Object

Representation ID: 16138

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

In the context of joint proposals with Basildon it was made clear that a significant wedge of open land would be required to the west of the site to maintain an open gap between Brentwood and Basildon. To achieve the scale of development now proposed, this open gap would have to be considerably eroded. The site is also subject to high flood risk.

Object

Representation ID: 16139

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Paragraph 7.10 confirms that land around West Horndon village remains a reasonable alternative to DHGV because it can provide for similar development numbers towards local needs. We submit that it represents a more sustainable option for strategic growth. The settlement of West Horndon had been emerging as the preferred location for strategic growth until the conception of the joint proposals for Dunton Garden Suburb a year ago. Although evidence regarding the development proposals for West Horndon has been submitted to previous versions of the Local Plan, to demonstrate its suitability and sustainability, this evidence and details have not been used by the Council and its consultants to inform the SA. Instead DHGV has emerged as the preferred option for growth, without the benefit of a full and comprehensive SA. The rejection of land at West Horndon as an option for growth is based on the single statement: "It has not been selected as a preferred site in this Draft Plan owing to the impacts on the existing village, which would not be consistent with the emerging spatial strategy." The DLP cannot be found to be sound based on the rejection of this option for growth without an SA that complies with the Directive and Regulations. Furthermore, we would argue that based on case law, this lack of assessment could not be 'corrected' at a later stage by an addendum because that would require evidence to show that a legally adequate reasoning process had occurred and influenced the plan, albeit not clarified or reproduced in a transparent way.

Object

Representation ID: 16143

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The overwhelming conclusion to draw on the DLP is that in all topic areas it has not been influenced by an appropriate and proportionate evidence base. There is no background assessment to support or justify the policies of the Plan. It is flawed in terms of evidence on housing, business, infrastructure, the environment, and in terms of viability and deliverability to list but a few. There has been a complete lack of evidence to inform what is in the plan and the Council is hastily collating and publishing this retrospectively. Some documents that are only now being published were commissioned three years ago. These are now seen to be contradicting the policies of the plan. Without an evidence base there can be no SA. The effects of the options and the plans policies must have been appraised in relation to the baseline situation. The absence of an evidence base and SA mean that the plan cannot be found sound. It is questionable whether this situation can be corrected in due course and we call for the Council to address the matter now and undertake the work required.

Object

Representation ID: 16146

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Table 7.2 has not been assessed in an SA . We object to the implied encouragement of early applications that accord with this list, this would be premature without the SA. The statement in paragraph 7.30 that
the sites have been assessed against criteria, including a long list such as suitability for housing, accessibility to public transport infrastructure provision, impact on Green Belt etc, is wholly incorrect. There is no evidence to demonstrate such assessment has been undertaken.

Object

Representation ID: 16147

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The Housing Trajectory at Appendix 3 to the DLP is referred to in para 7.37 but DHGV - the key strategic site proposed to deliver half the Borough's growth in housing going forward - is not included in the table at Appendix 3.

Object

Representation ID: 16148

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Housing on this site is not achievable to meet the Brentwood 5 year housing land need. The density proposed would not meet the needs of the housing market and the mixed ownership/leaseholders would make this unfeasible. Brentwood would need to demonstrate leaseholders needs are addressed, freeholders needs are addressed, there are no tenants with rights under the Landlord and tenant act 1954 and there are no restrictive covenants on site.

Object

Representation ID: 16149

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The evidence base as it relates to affordable housing is out of date. This is being addressed in ongoing work towards an update to the SHMA, published on 15 March 2016. This update needs to address recent government announcements and measures that propose to considerably increase provision. The DLP should consider full objectively assessed need for market and affordable housing, which now needs to reflect the government's latest initiative towards building 400,000 affordable
homes, of which 50% should be starter homes.

Comment

Representation ID: 16150

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

We support the Council's objective to promote economic growth. The DLP states in Policy 8.1 the ways in which this will be secured. The first refers to the economic benefits arising from Crossrail. However, background evidence assessing the impact of Crossrail is not available and has not therefore influenced this plan.

Comment

Representation ID: 16151

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

There is inconsistency in terms of the proposals for redevelopment of existing employment land for housing at West Horndon, when this serves as an important and much needed employment resource. High proportion of the Borough's residents commute to work elsewhere and employment provided by small businesses is growing. A127 will see significant economic growth based on plans to redevelop land at junction 29 of the M25, some growth at Childerditch Industrial Estate, and as part of DHGV. Growth is best provided at West Horndon that would be well-placed to meet all these employment objectives. It is in the A127 corridor, is accessible to A127, A12 and M25), served by a railway station and public transport links to key urban areas. Economies of scale would allow local employment provision, specifically aimed at small businesses, which would be accessible by walking and cycling. It lies close to proposed M25 employment location and public transport measures could be introduced to improve linkages between the two.

Object

Representation ID: 16153

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

In the DLP there is reference to an evidence base document entitled Green Infrastructure Strategy and published in September 2015. We submit that this report fails to draw any overriding conclusions but defers instead to additional work. A note is attached to this report that states that the GIS will require review and update upon receipt of Open Space and Sport Assessment and Landscape Sensitivity and Landscape Capacity Study, commissioned by the Council and due Spring 2016. The broad findings of the report are at odds with the latest interim SA. The report lends some support to Dunton for strategic growth but the results appear contrived. In dealing with Dunton the report also refers to "or another current new development site".