Object

Representation ID: 230

Received: 29/09/2013

Respondent: Basildon Borough Council

Policy S2 identifies that the OAN for Brentwood is 331-373 dwellings per annum or 4,950-5,600 dwellings over the plan period 2015-2030. However, the Local Plan proposes to make provision for just 200 dwellings per annum between 2015 and 2020 and, 250 dwellings per annum between 2020 and 2030, (3,500 homes in total over the plan period). There is therefore a shortfall of between 1,450 and 2,100 homes over the plan period which is not provided for within the Brentwood Local Plan and there is an expectation in the NPPF that in such an instance, the Council would have to demonstrate that in doing so, the adverse impacts would significantly and demonstrably outweigh the benefits, or specific policies in the NPPF. The proposed delivery of 3,500 dwellings over the plan period in Brentwood Borough would also not support the adequate provision of affordable housing that the Borough requires, nor would it provide the level of homes required to support its local economy. The justification for not meeting the full objectively assessed housing needs is not regarded as sufficient. As most of the key evidence is noted as being 'forthcoming' and the Sustainability Appraisal was not completed before the Local Plan was published for consultation, it is questionable as to how these could have been used to formulate the Local Plan's strategy to ensure it is robust and positively prepared. The plan is therefore not in conformity with the NPPF, which states that it should be based on a proportionate, robust evidence base and the justification to Policy S2 does not provide a robust and legitimate reason why Brentwood Council has not sought to meet its objectively assessed need within its boundaries. Basildon Council also raises concerns that the evidence presented does not even support the delivery of Policy S2 and consequently its reduced housing target of 3,500 homes.

Object

Representation ID: 231

Received: 29/09/2013

Respondent: Basildon Borough Council

Appendix 3 identifies Brentwood Borough's housing trajectory. The housing trajectory includes sites that have built from 2012. The plan period for the Brentwood Local Plan is stated as being 2015-2030, therefore Basildon Borough Council would question why the Plan is relying on the delivery of sites from outside the plan period (2012-2014) to help meet the delivery of 3,500 dwellings that are supposed to be delivered within it.

Object

Representation ID: 232

Received: 29/09/2013

Respondent: Basildon Borough Council

The proposed delivery of 3,500 dwellings over the plan period in Brentwood Borough would also not support the adequate provision of affordable housing that the Borough requires, nor would it provide the level of homes required to support its local economy.

Basildon Borough is not within the same Strategic Housing Market Area as Brentwood Borough. Basildon Borough Council would therefore recommend that Brentwood's own Strategic Housing Market Areas be explored first to accommodate unmet need, in line with the NPPF. Subsequently, Basildon Borough Council strongly objects to accommodating Brentwood's unmet needs and therefore Brentwood Borough Council's preferred approach.

Object

Representation ID: 233

Received: 29/09/2013

Respondent: Basildon Borough Council

It is recommended that a comprehensive review of Brentwood's Green Belt boundaries should be carried out, rather than relying on the broad conclusions drawn from the sub-regional "Heart of Essex Economic Futures" study as the basis for the spatial strategy and the conclusion that the objectively assessed needs cannot be met. Brentwood Borough is not unique in its circumstances to being largely constrained by Green Belt. Basildon Borough Council does not feel it is reasonable for Basildon Borough to accommodate some or all of Brentwood's unmet housing needs, when it faces similar environmental and Green Belt constraints.

Object

Representation ID: 236

Received: 29/09/2013

Respondent: Basildon Borough Council

The only recognition of Crossrail within the Local Plan is a proposed 'Park and Walk' scheme. The social and economic opportunities have not been explored as a way to address the Borough's growth pressures and this is at odds with the limited growth being proposed in Shenfield, when in reality, Crossrail improvements at Shenfield are likely to make the area more accessible as a place to live and work, supporting additional jobs/homes to help Brentwood meet its OAN. It is recommended that Crossrail be explored further and it is questionable whether the current strategy is the most appropriate for Brentwood.

Support

Representation ID: 238

Received: 29/09/2013

Respondent: Basildon Borough Council

In principle, Basildon Borough Council supports the steps being taken by Brentwood Borough Council in proactively meeting the needs of Gypsies and Travellers as part of its Local Plan, but questions whether the Policy is flexible enough to meet future needs given that the Essex-wide Gypsy and Traveller Accommodation Assessment (GTAA) is currently being updated and that the figures may therefore change beyond the extra 14 currently estimated, particularly when neighbouring area's needs and ability to provide are considered.