Object

Representation ID: 832

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

For the reasons set out in our response to Policy S1, a target of only 3,500 dwellings is considered fundamentally unsound as it does not meet OAN.
Paragraph 2.20 states that "Growth above a certain level would lead to significant impacts: notably harm to the landscape, Green Belt, settlement identity and character and town centre traffic congestion". While we acknowledge that the Local Plan must respond to the Borough's environmental characteristics, BBC as noted above have not yet carried out a Green Belt assessment, and to conclude that growth above a certain level would lead to "significant impacts" is entirely unjustified. The Plan appears to be based on an assertion-led strategy, with the evidence base still to be finalised after publication of key policies. Given the lack of transparency in the Plan preparation process, the 'preferred' growth strategy is based on constraints that have not been assessed. It instead represents an entirely new approach which has not been consulted on robustly at any of the previous consultation stages. Notwithstanding the lack of evidence explaining the reasoning behind the Plan's inability to meet OAN, PINS have outlined that the constraints identified by BBC should not be used to limit growth required to meet OAN. Given BBC's significant housing shortfall against OAN, it is recognised that Green Belt land will need to be released around Brentwood town as the largest settlement in the Borough. In addition to settlement specific housing needs to address localised affordability issues and retain the viability and vitality of local shops and services.

Object

Representation ID: 833

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

In order to meet BBC's significant housing shortfall against OAN, it is recognised that Green Belt land will need to be released around Brentwood town as the largest settlement in the Borough. Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan,"Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing (Ref G093). Therefore, should, a higher level of housing be adopted by BBC, a logical spatial strategy would include the allocation of the most sustainable residential sites at each of the Larger Villages.

Object

Representation ID: 904

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

1. Significant proportion- It is considered that paragraph 2.20, and the process it identifies to support the Local Plan is unsound as it does not accord with the key principles of the NPPF. Paragraph 2.20 states that "The preferred spatial strategy seeks to accommodate a significant proportion of this (objectively assessed) development need". This approach does not accord with the NPPF (paragraph 47), as Local Plans should plan to exceed housing targets, not simply accommodate a "significant proportion" of the identified housing need. The Plan makes provision for 3,500 dwellings over the plan period, however OAN, based on household and population projection figures, suggests this figure should be at least 5,600 dwellings. 3,500 dwellings only represents approximately 60% of OAN within BBC, and thus cannot be described as a 'significant' proportion.
2. Limits to Growth- While we acknowledge that the Local Plan must respond to the Borough's environmental characteristics, BBC have not yet carried out a Green Belt assessment, and to conclude that growth above a certain level would lead to "significant impacts" is entirely unjustified. The Plan appears to be based on an assertion-led strategy, with the evidence base still to be finalised after publication of key policies. Given the lack of transparency in the Plan preparation process, the 'preferred' growth strategy is based on constraints that have not been assessed. It instead represents an entirely new approach which has not been consulted on robustly at any of the previous consultation stages. Notwithstanding the lack of evidence explaining the reasoning behind the Plan's inability to meet OAN, PINS have outlined that the constraints identified by BBC should not be used to limit growth required to meet OAN. PINS have identified that LPAs should explore all reasonable options to fulfill 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.

Object

Representation ID: 905

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

The Sustainability Appraisal (August 2013) "accompanying" (published seven weeks after) the Local Plan does not adequately address the methodology and justification for the selection of their housing target. Further comment on the Sustainability Appraisal will be submitted by Savills UK on behalf of Crest Nicholson Eastern during the amended consultation period for the document.

Object

Representation ID: 906

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

BBC's Housing Trajectory is not capable of demonstrating a 5 year housing supply. If BBC were to adopt a NPPF compliant housing target more in line with the acknowledged objectively assessed need within the Borough, the position would be considerably worse still.

Support

Representation ID: 909

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

General support is given for the Vision as it emphasises, in line with the NPPF (paragraph's 17, 19 and 21), the Plan's support for growing the economy and fostering development which responds to "local community needs". It should be noted that local community needs should be met at a settlement specific level.
1.3 Despite supporting the Vision, it is not considered that the wording and approach contained within the consultation document reflects this Vision to support "local community needs". Accordingly, this will be commented on throughout these representations.

Object

Representation ID: 910

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Given the importance of significantly boosting housing growth at a rate that more than meets OAN, it is considered that Strategic Objective S08 should be moved to the top of the list of Strategic Objectives.
Notwithstanding this, it is considered that the following amendments should be made to the wording of Strategic Objective S08 (as currently numbered):
"SO8: Plan for housing that meets the needs of the Borough's population as a whole, as well as its individual settlements1, and contributes to creating inclusive, balanced and sustainable communities."

Object

Representation ID: 911

Received: 01/10/2013

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 the NPPF. Policy S1 states that the Borough "aims to protect the Green Belt" and that "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, as part of the emerging Local Plan process, 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. Policy S1 also notes the 'alternative' options considered as part of the 2009 Issues and Options consultation and helped to form the basis for the selection of the 'Preferred Option' within S1. We question whether this work can be considered up-to-date. In the interim between the Issues and Options document and the publication of the Preferred Options document, the NPPF has been published and the Regional Spatial Strategy revoked. Accordingly, it is argued that the alternative options should be reconsidered, particularly in relation to the increased emphasis that the NPPF places on housing and economic growth. Additionally, paragraph 2.2 notes that the justification for the selection of the 'preferred option'. Whilst we agree with this approach based on objectively assessed need, we do not consider that method is accurately reflected within the Policy on housing figures, as discussed in relation to paragraph's 2.9, 2.20, 2.26 and 2.37.

Support

Representation ID: 919

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

This policy is generally considered appropriate. It should be noted that housing need should be considered as an exceptional circumstance where the need for development outweighs harm caused by other factors. This approach accords with the NPPF (paragraph 187) in looking for solutions, rather than problems regarding development options.

Object

Representation ID: 920

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Policy DM24 should allow for off-site contributions subject to a robust demonstration that such contributions would be necessary to mitigate the impact of development itself and a more viable option. This suggested approach would better accord with the NPPF (paragraph 187) in looking for solutions rather than problems, and working proactively to ensure developments improve the economic, social and environmental conditions of the area.