10 years of the Plan period (totalling 410 units to be delivered by windfall sites). The reliance on windfall delivering seems unjustified and undeliverable. In addition, there is no robust reason why instead of allocating windfall sites to the last 10 years of the Plan, additional smaller sites could not be allocated in order to provide greater certainty of delivery and to improve the housing land supply, especially within the 5 years of the Plan being adopted, when the housing land position is at its weakest.
Release additional, suitable Green Belt sites in order to assist with the delivery of homes over the Plan period, including to meet the need for specialist housing.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
POLICY HP04: SPECIALIST ACCOMMODATION
Representation ID: 23675
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
The Plan's broad definition of Specialist Accommodation, which include Gypsies and Travellers who no longer exercise a nomadic lifestyle, is potentially too broad to meet the needs for older people. The Plan does not, therefore, give an accurate representation of the type of accommodation the Plan is seeking to deliver and for what specific group(s).
Release additional, suitable Green Belt sites in order to assist with the delivery of homes over the Plan period, including to meet the need for specialist housing.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Specialist Accommodation
Representation ID: 23680
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
There is an acute need for specialist accommodation to meet the needs of an ageing population, which the Plan proposes to provide for through care homes on strategic allocations and Policy HP04. The proposed care homes on strategic allocations will provide in total 180 beds of C2 accommodation, falling significantly short of the identified requirement for 494 additional units; whereas policy HP04 is not clear as to how much specialist accommodation, where, or how it is delivered. A more wholistic and supportive approach towards elder population's housing needs will be required.
Suggest specific housing sites are delivered to meet the needs of an ageing population and the modifications sought, recommended policy wording will follow in a subsequent email to BBC.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
POLICY HP04: SPECIALIST ACCOMMODATION
Representation ID: 23683
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
The policy is not clear as to how much, where, or how specialist accommodation and independent ling are expected to be delivered. It is difficult to see where a new site within the existing built up area will come forward for specialist accommodation, casting further doubts on the effectiveness of Policy HP04. The approach is neither positively prepared, consistent with national policy, nor effective.
Allocate deliverable sites to meet ageing population's need and reflect the objectives set out in the Plan in relation to accommodation for older people as the Plan has already (presumably) exhausted the available sites outside of the Green Belt.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Housing Allocations
Representation ID: 23685
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
Site 073 at Mountnessing should be allocated. The village of Mountnessing falls within the settlement classification 3 which is identified as being able to accommodate urban extensions, therefore Mountnessing should be considered a sustainable location to assist in the delivery of the spatial strategy. Site has accessibility to infrastructure and surrounding settlements; its location next to the A12 represents potentials to maximise opportunities around existing transport infrastructure and networks and to support the 'Transit-orientated Growth' strategy.
Site 073 at Mountnessing should be allocated.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.
