Object

Representation ID: 584

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

Support land at Nag's Head Lane, Brentwood for residential development.

Object

Representation ID: 776

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

My client objects entirely to the Council's proposed strategy in relation to the amount and distribution of growth in the Borough on the basis that it conflicts with the National Planning Policy Framework. It should be noted that it also conflicts with the Council's proposed spatial strategy set out in Policy S1 of the draft Local Plan.

1.Brentwood Borough's Objectively Assessed Housing Need. It is difficult to fully understand the OAN for Brentwood Borough because at the time of writing the Council had not published it. Notwithstanding my client's reservations over the process and evidence base, it is nonetheless clear that the OAN figure for the Borough is substantially higher than the target proposed by the Local Plan at policy S2. In this context Brentwood Borough Council's housing target is wholly inadequate and cannot be considered sound.
2.Constraints to meeting OAN. We accept that the Framework attaches great importance to Green Belt and its permanence however due to the considerable deficit between the targeted growth and OAN one would expect that exceptional circumstances exist and therefore a robust assessment of Green Belt boundaries is justified in this instance.
3.Quality of the Evidence. In the first instance we question the omission of a large number of sites which were assessed as suitable, available and deliverable by the Council's SHLAA and did not present insurmountable constraints in the published 'Supporting Document: Draft Site Assessment'. In the case of my client's land at Nags Head Lane, Brentwood the Council's reasons for discounting it (and many other sites) are unknown despite the site assessment suggesting it is actually a suitable allocation. We are therefore left to assume that the site has been discounted almost entirely on the basis of its designation as Green Belt, which does not acord with NPPF.

Object

Representation ID: 778

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

It is difficult to fully understand the objectively assessed housing need (OAN) for Brentwood Borough because at the time of writing the Council had not published the Report prepared by Peter Brett Associates. Paragraph 2.30 of the Local Plan document does identify the OAN figure recommended by the report, however it must nonetheless be considered that this lack of openness seriously undermines the transparency of the plan preparation process and the robustness of the consultation.

Object

Representation ID: 779

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

The Council attaches great importance to Green Belt and its permanence however it also allows boundaries to be altered in exceptional circumstances through the preparation or revision of the Local Plan (paragraph 83). Due to the considerable deficit between the targeted growth and OAN one would expect that exceptional circumstances exist and therefore a robust assessment of Green Belt boundaries is justified in this instance. As this is the only way a Green Belt release can be justified, to ensure the most appropriate growth strategy is proposed and the least sensitive sites developed.

Object

Representation ID: 792

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

A review of the Council's recently published Sustainability Appraisal (SA) gives no confidence that this approach has been implemented by BBC in preparing its draft Local Plan; which instead seems to be a more pre-emptive approach where evidence appears to be retrofitted to the political aims of the Council. We question the omission of a large number of sites which were assessed as suitable, available and deliverable by the Council's SHLAA and did not present insurmountable constraints in the published 'Supporting Document: Draft Site Assessment' including our client's land at Nags Head Lane, the Council's reasons for discounting remain unknown.

Object

Representation ID: 795

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

We question the appropriateness of focussing almost half of the Borough's growth in the village of West Horndon for the following reasons:
1. It directly conflicts with the Council's concerns over the urbanising effects of Green Belt release, as there are few options that would result in such a significant level of urbanisation as would be resultant of the proposed growth in a village of this size.
2. Reasonable Alternatives- It seems full consideration has not been given to Ingatestone as a reasonable option for growth given it has more services and facilities than West Horndon.

Object

Representation ID: 796

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

By implementing this policy the West Horndon strategic allocation will deliver the equivalent of 525 affordable homes, which would only comprise a total of 2035 households once the allocation is built out, (26% of the village). This
seems disproportionately high and raises questions over the capacity of the newly provided infrastructure and services to accommodate this provision. Surely it would be more sustainable if the affordable provision was more proportionately distributed amongst Brentwood, Shenfield and Ingatestone in accordance with their size and opportunities for local employment, retail, leisure and education.

Object

Representation ID: 799

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

Insufficient consideration is given to the significant negative socio-economic effects suggested in the SA as being resultant of under-delivery of housing. This concern is even greater when the likely timeline for delivery of the strategic allocation at West Horndon is considered. We therefore assume that given the level of infrastructure improvements that will be necessary to support the substantial growth in the village and the inadequacy of existing services and infrastructure, it is unlikely that any homes will be delivered until the last 5 years of the Plan, at the earliest. Surely this would exacerbate the 'significant negative socio-economic effects'

Object

Representation ID: 800

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

The growth strategy detailed in policy S2 conflicts with the wording of policy S1. Policy S1 states that development sites will be identified having regard to criterion 2. In the absence of the necessary evidence base to properly assess the appropriateness of the strategy, we would draw the Council's attention to the site being promoted by our client,Land east of Nags Head Lane, Brentwood. Having read the assessment of this site drafted by the Council (2013),we would ascertain that it's omission from the list of proposed allocations actually conflicts with policy S1 and the assertions at paragraph 2.32

Object

Representation ID: 831

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

1. It is considered that the current wording of Policy S1 is unsound as it does not accord with NPPF. Policy S1 states that the Borough "aims to protect the Green Belt other than that required to accommodate a strategic allocation at West Horndon and minor changes to accommodate proposed development on existing development sites in the Green Belt, no change to Green Belt boundaries is envisaged". To date Brentwood Council have not conducted a review of their Green Belt, and given that there is an NPPF requirement to boost significantly the supply of housing, it is not sound or justified for BBC to state that no change to Green Belt boundaries is envisaged;
2. Furthermore, the overall housing strategy and target is heavily reliant on the 1,500 allocation in West Horndon. Such reliance on a single site within a Local Plan is not a sustainable approach;
3. Alternative Options. Policy S1 notes the 'alternative' options considered as part of the 2009 Issues and Options consultation and how it helped to form the basis for the selection of the 'Preferred Option' within S1. Given that the Issues and Options consultation occurred almost four years ago, we question whether this work can be considered up-to-date.
4. Para 2.2 notes the justification for the selection of the 'preferred option'. We agree with this approach based on OAN but do not consider that the method is accurately reflected within the Policy on housing figures;
5. We note that at the other villages (beyond those named specifically within Policy SP1) within the Borough "limited" development should take place at a level commensurate with services and facilities available and which maintains local amenity and distinctiveness. In the interest of clarity it is considered that the word "limited" be deleted to support the NPPF's goal to boost significantly the supply of housing. Accordingly, it is considered that the 'limit' for such development should be defined by OAN at a settlement specific level, as derived from the Government's population and household projection figures.
6. It is also considered that S1 should make reference to identifying and maintaining a 5 year supply of housing land as per the NPPF (paragraph 47);
7. Paragraph 2.9 suggests that 200 dwellings will be built in villages excluded from the Green Belt, other than West Horndon (which has a separate allocation of 1,500). Given that the Local Plan will have a 15 year scope this means that only 13.33 dwellings will be built per annum across all the eleven villages excluded from the Green Belt. It is considered that this figure of 200 units will not be sufficient to facilitate development to meet "local community needs" at a settlement specific level.
8. PINS have identified that LPAs should explore all reasonable options to fulfil OAN. Where constraints are not fixed (i.e. they are not physical constraints such as floodplain), LPAs should plan positively to overcome the identified constraints. It is therefore clear that unfixed constraints including transport capacity and landscape impact should not be used as reasons to limit growth below OAN.