Comment

Representation ID: 10340

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The next iteration of the Brentwood Local Plan will need to consider sufficient sites to accommodate a minimum of 2,000 additional dwellings. Our consideration of housing targets focus on whether the housing targets identified in the SGO are 1. sufficient to meet needs, 2. are set over a realistic plan period, 3. are proposed to be accommodated in the most sustainable location, and 4 whether they seek to maximise the opportunities presented by the Duty to Cooperate. This will be with regard to the potential development around the existing West Horndon village.

Comment

Representation ID: 11125

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

There is no evidence to suggest that the spatial strategy contained within the PreferredOptions is no longer the most sustainable and deliverable option for accommodating future growth for Brentwood. Indeed, the requirement to provide for a greater level of growth should result in the determination to maximise the opportunities presented by West Horndon as a strategic growth location, including the opportunities presented by land to the south of the settlement.

Comment

Representation ID: 11126

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

There are a number of strategic matters that are identified in the SGO that are relevant to the determination of the most sustainable and deliverable options for the future development of the Borough. The review of planning, legal and technical matters confirms that the preferred options of the WHSGL is indeed the most sustainable and deliverable option. This is supported by the evidence base prepared by the Council and the Sustainability Appraisal of the SGO.

Comment

Representation ID: 11127

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The review of planning, legal and technical matters confirms that the LPPO preferred option of the WHSGL is indeed the most sustainable and deliverable option. This is supported by the evidence base prepared by the Council and the Sustainability Appraisal of the SGO. It has determined that the sustainability of the West Hordon Strategic Growth Location can be further enhanced through the identification of further land to the south of the settlement for development. Indeed, in the interests of discharging its duties under the DTC, EA Strategic urges the Council to consider the opportunities presented by development south of the settlement and the benefits it can deliver.

Comment

Representation ID: 11129

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Preferred Options was published in 2013 and proposed to cover the minimum plan period of 15 years, assuming adoption in 2015, (plan-period of 2015-2030). The current consultations (SGO and DGS) it is likely that a delay will be experienced in the adoption of the subsequent Local Plan. EA Strategic considers that a more realistic date for adoption would be no earlier than 2016/17. The plan should seek to cover the period should run until at least 2031/32, and the Council may wish to consider extending this to ensure additional required growth can be delivered. It may be prudent to prepare the plan to cover the period 2015-2035, allowing for delays in the adoption process and ensuring the plan will cover a minimum of 15 years at the point of adoption. By planning for a longer plan period from the outset, the Council will protect itself from needing to make changes to the plan period later in the process of plan preparation and will reduce the risk of any subsequent adoption being predicated on an immediate plan review.

Comment

Representation ID: 11132

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

To ensure strategic planning issues that cross administrative boundaries are considered, the Council should seek to accommodate all of its required growth within the broough boundary. This will ensure London population growth is considered and accommodated.

Comment

Representation ID: 11133

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

We wish to highlight the importance of publishing evidence base documents early in the plan production process to allow them to be reviewed alongside the emerging plan.

Comment

Representation ID: 11148

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The draft Strategic Housing Market Assessment (SHMA) July 2014 for Brentwood alongside each of the constituent authorities within the Heart of Essex (HoE) Housing Market Area (HMA). Paragraph 1.13 of the SGO confirms that this forms part of the housing and demographic evidence base for the Local Plan and we understand the document has informed the forthcoming Objectively Assessed Needs (OAN) Report. In September 2014 we drew our soundness concerns with the SHMA, in particular noting it is not compliant with the NPPF or NPPG as it is cast in the mould of a pre-NPPF SHMA and focused on affordable housing needs for the Borough. As the OAN is yet to be determined, we reiterate these concerns, set out in the attached letter.

Comment

Representation ID: 11151

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The 2013 SA concluded that the growth option that focused development primarily at Brentwood, Shenfield and West Horndon was the most preferable. An Interim Sustainability Appraisal (ISA) January 2015 has been produced. The Interim Sustainability Appraisal determines that the West Horndon SGL is ranked the most sustainable growth option overall. Furthermore, it ranks as the most sustainable option in terms of Economy and Employment, Housing, and Soil and Contamination.

Comment

Representation ID: 11186

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The revised OAN is still considered low. The issues raised by an Inspector in the Uttlesford Local Plan examination apply to Brentwood and an uplift in the OAN of a similar 10% figure is considered more appropriate. (Ie 340 to 374).
However, in consideration of the economic model forecasts in EPOA Phase 6 for Brentwood would raise the OAN still further to 425 dwellings per annum. This equates to a total of 5,610 - 6,375 over the plan period (15 years from 2015-2030).