Comment

Representation ID: 11883

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Comment is made on the purpose of the consultation, SGOC is referring to:
National policy and housing need, Green Belt and plan making; housing targets, population projections/formation rates; economic led need; market signals and the impact from Greater London are considered within the representations submitted by Barton Willmore on behalf of Croudace Strategic.

Comment

Representation ID: 11884

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Whilst we support the increased housing target included within the SGOC, BBC has not identified its full OAN in accordance with the requirements of the NPPF and PPG;
We support BBC's conclusion that Greenfield/Green Belt sites, along with brownfield sites, will be required in order to meet BBC's increasing housing target;
We are concerned that BBC's current conclusions on "Broad Areas" of growth are not supported by a sufficient evidence base, with the majority of documents still being prepared;
However, BBC's future growth strategy is likely to require a range of sites from each of the "Broad Areas" identified. This should include Shenfield, and the Officers Meadow site, both of which are identified as being suitable to accommodate future sustainable growth.

Comment

Representation ID: 11890

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Other factors, including access to public transport, services and facilities will need to be considered.

Object

Representation ID: 11891

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Section 2 of the representation makes comment ont eh proposed housing target. The Dec 2014 PBA OAN is referred to in terms of the demographic starting point (being too low). The economic led need needs adjusting upwards to support to labour force growth of the popultation (the Edge Analytic 2014 report supports 185 new jpa whereas the Phase 6 EPOA report supports 275 jpa). The 2014 EEFM figures show job growth over a range of periods, all are higher than the PBA OAN report. Concluding that economic led housing need in Brentwood is likely to be significantly higher than 362 dpa.

Object

Representation ID: 11892

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The development of the OAN need to consider population; economic led need and then market signals, particularly affordability.
With recent Inspectors decisions on the Eastleigh and Uttlesford local plan suggesting an increase of at least 10% to address worsening market signals and noting the Brentwood ration of lower quartile house prcie to lower quartile earnings worsening from 5.98 (in 1997) to 10.10 (in 2013).

Object

Representation ID: 11893

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The PBA OAN proposed housing target need to take account of the increase in need to accommodate the housing shortfall fron London. (FALP 2014).

Object

Representation ID: 11894

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Whilst the increased housing target is supported, further work is needed to stablish the correct OAN for the borough. Particularly in relation to job growth forecast, recorded past trands, job led scenario, market signals affecting affordability and the needs of Greater London. The housing target will also need to take account of previous years shortfalls.Therefore the submission Local Plan should positively seek opportunities to meet the development needs of its area.

Comment

Representation ID: 11895

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Whilst we have no objections to the broad areas identified, it is important defining features are taken into account.
The ability of transport corridors to accommodate additional growth; The sustainability of individual settlements (facility and services availability); the capacity of the landscape to accommodate development; infrastructure capacity and site availability. This will need to be informed by the evidence base , the majority of which is emerging and not yet published.

Object

Representation ID: 11896

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

As the majority of the evidnece base is still being prepared it is unclear how issues for hte three broad areas were identified.
West Horndon is not considered justified as the reference to the landscape assessment is 8 years old and is being updated. The brownfield sites only are considered suitable by the 2011 SHLAA, which is being updated.
Has BCC or Essec CC identified that improvements could be made to the A12 to accommodate growth? How does this consideration relate to the scope to improvement to the A127? There is no evidence that demonstrated that congestion of the A12 corridor is an issue or that it cannot be overcome by suitable improvements.

Object

Representation ID: 11897

Received: 20/04/2015

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Housing should be largely proporionate and appropriate to each settlement in the borough and greater in munber for the large settlements that would accomodate sustainable growth.