Comment

Representation ID: 16020

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The site being put forward for consideration is a smaller part of the site ref GO92 in the 2011 SHLAA. A map detailing the boundary has been submitted, in Hutton Conservation Area and is in Green Belt. The sustainability and suitability for development are addressed within Section 4 of this submission.

Comment

Representation ID: 16021

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Consider Plan will be found unsound due to duty to cooperate; objectively assessed housing need; Brentwoods housing growth strategy and the Sustainability Appraisal.
The following needs to be done to make the plan sound:
Review the current proposed number of homes to be provided 2013-2033 having regard to market signals and unmet housing need within areas with which the Borough is connected, to be determined through further working under the Duty to Cooperate with relevant Authorities.
Ensure that the Local Plan does not rely on the delivery of Dunton Garden Hills Village or windfall to meet housing needs, due to considerable uncertainty regarding their potential to deliver housing.
Reduce reliance on large strategic sites that will not be delivered in the short- term, and seek to address the current, urgent housing need through the identification of a range of smaller, deliverable sites in sustainable locations; and ensure the provision of a five-year housing land supply.
Apply a more sophisticated and transparent approach to site selection (and Sustainability Appraisal of potential sites) that considers the sustainability and deliverability of sites, along with their potential to relate to a spatial strategy for development linked to the settlement hierarchy.

Comment

Representation ID: 16022

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Reliance is being placed on the Dunton Hills GArden Vilalge for significant numbers of the housing provision over the life of the plan. There is no published evidence that the Duty to Cooperate with Basildon is being fulfilled to progross plans and firm up proposals. Basildon states that "Brentwood Borough Council has not provided sufficient information, at this time, to show it is the best location for new housing provision in the Brentwood borough". Information on engagement with London and London brooughs is also lacking.
Therefore it is not clear to what extent authorities with whom Brentwood Borough has a connection have been engaged and are agreeable to such an approach. This issue is particularly pertinent given the strong relationship between Brentwood and London, and the latter's acute housing need. We question whether the approach currently being taken in the preparation of the Local Plan meets the Duty to Cooperate.

Object

Representation ID: 16027

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Noted that the Council are using the 362 dpA identified by the 2013 SHMA. Also noted that the OAHN considers the delivery of 411 dpA as a feasible target for Brentwood Borough. It is unclear on whet basis this level of growth was rejected. The borough should have regard to market signals and with the borouhs expensive housing cost, comparable to London prices, the figure should be revised upwards from the houshold projections. It is not clear from the DLP how unmet needs in neighbouring areas have been considered. On the contrary, the DLP indicates at paragraph 5.36 that only housing needs within the Brentwood Borough boundary have been addressed. The DLP recognises how well connected the Borough is with neighbouring areas and London. It follows that the Borough may be suitably placed to accommodate some of the unmet needs of such areas, and this should be explored through the Local Plan process if it is to avoid being unsound.

Comment

Representation ID: 16031

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The intrinsic economic benefit of housing development should be recognised and jobs relating to the supply chain. Housing development also engenders local economic benefits relating to additional local expenditure. It is important that the economic growth aspirations of the Local Plan and the housing growth policy support, rather than contradict, one another. There are clearly factors that suggest the Brentwood Local Plan should seek to deliver a greater number of homes than proposed in the DLP. At the very least the provision of a greater number of dwellings is a reasonable option that should be explored.

Object

Representation ID: 16033

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The Brentwood Local Plan should seek to deliver a greater number of new homes than the DLP proposes. However, we would question the deliverability of even the reduced quantum based on the strategy currently proposed by the DLP. Of particular concern is the reliance placed on Dunton Hills Garden Village and on windfall to help meet housing needs.

Object

Representation ID: 16034

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Dunton Hills Garden Village requires support from Basildon which is not in evidence. The delivery of a development of the scale of Dunton Hills Garden Village would require collaborative working between a multitude of authorities, service / infrastructure providers, landowners and developers. the suitability and sustainability of Dunton Hills Garden Village is questionable, the proposed new station is not included in the Network Rail Anglia Route Study Draft for Consultation (November 2014), which sets out the strategic vision for the future of the Anglia route network over the next 30 years. The Dunton Garden Suburb consultation documents are largely silent on the access strategy and potential mitigation measures necessary to accommodate development traffic on the existing local and strategic highway network.

Object

Representation ID: 16035

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The DLP strategy relies on windfall to deliver 928 dwellings - 12% of the proposed total. By definition, there is considerable uncertainty as to how much of a contribution windfall will be able to make towards delivery housing. It is far from clear that it will be able to make the level of contribution which the DLP assumes. Brentwood should not rely on windfall, as per para 47 of NPPF.

Object

Representation ID: 16040

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Figure 5.10 of the DLP shows that the current housing delivery rate is well below that required to meet what the Council consider to be the Borough's need. Furthermore, it is projected to remain below this level in the short-term. There is clearly a current, urgent housing need in the Borough. The DLP should not seek to rely on large strategic sites to deliver housing, as these cannot meet housing need in the short- term and enable the Borough to retain a five-year housing land supply, as required by the NPPF (para 47). To ensure the plan is capable of addressing the current urgent housing need and ensuring a five-year housing land supply a range of sites should be identified, including smaller sites that are deliverable in the short-term.

Comment

Representation ID: 16041

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The inclusion of Hutton within Settlement Category 1 suggests it is an appropriate and sustainable location to direct a proportion of growth towards. However, it is unclear how the settlement hierarchy has informed the selection of sites for development within the DLP.