Local Plan 2015-2030 Preferred Options for Consultation

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Local Plan 2015-2030 Preferred Options for Consultation

Strategic Objectives

Representation ID: 757

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Support proposals to achieve growth put forward in the Strategic Objectives, including those in SO1 regarding specific locations. These existing urban areas have the greatest access to existing and proposed local services and are therefore considered the most suitable.

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Local Plan 2015-2030 Preferred Options for Consultation

2.20

Representation ID: 769

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Para 2.20 highlights that the Council does not envisage meeting the full level of growth proposed due to significant constraints which would impact on the boroughs character. These findings may prove o be correct, however they should not be seen as a pre-determinant to the development plan process.

Paragraph 2.21 in turn, implies that the unmet need can be met through the duty to cooperate process in adjoining boroughs. This is fundamental in determining the councils housing land allocation, and accordingly this discussion should lead not follow the proposed growth option. In the event that adjoining boroughs can not assist in meeting Brentwoods growth, the borough need to ensure it has sufficient flexibility to meet its own housing growth. In our view additional development can be accommodated, without adverse environmental impact. An obvious approach is to rely on those gb incursions presently identified. However Brentwood is right that development should not come at any cost and therefore both existing and future allocations should be capable of demonstrating sufficient infrastructure can be brought forward to contribute to the overall improvement of Brentwood for residents and visitors alike.

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Local Plan 2015-2030 Preferred Options for Consultation

S2: Amount and Distribution of Residential Development 2015-2030

Representation ID: 771

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Policy S2 highlights the provision in the plan for 3,500 new dwellings to be built over the plan period 2015-2030, with 1,500 dwellings to be allocated at West Horndon. This level of delivery cannot presently be established. In our opinion the council needs to follow a sequential process as follows:
* Firstly, the OAN for the borough needs to be determined, which requires the completion of a SHMA
* Second, a view should be taken whether some of this need can be met by neighbours through the Duty to Cooperate process
* Third, through a combination of associated evidence, including the analysis of infrastructure deficiency, landscape assessment, land quality and sustainability appraisal, a balanced approach should be taken to the relative merits of meeting the boroughs housing need versus the potential impact on the character and quality of the borough. Only at this stage can the borough confidently and robustly promote options for growth.

The Council should therefore allow for sufficient flexibility to respond to the findings of the SHMA and the associated evidence at this stage of the Plan and recognize that the level of growth presently being promoted is likely to be a minimum.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP4: West Horndon Opportunity Area

Representation ID: 791

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Support in principle. However, as with response to Policy S1, greater flexibility should be allowed for increased capacity at West Horndon. This would aid the Council in meeting Borough housing need. By removing a larger land area from Green Belt, the Council will be in a more defendable position to ensure services and infrastructure required for 1,500 new homes can be provided, including facilities this "Garden Village" settlement needs, without subsequent additional Green Belt encroachment.

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Object

Local Plan 2015-2030 Preferred Options for Consultation

Appendix 2: Preferred housing allocations and small sites allowance 2015 - 2030

Representation ID: 794

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Appendix 2 indicates that not all of 037B is to be allocated, but the whole site is needed to ensure that the requisite infrastructure and facilities can be accommodated.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP10: Green Belt

Representation ID: 797

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Support exclusion of West Horndon from Green Belt. However, Borough settlement boundaries need to include sufficient land to ensure flexibility to deliver housing with associated services, infrastructure and facilities.

The full extent of the proposed West Horndon settlement boundary has not been illustrated, which should be published for consultation ASAP.

A wider allocation of land west of Thorndon Avenue is requested, creating a defensible boundary formed by the A127 to the north, Childerditch Lane to the west, and railway to the south. Alternatively, reference is needed for an early Green Belt review over the course of the Plan period.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP14: Sustainable Construction and Energy

Representation ID: 798

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Support the policy in principle, but would like to draw to the Council's attention the Housing Standards Review and Government proposal to wind down the Code for Sustainable Homes. The Council should keep the Government's intentions in mind and allow sufficient flexibility in the policy to achieve this.

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Local Plan 2015-2030 Preferred Options for Consultation

S1: Spatial Strategy

Representation ID: 801

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

The approach set out in the spatial strategy at S1 and the locations in which to focus the development is supported. We agree that these locations, including the west horndon allocation is capable of accommodating the growth required over the plan period. This proposed strategy is considered to be the most appropriate, and in particular we agree Alternative Option 3 is not suitable. This alternative option will not enable sufficient delivery of growth or critical mass to enable improvements to infrastructure, settlements such as WH not only provide the most logical solution in terms of infrastructure constraints and accessibility, but can take advantage of under-utilised existing infrastructure, notably the excellent rail links of the settlement. The proposed change to ensure that WH is not within the GB is also welcomed however, it is considered that it would be beneficial to extend this allocation to include the entire parcel of land to the west of Thorndon Ave, not only the southernmost section. This will create a defensible boundary to the GB as stated in Para 85 of the NPPF. This will ensure that the council can be sure that the GB boundary would not need to be altered before the end of the plan period. This land can provide the necessary flexibility concerning the form of future development proposals. By way of justification for S1, Brentwood has set out a settlement hierarchy in para's 2.12-2.16. The purpose of this is to show how it has assessed suitable locations in which to accommodate growth in a sustainable manner. West Horndon is catogrised as a settlement 3 -large village. In our opinion it is more significant settlement than that and should be catogorised accordingly. We would suggest a new tier of settlement be created above catorgory 2 and that this should be entitled "Garden Village" settlements.

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Support

Local Plan 2015-2030 Preferred Options for Consultation

Alternative Approach

Representation ID: 802

Received: 26/09/2013

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

Alternative allocations do not include those that are most suitable or deliverable. Allocations should demonstrate that they can bring forward necessary services and infrastructure to contribute to an improvement in quality of life.

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