Local Plan 2015-2030 Preferred Options for Consultation
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Local Plan 2015-2030 Preferred Options for Consultation
S1: Spatial Strategy
Representation ID: 728
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
1.The premise of the spatial strategy appears to be to protect the Green Belt around the two principal urban areas of Brentwood and Shenfield and that this overrides other requirements such as meeting 'objectively assessed needs' in accordance with the NPPF. The starting point for establishing the quantum of residential development to be provided within the Plan period should to meet 'objectively assessed needs' (Paragraph 14, NPPF). This was assessed by the Council (Alternative Option 1) and rejected on the basis that this level of growth (4,960 to 5,600 dwellings) "would require significant Green Belt release, significantly worsen congestion in Brentwood Town Centre and irrevocably change the rural character of the Borough." It goes on to state that "significant investment in infrastructure and services would be required to support this level of growth and there is no guarantee this would be forthcoming", none of the evidence base documents produced to date give a clear indication of the extent of Green Belt land required to meet needs relative to the Borough as a whole or an assessment on the impact of this level of development on the rural character of the Borough.
2.In the cases of congestion, infrastructure and services it is not disputed that further development may well have an impact as additional homes and people will result in increased use of infrastructure, but again there is no assessment of the extent of this impact and likely implications, and consequently it is difficult to respond with conclusions on how to quantify the impact. The Plan proposes to expand West Horndon with new infrastructure as part of the development, but does not make clear why the same approach cannot apply to other sites.
3.As many of the evidence base documents referred to in the Draft Local Plan are not currently available, it is not possible to assess whether the impact of meeting objectively assessed needs would "significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole" (NPPF, paragraph 14). It is queried whether these documents were prepared in advance of the Local Plan or whether they are being retrospectively prepared to accord with the 'revised' strategy. Green Belt sites identified as having potential for development in the SHLAA should be considered for inclusion within the Plan with a consequential amendment to Green Belt releases in this policy.
4.Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Comment
Local Plan 2015-2030 Preferred Options for Consultation
S1: Spatial Strategy
Representation ID: 729
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
S2: Amount and Distribution of Residential Development 2015-2030
Representation ID: 731
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
The starting point for establishing the quantum of residential development to be provided within the Plan period should be to meet 'objectively assessed needs' in accordance with paragraph 14, NPPF. The option chosen is contrary to the NPPF and therefore it is inappropriate as it fails to meet 'objectively assessed needs' and there is a lack of evidence to justify this approach. The Plan also fails to "positively seek opportunities to meet the development needs of their area" . There is no evidence to support the selected level of residential development. Further sites should be considered that will help to meet the objectively assessed needs without resulting in adverse impacts that would "significantly and demonstrably outweigh the benefits" (NPPF, paragraph 14). Sites identified within the Council's SHLAA as being 'suitable, available and achievable', such as land at Bayleys Mead could contribute towards fulfilling this objective, providing residential development adjoining the urban area of Brentwood. This site should be allocated for development within the Plan period.
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy CP2: Managing Growth
Representation ID: 732
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
This policy requires a consequential amendment resulting from our representations to policies S1 and S2 to enable development of appropriate Green Belt sites. Policy CP2: Managing Growth should be amended to read as follows:
"The Council expects the majority of new development to be provided within or adjoining existing settlements, as identified on the Policies Map, through the development, conversion of previously developed land and buildings or release of appropriate Green Belt sites. In allocating sites..."
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy CP3: Strategic Sites
Representation ID: 735
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
With regard to the proposed identification of West Horndon as a strategic growth location, this clearly involves a reappraisal of Green Belt boundaries and significant infrastructure investment, which conflicts with the constrained approach of the Plan in relation to Brentwood/Shenfield. This is not consistent with that of West Horndon. Given the need for relocation of employment uses, together with the significant lead-in times to deliver new infrastructure, the trajectory suggests that the site could deliver from 2017/18- this is questionable as the Plan is unlikely to be adopted until late 2014,at earliest.
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy CP6: The Baytree Centre
Representation ID: 736
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
With regard to CP5 and CP6, both sites involve the redevelopment of existing commercial and retail premises. There is no expressed commitment from landowners or information on how disruption to existing business will be minimised, and therefore we would be cautious about both the principle and potential delivery from these sites. The Baytree Centre appeared as an allocation in the previous Local Plan, and a recycling of such an allocation adds weight to whether the site can be delivered within the lifetime of the Plan. More information needs to be provided by the Council in justifying their inclusion.
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Support
Local Plan 2015-2030 Preferred Options for Consultation
Policy CP5: William Hunter Way
Representation ID: 745
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
With regard to CP5 and CP6, both sites involve the redevelopment of existing commercial and retail premises. There is no expressed commitment from landowners or information on how disruption to existing business will be minimised, and therefore we would be cautious about both the principle and potential delivery from these sites. The William Hunter Way development appeared as an allocation in the previous Local Plan, and a recycling of such an allocation adds weight to whether the site can be delivered within the lifetime of the Plan. More information needs to be provided by the Council in justifying their inclusion.
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM23 Housing Land Allocations - Major Sites
Representation ID: 746
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
Sites identified within the Council's SHLAA as being 'suitable, available and achievable', such as land at Bayleys Mead could contribute towards fulfilling this objective, providing residential development adjoining the urban area of Brentwood. This site should be allocated for development within the Plan period.
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy CP10: Green Belt
Representation ID: 747
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
Policy CP10: Green Belt should be amended as follows:
"The general extent of the Green Belt across the Borough will be retained subject to allocations made in this Plan affecting Green Belt and where new development has had the effect of consolidating settlement patterns so as to create a defensible boundary. The following settlements..."
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Object
Local Plan 2015-2030 Preferred Options for Consultation
S1: Spatial Strategy
Representation ID: 936
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
Objections to the Plan, on the basis that it is unsound as currently drafted, for the following reasons:
1.The absence of an appropriate, comprehensive and up-to-date evidence base. A robust and credible evidence base must inform the content of the emerging local plan. Local plan policies must be justified by evidence in order to be considered sound. Failure to publish these and other technical documents will deprive interested persons of the opportunity to comment upon them and fully to comprehend how the preferred spatial growth strategy has been decided.
2.The emerging plan does not propose to meet its full objectively assessed needs (OAN) as advised in the NPPF. Seeking to meet such needs is part of the soundness test of being positively prepared (paragraph 182 of the Framework). Proposed provision of 3,500 new dwellings to be built in the Borough between 2015-2030, at an average annual rate of 233 dwellings per annum, is woefully inadequate to meet the needs of Brentwood over the next 15 years. Various studies commissioned by the Council place the housing need target closer to 5000 - 5500 (331 - 362 dwellings per annum) whilst the ONS/CLG projections point to a need for 6000 new dwellings over the plan period (400 per annum).
3.There is no explanation given as to how the shortfall in housing would be addressed. In such circumstances the NPPF advises local planning authorities to accommodate unmet need which cannot wholly be met within their own areas, under a 'duty to cooperate" but there is no evidence that this action has been progressed.
See attached
