Object

Representation ID: 1281

Received: 01/10/2013

Respondent: JB Planning Associates Ltd.

We are extremely concerned with the direction of the Local Plan. We believe the Council is failing to recognise the scale of housing needs in Brentwood. The plan fails to meet the requirements of the National Planning Policy Framework (NPPF) with respect to meeting the full range of 'objectively assessed' housing needs and as a result, the Local Plan is unsound. The Plan is planning for a significant shortfall in homes over the 15 year period of the plan. With little information provided on how the needs of those residents will be met, we can only assume a future scenario of increased unaffordability, overcrowding, homelessness and pressure on neighbouring authorities to meet Brentwood's unmet housing needs. This approach is therefore inconsistent with the objective of the NPPF to promote sustainable development.Evidence produced by the Council demonstrates a need for 4,960-5,600 additional homes from 2015-2031. This would represent meeting the full range of housing needs. However, Policy S2 of the consultation draft proposes to deliver 3,500 additional homes during the same period. This represents an under-provision of approximately 1,500 homes. The reasons given for the preferred housing target are to resist pressure on existing services and infrastructure; to not worsen congestion in Brentwood Town Centre; and to protect the rural character of the Borough. According to the Council, Green Belt sites would need to be released to meet the shortfall which would risk 'irrevocably changing the rural character of the borough'. It is our opinion that the reasons given for setting a lower housing target than would meet the Borough's housing needs are insufficient and unsatisfactory.

Object

Representation ID: 1283

Received: 01/10/2013

Respondent: JB Planning Associates Ltd.

The Council is placing a significant policy priority in favour of protecting the Green Belt which we believe is unnecessarily restrictive and fails to recognise the potential for some Green Belt sites to deliver sustainable development. We acknowledge the political sensitivity of the Green Belt, however in a borough where 80% is designated as Green Belt, we struggle to believe the few sites identified for release by the Borough are the only suitable sites. The Council should therefore take the form of a full Green Belt review. What is clear is that Brentwood will not meet its housing needs over the
plan period unless additional land is identified to meet the need for increased delivery, which will include assessing the potential for additional Green Belt release. Releasing appropriate Green Belt sites should not automatically be assumed to be an unsustainable and unfavourable outcome.

Object

Representation ID: 1287

Received: 01/10/2013

Respondent: JB Planning Associates Ltd.

We have also reviewed the Interim Sustainability Appraisal (SA) and failed to find any assessment of alternative site allocation which should form part of the appraisal. We can therefore only assume no alternative sites were considered by the Council which is contrary to national policy. Transparency should be at the heart of the process and failure to fully explain why some sites were chosen and others not, and to test alternatives, raises serious concerns over how the Plan was prepared.

Object

Representation ID: 1292

Received: 01/10/2013

Respondent: JB Planning Associates Ltd.

Our client has interests in a number of Green Belt sites in and around Ingatestone, Four of which were put forward during the SHLAA call for sites requests. Site 1 - Identified in the SHLAA as 'the site south of the flyover on Roman Road' and is suitable for development. Despite this positive conclusion, the site was not taken forward by the Council. The other three sites, identified on the map in Appendix 1 as sites 2, 3 and 4, were all discounted from the SHLAA. We believe these sites would help meet the boroughs housing need and housing targets.