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Object

Draft Local Plan

Evidence Base

Representation ID: 15203

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Object to the fact that the Green Belt Assessment (Crestwood March 2016) assessed sites 024a and 024b as two separate parcels as since the start of 2015 the site has been promoted to the Council as a single parcel. The results of the two parcel assessment are therefore inaccurate and do not fully reflect its true contribution towards the Green Belt purposes.
Recommended that the site is assessed as a single site in the Local Plan evidence base (not as two separate land parcels). Based on this assessment the overall contribution of the site to Green Belt purposes should be changed to be "low" or "low / moderate"

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Object

Draft Local Plan

Figure 7.2: Housing Land Allocations

Representation ID: 15206

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Recommend that the site at Sawyers Hall Lane is allocated for housing in the Local Plan. In particular the site achieves the requirements of Policy 5.1 and Policy 9.12 in relation to defensible boundaries.
The planning reason for non-allocation relating to the Green Belt / clear physical defensible boundaries has been fully addressed [see full representation]. Overall the site is considered to have moderate capacity to accommodate change to residential development (based on landscape findings and visual assessment findings).
The Highways Note [see supporting document] demonstrates that the proposals for 450 units is unlikely to have an adverse effect on traffic capacity or safety.
The planning reason for non-allocation relating to accessibility has been fully addressed. It is clearly illustrated the site is in close proximity to important supporting community infrastructure as well as public transport. The issue of school capacity would impact upon all new development sites in Brentwood.
Recommend the site is acknowledged as being part brownfield / PDL in the Local Plan.

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Object

Draft Local Plan

Policy 7.4: Housing Land Allocations

Representation ID: 15208

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Recommend that the site at Sawyers Hall Lane is identified as a Housing Land Allocation in the Local Plan, and that the site is released from the Green Belt.
The site at Sawerys Hall Lane is available, the location is suitable, development is achievable. Recommend that the site is brought forward within the first five years of the plan period.
The site is able to secure the long-term future of Hopefield Animal Sanctuary (and this approach to the proposals has been agreed in principle with the existing occupier).
The proposals are also able to deliver a range of social, economic and environmental benefits to Brentwood and would meet the Council's strategic objectives

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Comment

Draft Local Plan

Policy 5.1: Spatial Strategy

Representation ID: 15227

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Support the spatial strategy in general and recommend Site at Sawyers Hall Lane is allocated as it meets the requirements of Policy 5.1, being located in the A12 Corridor and the demonstrating characteristics which are necessary to justify Green Belt release for housing.

Recommended that due to Crossrail, strategic infrastructure investment, that deliverable and suitable potential housing sites around Brentwood town are identified for development in the Local Plan e.g. Sawyers Hall Lane. It must be noted that the effect of Crossrail enhances the Site at Sawyers Hall Lane's credentials as an accessible location and suitable site for growth.

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Comment

Draft Local Plan

Figure 7.2: Housing Land Allocations

Representation ID: 15228

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Noted in the SA the option to the North of Brentwood scored comparably against Dunton Hills Garden Village and West Horndon. Therefore although no specific location is set out, it is considered that as a result, development to the North of Brentwood (Sawyers Hall Lane) represents a sustainable site.

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Object

Draft Local Plan

Policy 5.2: Housing Growth

Representation ID: 15229

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Housing target should be increased because the "OAN" calculation fails to take account of market signals, affordable housing needs and the impact of crossrail.
Reccomended the Council works with its neighbours under the duty-to-cooperate to coordinate and fully understand local needs.
The Draft Local Plan should be positively prepared to take account of these factors. The housing target in Policy 5.2 is not fully justified, effective or consistent with national policy.

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Object

Draft Local Plan

Evidence Base

Representation ID: 15232

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

The Council's evidence base on OAN is spread across a number of studies undertaken by different organisations. There is a lack of a clear narrative about how the various components of the evidence have been brought together to derive OAN for 362 dwellings per annum identified in the Draft Local Plan.

The PBA Study shows that housing delivery has exceeded past housing targets, and based on analysis of a range of indicators suggested that there was not automatically a basis for making an upward adjustment to figures to respond to market signals. We suggest that this is inconsistent with the evidence [see full rep for detail].

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Object

Draft Local Plan

Policy 5.2: Housing Growth

Representation ID: 15234

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

There are 3 areas which the Council should consider in more detail in order to provide an assessment of the OAN need for market and affordable housing as required by the Framework. These are:
1. Market Signals. The PBA Study shows that housing delivery has exceeded past housing targets, and based on analysis of a range of indicators suggested that there was not automatically a basis for making an upward adjustment to figures to respond to market signals. We suggest that this is inconsistent with the evidence.
2. Affordable Housing Need. Council's evidence indicates 234 affordable homes per year. PPG makes it clear an increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes. There is limited evidence that the Council has considered this issue to prepare the Draft Local Plan.
3. Impact of Crossrail.

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Object

Draft Local Plan

Evidence Base

Representation ID: 15243

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Limited reference of Crossrail to inform the OAN. This provides a clear local driver which can be expected to enhance demand for housing relative to trend. This warrants further careful evaluation as the plan is developed.

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Comment

Draft Local Plan

Policy 7.5: Affordable Housing

Representation ID: 15247

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Evidently not all schemes will be able to deliver policy-compliant affordable housing provision (taking account of site viability) and some developments will fall below the threshold. Assuming 30% affordable housing delivery with a target of 362 dwellings per annum, 109 affordable homes would be delivered per annum. The plan thus can be expected to meet less than half of the affordable need - providing a clear basis considering higher provision.
The high need for affordable housing clearly points to a need to consider increasing overall housing delivery.

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