Comment

Representation ID: 15901

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

It does appear that the starting point for Brentwood is to meet the lower OAN. It is not entirely clear from the OAN report how the Council decided to progress a housing target 362dpa and this should be clarified moving forward.

Object

Representation ID: 15902

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

The SHMAA considers the housing market for Brentwood is self-contained. Brentwood Borough has strong inter-connectivity with London and Essex and therefore could not be considered a self-contained Borough. There appears to be strong commuting flows with Basildon and Chelmsford, and the construction of Crossrail (strategic objective S07) will only increase this connectivity with London and Essex. On that basis, we consider that Brentwood should consider a joint-SHMA with Basildon, Chelmsford and Epping Forest to establish the overall OAN for the HMA and how the overall OAN can be collectively met.

It is not clear from the draft Local Plan and the supporting evidence base whether or not the Council has fully considered London migration and this is therefore contrary to NPPF.

Comment

Representation ID: 15903

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

Green Belt protects Brentwood's high quality environment and at the same time constrains development opportunities, making it difficult to meet development needs in full. However, there are likely to be many sustainably located sites that do not fulfil the five purposes of the Green Belt as set out in Para 80 of the NPPF, and should therefore be considered for released as part of the plan-making process. The Council should also consider the release of reserve sites for release beyond the plan period or in the event that the proposed allocations fail to deliver.

Comment

Representation ID: 15904

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

It is positive that the Council will release Green Belt land (albeit "limited") for development within transport corridors, in strategic locations and urban extensions. However, there are further areas that should be considered for release from the Green Belt to allow a flexible approach for expansion greater than that, which has already been considered in the Council's OAN projection.

Support

Representation ID: 15905

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

Support the removal of site 022 from the Green Belt and its proposed allocation for around 250 dwellings.

Comment

Representation ID: 15906

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

'Land to the rear of BT officers' (15.6ha) offers the opportunity to infill development contained within the urban area of Brentwood. The site should therefore be allocated.

Comment

Representation ID: 15907

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

the best approach for the Council to maintain a deliverable five year housing land supply against the up-to-date OAN, is to ensure the release of a range of sites, of varying sizes, in several locations. To ensure delivery, especially within the first five years of the plan, strategic scale allocations should be balanced with smaller sites.

The current reliance on windfall sites is inappropriate and therefore not fulfilling the objectives of NPPF. The allocation of Dunton development appears to be risky strategy and could result in a significant shortfall in the supply of housing if it is proved undeliverable.

Comment

Representation ID: 15908

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

There appears to be a lack of cross-boundary co-operation between Brentwood and Basildon Borough Council on this matter. The Basildon Consultation 2016 (Policy H10) confirms that insufficient evidence has been prepared to demonstrate that the Dunston Garden Village is appropriate or deliverable in the plan period.

Comment

Representation ID: 15909

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

It is imperative that a full Green Belt review is undertaken to identify additional sites that could be considered for release in the medium and longer term.