Object

Representation ID: 943

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

1. The Plan's spatial strategy is focused on achieving a level of development that does not meet Brentwood's full objectively assessed housing need. The option of centralising growth in and around the town of Brentwood is discounted on the basis that "having more than one strategic location for development will provide flexibility to meet development needs over the long term". However, the allocation at West Horndon appears unrelated to the existing settlement hierarchy and available infrastructure identified in the Borough. The town of Brentwood must retain its status as the highest order settlement in the Borough and focus for future growth.
2.The spatial strategy chosen does not reflect the evidence of housing need and demand identified in the Plan's evidence base. It appears to be the result of a decision to use a capacity constrained approach as the reason for not being able to deliver the full objectively assessed housing need.
3.There is little recognition of the inter-relationships between meeting housing need, justified Green Belt constraint and the hierarchy of development within the Borough.

Object

Representation ID: 955

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

The draft Local Plan fails to provide an adequate justification as to why it cannot deliver Brentwood's full objectively assessed housing needs. There is no evidence presented in the Plan to demonstrate why a capacity constraint-led approach is the most appropriate strategy given the level of housing needs identified, there is also an over-reliance on assumed delivery from the West Horndon major allocation, with inadequate provision made in the draft Local Plan for flexibility and contingency in housing delivery from other sites.

Object

Representation ID: 956

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

The aims of this policy as drafted are incompatible with The National Planning Policy Framework. The policy approach fails to provide the necessary flexibility and contingency to deliver Brentwood's full objectively assessed housing needs and does not reflect the critical importance of securing housing delivery and in boosting the supply of housing in accordance with The Framework.

Object

Representation ID: 957

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

Policy CP10 seeks to restrict Green Belt review and release those sites identified by the Council as necessary to deliver the level of housing identified in the draft Local Plan. The level of housing proposed in the draft Local Plan does not meet the full objectively assessed housing needs of the Borough. It is unclear whether the necessary analysis required to underpin policy CP10 and therefore support a capacity constrained development approach to housing and economic growth has been undertaken. This is compounded by the lack of evidence to show how Brentwood has complied with Duty to Co-operate.

Object

Representation ID: 958

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

This policy is too limited in terms of the number of housing land allocations it identifies. The phasing section of the policy exacerbates these issues only allowing sites to come forward in advance of their assumed trajectory where other sites have failed to deliver. The combined effect is, notwithstanding that the list of sites does not deliver the level of housing required to meet Brentwood's full objectively assessed housing needs, an inadequate flexibility and contingency in the Local Plan should sites fail to come forward or be subject to significant delay. Honeypot Lane should be included at DM23.

Object

Representation ID: 963

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

Strategic Objectives SO7 and SO8 reflect national policy set out in the Framework. However the application and delivery of the Strategic Objectives when taken together through the proposed Local Plan policies is of concern. The starting point is for Brentwood Borough to ensure that the Local Plan meets the full objectively assessed needs for both market and affordable housing in its housing market area, followed by a Green Belt Review. The Local Plan needs to positively address national policies to boost housing delivery, economic growth and sustainable development.