Comment

Representation ID: 15340

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

It is important that BBC takes record of all discussions and undertakings in order to be able to demonstrate that the Duty to Cooperate has been complied with. This should include details of actions to secure effective cooperation, respond constructively to requests for cooperation and also highlight the outcomes of cooperation.

Comment

Representation ID: 15341

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Basildon Borough Council's Draft Local Plan states the following: "Brentwood Borough Council have not however carried out Green Belt, ecology, landscape and infrastructure assessments for their proportion of the site, and consequently it is not known if the proposal is the most appropriate option for their area."

Cross boundary discussions should be undertaken with Basildon Borough Council in the context of both the proposed allocations at Dunton (including all matters listed above), and also in respect of strategic matters. The provision of a joint Area Action Plan should be considered by both Councils to provide policy and guidance for the specific area, particularly given that a joint approach is no longer pursued in the respective Local Plans.

Comment

Representation ID: 15342

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

PPG directs that OAN should be adjusted to reflect economic forecasts and market signals.The OAN for Brentwood should take account of:
- Economic Led Need: level of job growth underpinning PBA's conclusion on economic-led need is constrained by a housing provision target. This is considered in conflict with the PPG which advises that plan makers should not apply constraints to the overall assessment of need.
- Market Signals: Brentwood affordability ratio is significantly higher than Essex and national averages. The PBA assessment identifies that the affordability in Brentwood has not worsened compared to national and regional indicators and therefore an additional uplift is not required. As a result of this, BBC's housing target would simply allow the issue of affordability to continue and would not assist in addressing such a trend.
- Greater London - Brentwood borders the Greater London Authorities (GLA) and there is strong evidence to suggest that LPAs outside the GLA will need to accommodate London's housing shortfall.

Object

Representation ID: 15400

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Para 5.9 states that: "it was proposed that the Borough [...] not meet the full objectively assessed housing need".

BBC must be satisfied that it has identified the full OAN for the Borough , before considering its ability to meet such need in respect of the NPPF policy constraints.

The Plan should positively seek opportunities to meet the development needs of its area. This is particularly important given that a number of surrounding authorities have confirmed, via representations to the previous iterations of the Local Plan, that they would not accept any shortfall from BBC within their own boundaries.

In this regard, BBC should be striving for as high levels of growth as possible.

Object

Representation ID: 15403

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

It is noted that (as of yet) BBC has not undertaken a Green Belt Review of the Borough. A Borough-wide Green Belt review is necessary for "exceptional circumstances" to be 'Justified' and ultimately for the Plan to be found "sound".

It is therefore necessary that BBC undertake a full review of the Borough's Green Belt in order for the approach to be deemed comprehensive and fair, and to also satisfy themselves (and an Inspector) that the Green Belt is capable of enduring for the Plan period.

Comment

Representation ID: 15404

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The DLP provides the context of Green Belt as a constraint to available development land (para 9.51) and proposes the removal of land from the Green Belt, however it does not make explicit reference to "exceptional circumstances" and does not set out whether BBC considers that the test for "exceptional circumstances" has been met.

Comment

Representation ID: 15405

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The following provides an assessment of "exceptional circumstances" for the release of Green Belt land within BBC's emerging Local Plan:
i) The Acuteness/Intensity of the OAN
ii) The Inherent Constraints on Supply/Availability of Land Prima Facie Suitable
for Sustainable Development
iii) The Consequent Difficulties in Achieving Sustainable Development without
Impinging on the Green Belt
iv) The Nature and Extent of the Harm to this Green Belt (or those parts of it
which would be lost if the boundaries were reviewed)
v) The Extent to which the Consequent Impact on the Purposes of the Green Belt may be Ameliorated or Reduced to the Lowest Reasonably Practicable Extent

Support

Representation ID: 15406

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support the approach as stated in paragraph 1.17 of the DLP, in that the Plan will cover at least a 15-year period from likely adoption, as well as previous years' development shortfall since 2013.

It should be noted that there are a number of discrepancies in the DLP with regards to the Plan period. As noted above, the proposed Plan period is 20-years however reference is made to a 15-year Plan period within a number of DLP paragraphs, including 1.1, 5.43 and 10.2.

Comment

Representation ID: 15505

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support the approach contained in Policy 5.1 for development to be focused in the 'A12 Corridor', which includes Brentwood and Shenfield.

The growth strategy for the Borough should include a proportion of development within each of the broad areas, namely the 'A12 Corridor', 'A127 Corridor', 'Rural North' and the 'Rural South', in line with the sustainability credentials of each of the settlements, informed by evidence base documents and strategic priorities for the Borough.

Comment

Representation ID: 15506

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

It is suggested that the DLP is amended to make it clear that the "strategic sites" identified is also Green Belt (i.e. bullet No 4 above). In doing so, BBC should also confirm that the potential for non-green belt Greenfield sites have been considered, but no such site are available/suitable.