Object

Representation ID: 16042

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

We note that sites have been selected based on a "sequential approach to sustainable land use" (paragraph 7.29 of the DLP). This appears to result in any site within an existing settlement boundary being automatically considered more sustainable than brownfield sites in the Green Belt, which in turn are considered inherently more sustainable than any greenfield site in the Green Belt. We question the soundness of such a simplistic approach to the consideration of sustainability, and whether this approach will result in the most sustainable strategy when considered against the reasonable alternatives. Furthermore, it is unclear whether a Green Belt review has been undertaken prior to this filtering process to determine whether all land currently allocated as such meets the purposes of including land in the Green Belt, as set out in the NPPF.

Object

Representation ID: 16043

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Five greenfield Green Belt site are proposed for allocation for housing development in the DLP. The justification for the identification of the five greenfield Green Belt sites is unclear, as is the justification for the rejection of land adjacent to Rayleigh Road, Hutton.

Object

Representation ID: 16044

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

There is reference at paragraph 7.28 of the DLP to the 2010 Strategic Housing Land Availability Assessment (SHLAA) being the starting point for considering sites as part of the plan making process. The most recent SHLAA is the 2011 iteration, and as such is somewhat dated. Furthermore, whilst a larger parcel of land in which our client's site sits was assessed by the Council as part of the Brentwood Borough 2011 SHLAA as site reference GO92, it is unclear how the site as submitted in response to consultation on the Strategic Growth Local Plan in February 2015 has been assessed or considered.

Comment

Representation ID: 16045

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

In terms of site reference GO92 and its assessment in the SHLAA 2011, the SHLAA 2011 found the site GO92 to be available and achievable, but stated that it was not suitable. The justification for this set out within the SHLAA was as follows:
"The site lies within the Hutton Village conservation area and development on this scale would have an unacceptable impact on the character of the conservation area. Development would also have a detrimental impact on the visual and landscape quality of the area." The above concerns have been addressed through subsequent submissions to the
Council.

Comment

Representation ID: 16048

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Submissions were made in relation to a smaller area of land that forms part of site GO92 in response to the Council's consultation on Strategic Growth Options and Dunton Garden Suburb Local Plan Consultation in February 2015. This submission was accompanied by extensive supporting technical work, comprising:


* Site Opportunities and Constraints plan prepared by Go Planning Ltd.
* Site Master planning prepared by Go Planning Ltd.
* Site Context Sheets 1 & 2
* Site Landscape Assessment prepared by Lockhart Garratt
* Tree Constraints and Opportunities Report prepared by Lockhart Garratt
* Ecological Constraints and Opportunities Report prepared by Lockhart Garratt
* Access Appraisal prepared by Journey Transport Planning.
Submission also addressed concerns raised by the SHLAA in respect of the larger area of land in which the site sits

Comment

Representation ID: 16049

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The site - as set out in previous representations - is considered sustainable and deliverable. Furthermore, it would not undermine the purposes of including land in the Green Belt, and its allocation for development would result in the creation of a new robust, defensible Green Belt boundary for this location. As such it is a suitable site capable of helping to meet housing need in the short-term. It is not clear from the DLP or its supporting documentation how information submitted to the Council since the publication of the SHLAA has been considered, and why land adjacent to Rayleigh Road, Hutton has not been identified for development in the DLP.

Comment

Representation ID: 16051

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The SA considers all reasonable alternatives. We would draw the Council's attention to judgments in respect of Heard v Broadland District Council, South Norfolk District Council, Norwich City Council [2012] and Save Historic Newmarket Ltd v. Forest Heath District Council [2011]. The judgments in these cases confirm inter alia the need for the public to be presented with an accurate picture of the reasonable alternatives at an early stage; for these alternatives to be subject to appraisal; and for reasons for their rejection / selection to be explained within the Environmental Report.

Comment

Representation ID: 16053

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

We have concerns with the current approach to SA in respect of both how the proposed total housing figure has been considered; and specific individual sites have been assessed. In respect of the total housing target for inclusion in the Local Plan, we note the Interim SA published alongside the DLP assumes the Local Plan will plan for the delivery of 7,240 new homes over the plan period (2013 - 2033). As set out within this representation, the provision of a greater number of new homes is clearly a reasonable alternative that merits consideration. However, there appears to be no assessment of the sustainability of a higher level of growth.

Object

Representation ID: 16056

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

In terms of our client's land at Rayleigh Road, Hutton the site appears to have been appraised as Site ID 219 within Table C of the SA, though this may in fact relate to the larger site in which the submitted site sits and which was assessed as part of the SHLAA 2011. We note that the text which accompanies Table C of the SA states that it presents an appraisal of all site options in terms of all the appraisal criteria set out previously within the SA. However, it also states the following:
"To reiterate, this table is presented for completeness. It is recognised that only limited understanding can be gained from strict GIS analysis; and equally it is recognised that presenting appraisal findings for all site options in tabular format is in practice of limited assistance to those interested in the spatial strategy".
We note, for example, that Site ID 219 has been assessed as performing "particularly poorly" against the Conservation Criteria, simply by virtue of being in the Conservation Area. We would question the robustness of such an approach.
We have been unable to identify the justification within the SA for the failure to include land adjacent to Rayleigh Road, Hutton as site for residential development in the DLP. The site is considered to be a sustainable location for development and the SA should reflect this in its assessment of the site.

Object

Representation ID: 16062

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

There are significant concerns with the current direction being taken in respect of the Brentwood Local Plan. If the Local Plan were to proceed along the lines of the DLP it is considered unlikely to be found sound. To rectify this the following should be done:
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.