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Draft Local Plan
Policy 5.2: Housing Growth
Representation ID: 15251
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Recommended that the supply of sites is re-considered because the sites set out in Policy 5.2 are not deliverable over the plan period and therefore would not achieve the housing target. This means that assuming there is no change to the housing target, sites to deliver an additional 1,500 new dwellings must be identified.
Recommended that a 10% discount for non-delivery is applied to extant permissions, permitted development and windfall allowance. During the plan period only 50% of the strategic site can reasonably be expected to be delivered reducing supply from this source to 1,250 units.
Therefore recommended that the site at Sawyers Hall Lane is added to the Greenfield Urban Extensions in Green Belt sites to help meet the housing target. The Draft Local Plan should be positively prepared and the housing sites set out in Policy 5.2 must be effective.
See attached
Object
Draft Local Plan
Policy 7.1: Dunton Hills Garden Village
Representation ID: 15260
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Consider the levels of development within the Plan at Strategic Site Dunton Hills Garden Village to be completely unrealistic based upon reasons relating to:
- Suggested phasing as set out in Appendix 2. These completion rates are overly ambitious.
- Joint-working under the duty to co-operate is essential to bring the site forward. It is considered vital that the whole Strategic Site opportunity is fully embraced by both Local Plans, at present this is not the case, and therefore the contribution of the Strategic Site to Brentwood housing target is questionable.
- Lead-in period to the commencement of development would be expected to be several years.
See attached
Object
Draft Local Plan
Housing Trajectory
Representation ID: 15261
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
The Council cannot demonstrate five year housing land supply. Our assessment [see full representation] concludes that Brentwood has less than 2.5 years housing land supply. This represents a significant and serious shortfall in housing sites.
Recommend that sites for housing in addition to those already identified in the Local Plan must be identified to come forward in the first five years e.g. Sawyers Hall Lane.
See attached
Object
Draft Local Plan
Appendix 2 - Proposed Housing Delivery
Representation ID: 15262
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Notably the five year housing land supply assessment does not include the Strategic Site as it is
planned to come forward in years 5 to 10 (not the first five years). The Council cannot demonstrate a five year housing land supply and therefore the Draft Local Plan is not sound.
See attached
Comment
Draft Local Plan
Policy 7.4: Housing Land Allocations
Representation ID: 15264
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Recommended that Policy 7.4, and supporting Figure 7.2, is revised to include the site at Sawyers Hall Lane as a Housing Land Allocation.
The sequential approach towards site selection and delivery is supported, however the delivery of identified sources of housing supply is questionable, and it is recommended that the housing target is increased.
In the SA the site at Sawyers Hall Lane achieves the same overall "score" as the three allocated Greenfield Green Belt sites in Brentwood.
See attached
Support
Draft Local Plan
Policy 9.11: Previously Developed Land in Green Belt
Representation ID: 15266
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Support Policy 9.11, as this policy direction recognises latest Government announcements and consultation of the NPPF which recognise the important role that brownfield sites will play towards accelerating housing delivery. Any brownfield opportunities in the Green Belt should be maximised. Therefore it is recommended that the Council acknowledge the fact that the site at Sawyers Hall Lane is a part brownfield site in the Green Belt.
See attached
Support
Draft Local Plan
Policy 10.1: Sustainable Transport
Representation ID: 15269
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Representations support Policy 10.1 and encourage the Council to maximise any additional development potential arising from Crossrail, especially in Brentwood and Shenfield e.g. Sawyers Hall Lane.
See attached
Comment
Draft Local Plan
Policy 10.9: Open Space, Community, Sport and Recreational Facilities
Representation ID: 15284
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
In relation to the site at Sawyers Hall Lane, the proposals to bring forward the site would secure the long-term future of Hopefield Animal Sanctuary, which is recognised as an important community facility in the Borough. Therefore the site should be allocated for development to achieve this purpose.
See attached
Support
Draft Local Plan
Policy 6.4: Effective Site Planning
Representation ID: 15285
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Support Policy and consider them to be relevant to the site at Sawyers Hall Lane. In particular, the proposals are designed to secure the long-term future of Hopefield Animal Sanctuary. It is therefore recommended that the proposals are favourably considered.
See attached
Object
Draft Local Plan
Chapter 1. Introduction
Representation ID: 15289
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
At present, the Draft Local Plan is considered to be not sound.
- Not positively prepared: strategy for growth including the proposed housing target is not based on a national policy compliant calculation of OAN. To become sound, the proposed housing target must increase and additional land for housing must be allocated to deliver the strategy.
- Not justified: strategy is not appropriate and it cannot be delivered. To become sound, additional land for housing must be allocated to deliver the strategy.
- Not effective because the plan is not deliverable. The identified source and supply of housing sites will not be delivered over the plan period and will not achieve the proposed housing target. In addition the Council cannot demonstrate a five year housing land supply, and there is a lack of evidence of joint-working with neighbouring authorities through the duty-to-cooperate. To become sound, additional deliverable and suitable sites for housing be identified to come forward in the first five years; and,
- Not consistent with national policy: the proposed housing target has not been prepared in accordance with the NPPF or NPPG.
See attached