Object

Representation ID: 1144

Received: 30/09/2013

Respondent: Chater Homes Ltd

Agent: EJW Planning Ltd

The Council's estimated need for 3,500 homes is the same as that which was required under the now abolished RSS. Under the coalition Government, Local Authorities are being encouraged to increase the delivery of new homes. In most cases the demand for new homes, as measured by the Government, is higher than the former RSS target. Brentwood Council, together with the adjoining Boroughs of Chelmsford and Maldon commissioned a report specifically to inform the three authorities on adopting new housing targets in the light of the abolition of the East of England Plan and its associated housing targets. The report 'Heart of Essex Housing Growth Scenarios', June 2012 suggest that 362 dpa are required. The figures identified in the report are based on CLG household projections,
which are based on up-to-date data and are generally considered to be the most robust approach to determining housing need.
There is considerable disparity between numbers identified in the Essex Study which suggests
5,430 homes are needed between 2015-2030 and Council's estimate of 3,500 homes. The report also identified the limited opportunities in Brentwood to deliver new homes without releasing Green Belt sites. Given the Council's preferred strategy is one of restrained growth there is a concern that in this area of high demand for new housing, demand will outstrip supply. It is evident from the 'Heart of Essex Housing Study' that the Council's preferred approach to housing delivery falls significantly short of the need for housing in the Borough and will in turn
result in a density of development which will have greater adverse impact on the character of
the local area, than if development was more dispersed and achieved through the planned release of appropriate Green Belt sites. The NPPF states that the planning system should do everything it can to support sustainable economic growth and deliver houses. The Council should, therefore, have completed its Green Belt Review and Landscape Assessment in advance of preparation of the LDP and identified suitable sites within the Green Belt to deliver the required additional housing.

Object

Representation ID: 1150

Received: 30/09/2013

Respondent: Chater Homes Ltd

Agent: EJW Planning Ltd

1. Concern is raised with regard to the mechanisms for achieving the supply forecast on the sites
which are allocated. Additionally, the forecast supply makes no allowance for permissions that will lapse. Given
recent market conditions these assumptions are unsound. It would be appropriate to conclude that up to 15% of the outstanding planning permissions listed in the Housing Trajectory at Appendix 3 of the Plan will lapse.
As a result, a greater number of housing land allocations are required. The Plan would benefit from increased flexibility to ensure a continuous and rolling supply of housing land and the need for deliverable sites is met.
We do not believe that this can be achieved by Policy DM23, as there is too much reliance on the delivery of new homes on small brownfield sites, the majority of which are owned by the Council. The 3,500 target has only been achieved by maximising site densities to unrealistic
levels.The suggested densities as shown at Table 4 of the Council's Five Year Housing Supply Assessment 2012-2017, are on average between 60-80 dph, with some sites shown as high as 120-150 dph which is wholly inappropriate for this suburban location.
2. Furthermore, Policy DM23 should not refer to the allocated sites as major sites, as this is ambiguous. The majority of the sites identified in the policy are for between 10 and 20 houses, which in a built-up area like Brentwood does not constitute a major housing development.

Growth needs to be planned for, over and above the proposed allocations. The proposed strategy is not effective and there is a requirement for further contingency and flexibility within the Plan. The site put forward by Chater Homes is deliverable within the plan period.Although this is a Green Belt site, it is important to recognise that there is insufficient
brownfield land to accommodate housing requirements that have been forecasted for Borough and, therefore, sustainable and appropriate Green Belt sites such as this will have to come forward in the Plan period.