Comment

Representation ID: 15610

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council is a neighbouring local planning authority (LPA) to Brentwood and there are a number of strategic issues, such as housing and infrastructure, which operate at levels greater than a single LPA area and which concern both Boroughs. It is important that such issues are addressed through collaborative working and meaningful discussions.

Comment

Representation ID: 15618

Received: 10/05/2016

Respondent: Basildon Borough Council

Brentwood Borough intends to meet its objectively assessed housing need (OAN) inline with the 2014 OAN document within the Brentwood Borough boundary. We supports this approach to housing growth. However, the OAN report was produced prior to the release of the 2012 sub national population projections (2012 SNPP), or the more recently published 2012 based CLG Household Projections. The Planning Practice Guidance is clear that these more recent projections should form the starting point for calculating the OAN for housing in an area. Additionally, the calculations of OAN has not given consideration to changing patterns of out-migration from London, which could reasonably be expected to be considered in any sensitivity testing of demographic forecasts, in those areas surrounding London. Changing migration patterns could seriously impact on the need for housing within Brentwood Borough going forward. Brentwood Borough Council should carry out further work to re-assess the OAN to include these projections, and should the need for housing change in light of this, Brentwood Borough Council should seek to revise the target accordingly and to continue to fully meet their OAN.

Object

Representation ID: 15624

Received: 10/05/2016

Respondent: Basildon Borough Council

The recently published evidence (Assessment of Potential Housing, Employment and Mixed Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation - March 2016) states that 'An update to the 2014 SHMA is currently being undertaken by the Council in light of subsequent amendments in national policy guidance'. This suggests that Brentwood Borough Council recognise the deficiencies in their evidence regarding the objectively assessed need for housing in their borough, and it is therefore expected that the matters raised above will be resolved prior to the Brentwood Local Plan being progressed to submission. Basildon Borough Council would be pleased to be engaged and kept informed of the progress with this work as it is progressed.

Object

Representation ID: 15625

Received: 10/05/2016

Respondent: Basildon Borough Council

Work on the South Essex Strategic Housing Market Assessment has included a re-assessment of the South Essex Housing Market Area to ensure it is still appropriately defined. In defining Brentwood as a single housing market area, the current Brentwood SHMA does state that 'data suggests that Brentwood shares a housing market area with Chelmsford and Basildon and to a smaller extent Epping'. It therefore recognises that overlaps with surrounding housing market areas exist. As the proposals within the Brentwood Draft Local Plan propose a strategic housing site for 2,500 homes within close proximity of the Borough boundary shared with Basildon Borough Council, there may be implications for the future definitions of the Brentwood and South Essex housing market areas, which need to be given further consideration as the Brentwood Local Plan is progressed towards submission. Basildon Borough Council would be pleased to be engaged in such work in order to understand the implications this proposal would have for both the Brentwood and South Essex housing markets, and the extent to which development in this location would meet the needs arising from both housing market areas.

Comment

Representation ID: 15626

Received: 10/05/2016

Respondent: Basildon Borough Council

Past windfall trends for Brentwood Borough Council has accounted for 77 homes pa. Brentwood Borough Council have stated within their Draft Local Plan that this level of supply will continue into the future providing 928 homes over the plan period. However, there is no evidence that supports the ongoing supply of homes at this rate from windfall sites. In line with Government guidance, Brentwood Borough Council must provide compelling evidence that such windfall sites have consistently become available in the local area, and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens. Supply from windfall sites should also be split down into categories to identify where the provision could arise from.

Object

Representation ID: 15627

Received: 10/05/2016

Respondent: Basildon Borough Council

In relation to identified housing land supply, it would appear from the evidence base that Brentwood Borough Council has not carried out a Strategic Housing Land Availability Assessment (SHLAA) since 2011. Basildon Borough Council made it clear in its response to Brentwood Borough Council regarding the Brentwood Borough's Local Plan Strategic Growth Options in early 2015 that it would expect the SHLAA to be updated before a Local Plan for Brentwood is progressed. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments to help inform the emerging Local Plan, and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply. It is not clear how any of the proposed housing sites included in the Draft Local Plan have been put forward and how the sites are justified as suitable without crucial supporting evidence which is missing including recent landscaping, ecology and open space evidence.

Object

Representation ID: 15628

Received: 10/05/2016

Respondent: Basildon Borough Council

In relation to identified housing land supply, it would appear from the evidence base that Brentwood Borough Council has not carried out a Strategic Housing Land Availability Assessment (SHLAA) since 2011. Basildon Borough Council made it clear in its response to Brentwood Borough Council regarding the Brentwood Borough's Local Plan Strategic Growth Options in early 2015 that it would expect the SHLAA to be updated before a Local Plan for Brentwood is progressed. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments to help inform the emerging Local Plan, and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply. It is not clear how any of the proposed housing sites included in the Draft Local Plan have been put forward and how the sites are justified as suitable without crucial supporting evidence which is missing including recent landscaping, ecology and open space evidence.

Object

Representation ID: 15629

Received: 10/05/2016

Respondent: Basildon Borough Council

It is of concern to Basildon Borough Council that Brentwood Borough Council are looking to take forward development within the previously outlined Dunton Garden Suburb location. Basildon Borough Council do not believe that Brentwood Borough Council have provided sufficient evidence to show that development in that area would be the best location for new development, and that the scale of development proposed, over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure.

Object

Representation ID: 15630

Received: 10/05/2016

Respondent: Basildon Borough Council

The proposal included within the Brentwood Draft Local Plan departs from the proposal for a Dunton Garden Suburb insofar as it is a proposal for a stand-alone settlement to the south of the A127 and to the east of the A128 within the Brentwood Borough only. However, at this time the precise location and land requirement of this proposal is unknown, as are details such as access arrangements. It is therefore unclear as to whether these proposals will result in a stand-alone settlement or an extension to the Basildon urban area in the long-term. It is also unclear how this proposal will relate in terms of access and connectivity to the Basildon urban area in terms of highway impacts or demand for infrastructure and services within Basildon Borough.

Object

Representation ID: 15631

Received: 10/05/2016

Respondent: Basildon Borough Council

The land which would form the Dunton Hills Garden Village does not appear to have been put forward in the most recent call for sites and has not been assessed within the Brentwood Council Strategic Housing Land Availability Assessment (2011). The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use.