Support

Representation ID: 1885

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

General support is given for growing the economy and fostering development in response to "local community needs".

We also note that at the other villages (beyond Policy SP1) "limited" development should take place at a level commensurate with services and facilities. In the interest of clarity and in accordance with the overall Vision, it is considered that the word "limited" be deleted to support the NPPF's goal to boost significantly the supply of housing and that the 'limit' for such development should be defined by OAN at a settlement specific level, as derived from Government's population and household projections.

Support

Representation ID: 1886

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Given the importance of significantly boosting housing growth at a rate that more than meets OAN (as identified within NPPF paragraphs 47 to 55), it is considered that Strategic Objective S08 should be moved to the top of the list of Strategic Objectives. In addition, 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: 1888

Received: 02/10/2013

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: 1889

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

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, as identified within the Local Plan Vision. 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, and is one that has been heavily criticized by a number of Inspectors. Notwithstanding the above comments, 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 and in order to accord with the overall Vision, identified within the consultation document, 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.

Object

Representation ID: 1890

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Paragraph's 2.29 and 2.32 of the consultation document identify that BBC has commissioned a number of technical studies to inform their view of how OAN can be met and how many homes can be accommodated. Paragraph 2.29 acknowledges that the majority of this work has not yet been published, and on this basis it is considered that the selection of a Preferred Option (which consequently rules out other approaches) is unsound. The absence of relevant technical work in order to support this decision is contrary to all four tests of soundness identified within paragraph 182 of the NPPF: positively prepared, justified, effective and consistent with national policy.

Object

Representation ID: 1891

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Paragraph's 2.29 and 2.32 of the consultation document identify that BBC has commissioned a number of technical studies to inform their view of how OAN can be met and how many homes can be accommodated. This flawed approach is for example highlighted in paragraph 2.32 which states that "Evidence suggests that a higher level of growth would significantly worsen existing traffic congestion problems (Traffic Modelling Study - forthcoming)". It is considered that without the forthcoming Traffic Modelling Study, the Council do not possess the necessary up to date evidence base.

Support

Representation ID: 1892

Received: 02/10/2013

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: 1893

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

In line with the NPPF (paragraphs 50 and 159), the Policy appropriately identifies that viability, which should be supported by a toolkit appraisal, shall be taken into account in the negotiation of rates of affordable housing.
Furthermore, 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).

Object

Representation ID: 3386

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

In discussion of the background work to inform the housing figure, paragraph 2.26 identifies that national policy makes it clear that household and population projections should be the starting point for identifying 'objectively assessed need' for development, taking account of migration and demographic change. Full support is given to this approach, however, for the reasons noted above, it is clear that BBC have not sought to use this approach in the formation of their housing figures, and as a result fall considerably short of the required OAN within the Borough.

Object

Representation ID: 3387

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Paragraph's 2.29 and 2.32 of the consultation document identify that BBC has commissioned a number of technical studies to inform their view of how OAN can be met and how many homes can be accommodated.Paragraph 2.29 acknowledges that the majority of this work has not yet been published, and on this basis it is considered that the selection of a Preferred Option (which consequently rules out other approaches) is unsound. The absence of relevant technical work in order to support this decision is contrary to all four tests of soundness identified within paragraph 182 of the NPPF: positively prepared, justified, effective and consistent with national policy.