Object

Representation ID: 1188

Received: 02/10/2013

Respondent: Gladman Developments

Policy S2 of the Council's Preferred Options sets out an overall housing requirement of 3,500 new homes over the Local Plan period 2015-2030, with the rate of development phased to deliver 200 dpa between and 2015 and 2020 and 250 dpa between 2020 and 2030. Reviewing the Council's policy justification Gladman submit that this requirement is too low and is not justified by an adequate evidence base.

Object

Representation ID: 1191

Received: 02/10/2013

Respondent: Gladman Developments

Several of the Local Plan's policies refer to developer contributions. Such polices should meet the requirements of §173 of the Framework. Any policy obligations should be founded on robust evidence and should not act to restrict development coming forward. The Council should prepare a viability assessment of the Local Plan's requirements.

Object

Representation ID: 1195

Received: 02/10/2013

Respondent: Gladman Developments

Gladman note that the Council's proposed housing requirement will significantly constrain the scope for addressing affordable housing needs in Brentwood. This supports the need to increase the Council's overall housing requirement.

Object

Representation ID: 1198

Received: 02/10/2013

Respondent: Gladman Developments

1. Spatial Distribution. Brentwood has a number of different and distinct housing market areas. Each of these distinct areas will have their own requirement for housing and this should be reflected in the spatial distribution of housing supply within the Local Plan. This decision should be based on the findings of the evidence base and should not be a politically driven spatial strategy to put a disproportionate amount of housing in areas where people don't want to (and will not) live. Following a dispersed spatial distribution pattern across a large number of settlements is also undesirable as this approach is not likely to be sustainable, will not be delivered and cannot generate the level of community benefits that larger sites can to help make settlements more sustainable and fill important gaps in community provision. However, this should not preclude development in lower order sustainable settlements, which could also help to sustain existing facilities and services. The Local Plan needs to provide sufficient flexibility to address situations where housing does not come forward as expected. In this regard it may be necessary to plan for the release of additional housing sites, and earlier in the Plan period, to maintain a five-year housing land supply. In some instances this objective may be best achieved through sustainable, deliverable sites that do not benefit from a formal Plan designation.

2. The Framework sets out that Local Plans should be drawn up over an appropriate time scale, preferably a 15-year time horizon. Gladman note that once adopted it is likely that the Local Plan will not cover a 15 year period. Gladman submit that a Plan can only come into effect from the date of adoption. There would need to be compelling reasons to ignore the guidance set out in §157 of the Framework.

In summary: we have concerns over the soundness of the plan specifically:
* Housing requirement
* Affordable housing
* Plan Period
* Spatial distribution
* Viability