brentwood.gov.uk

Object

Representation ID: 1150

Received: 30/09/2013

Respondent: Chater Homes Ltd

Agent: EJW Planning Ltd

1. Concern is raised with regard to the mechanisms for achieving the supply forecast on the sites
which are allocated. Additionally, the forecast supply makes no allowance for permissions that will lapse. Given
recent market conditions these assumptions are unsound. It would be appropriate to conclude that up to 15% of the outstanding planning permissions listed in the Housing Trajectory at Appendix 3 of the Plan will lapse.
As a result, a greater number of housing land allocations are required. The Plan would benefit from increased flexibility to ensure a continuous and rolling supply of housing land and the need for deliverable sites is met.
We do not believe that this can be achieved by Policy DM23, as there is too much reliance on the delivery of new homes on small brownfield sites, the majority of which are owned by the Council. The 3,500 target has only been achieved by maximising site densities to unrealistic
levels.The suggested densities as shown at Table 4 of the Council's Five Year Housing Supply Assessment 2012-2017, are on average between 60-80 dph, with some sites shown as high as 120-150 dph which is wholly inappropriate for this suburban location.
2. Furthermore, Policy DM23 should not refer to the allocated sites as major sites, as this is ambiguous. The majority of the sites identified in the policy are for between 10 and 20 houses, which in a built-up area like Brentwood does not constitute a major housing development.

Growth needs to be planned for, over and above the proposed allocations. The proposed strategy is not effective and there is a requirement for further contingency and flexibility within the Plan. The site put forward by Chater Homes is deliverable within the plan period.Although this is a Green Belt site, it is important to recognise that there is insufficient
brownfield land to accommodate housing requirements that have been forecasted for Borough and, therefore, sustainable and appropriate Green Belt sites such as this will have to come forward in the Plan period.