brentwood.gov.uk

Whilst we support elements of the spatial strategy as set out in policy 5.1, we do not believe that this strategy has been carried through into the allocations and detailed policies. We do not support other elements of the strategy. Specifically the reliance on a new settlement to deliver a significant proportion of the Borough's needs and the decision not to release any Green Belt sites adjacent to Larger Villages in the A12 corridor.
We support the strategy to focus development within the transport corridors with Brentwood and Shenfield being the main focus, however, we do not support the reliance two strategic allocations in the A127 corridor to deliver the Borough's needs.
Whilst the spatial strategy suggests Brentwood and Shenfield will be the main focus for development, urban area site allocations total only 1,266 dwellings. This is significantly lower than the so called "supporting" strategic allocation of 2,500 new dwellings, which comprises 35% of the Borough's housing requirement. Other Greenfield urban extensions account for a further 1,292 dwellings and Green Belt brownfield 97 dwellings. It is clear from the numbers alone that the focus of development is not, as stated in the spatial strategy, Brentwood and Shenfield, but Dunton Hills Garden Village in the A127 corridor.
Dunton Hills Garden Village does not support the strategy, it underpins it and the strategy relies upon it. Elsewhere in consultation document Dunton Hills Garden Village is described as delivering a "significant proportion" of need and being "critical to delivering the Plan's key development objectives".
We strongly object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations.
Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live.
Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take an average of five years to deliver, from submission of a planning application.
As such, we support the release of smaller Green Belt sites within the transport corridors to meet local needs fully and provide development quickly. We also support the strategy for limited development in villages. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. It is also logical to allocate a range of site types and sizes as opposed to rely on larger strategic sites only.
We object to the decision not to allocate any sites surrounding Larger Villages, specifically at Mountnessing.
Mountnessing lies within the A12 corridor, which the spatial strategy claims to be the focus for development. It is also a sustainable settlement, being served by a local shopping parade and primary school.
However, no sites have been allocated save for existing permissions. Conversely, allocations have been made in Brentwood, Shenfield and Ingatestone, which are also in the A12 corridor.
The explanation for this departure from the spatial strategy appears to be due to Mountnessing occupying a lower position in the settlement hierarchy and/or the existence of recently granted planning permissions. However, to exclude allocations based on the settlement hierarchy is inconsistent compared to treatment of other settlements in this category and in the A12 corridor. Furthermore, the recently granted consents do not serve the needs of Mountnessing.
Mountnessing has been categorised as a "Larger Village" where, according to paragraph 5.33, no Green Belt alterations are proposed "in order to retain the character of the Borough in line with the spatial strategy".
Other Larger Villages are Blackmore, Doddinghurst, Herongate, Ingrave, Kelvedon Hatch and West Horndon.
Blackmore, Doddinghurst and Kelvedon Hatch are in the Rural North where the spatial strategy does not claim to focus development. It allows for only limited infilling at a level commensurate with services and facilities available. To exclude allocations from these settlements is consistent with the spatial strategy.
Similarly, Herongate and Ingrave are in the rural south where the same strategy exists and are therefore also logical exclusions.
The only other Larger Village within a transport corridor, where the spatial strategy seeks to focus development, is West Horndon in the A127 corridor. Whilst no Green Belt boundary change is made, the existing industrial estate is allocated for redevelopment, to deliver 500 new dwellings.
Ingatestone has sites within the urban area, plus both greenfield and brownfield sites outside of the urban area, proposed for delivery of 128 dwellings. Ingatestone, as Mountnessing, lies in the A12 corridor focus for growth area.
Ingatestone has been categorised as a "Village Service Centre" as the Borough's largest village. However, we question whether it occupies a higher category than Mountnessing and the other Larger Villages as a means of setting it apart in order to justify alterations to the Green Belt boundary. Whilst it is larger than the other Larger Villages and benefits from a greater service provision, it stands alone as the only settlement currently within this category. Whilst Dunton Garden Village and West Horndon are proposed to be included later in the Plan period, this is as a result of the development proposed through this Plan.
It is our strong opinion that being a sustainable settlement in the A12 corridor Mountnessing should be treated in the same way as Ingatestone and West Horndon and allocations for a modest level of development should be made. This would be consistent with the spatial strategy to focus development in the Borough's transport corridors and ensure that both the local and Borough's needs are met in the early years of the Plan. With no brownfield redevelopment opportunities, this would necessitate Green Belt release to comply with the spatial strategy to focus development in the transport corridors.
Paragraph 5.19 and figure 5.7 provide an explanation as to why no sites have been allocated at Mountnessing; that planning permission has already been granted for 172 new homes. Paragraph 5.19 states that these will "make a significant contribution to the Borough's needs" and figure 5.7 that they "will contribute to village life".
However, we object to the reliance on these sites; they do not make a "significant" contribution to the Borough's needs and they do not serve the needs of Mountnessing due to their physical separation from the settlement and lack of affordable housing provision.
The Borough's housing need for the Plan period is 7,240 dwellings. At only 2.4% of the Borough needs, 172 homes cannot be said to be a "significant" contribution.
Thoby Priory (15/00527/OUT) lies approximately 1km to the north of the Mountnessing village boundary, in open countryside. Whilst the highways support is subject to a condition to provide a new cycle and footway linking the site to Mountnessing, this does not change the physical separation of the site or guarantee sustainable movements between the site and the village.
The second site is the former scrap yard (14/01446/EIA) which lies approximately 700m to the south west of the Mountnessing village boundary, adjacent to the A12 junction. The highways condition for this consent also requires construction of a new cycle and footway.
Thoby Priory does not have planning consent; it is still subject to a resolution to grant. Whilst it is appreciated that this doesn't necessarily render the site undeliverable, it does raise questions, particularly since the delay in signing the section 106 agreement is due to viability testing in relation to affordable housing provision.
The proposal which went before the committee was for 87 market dwellings and no affordable housing. This was subject to a satisfactory Viability Assessment in support of this. A recent telephone conversation with the case officer confirmed that the Viability Assessment has not yet been agreed and nor has any Extension of Time. As such, there is no certainty of timescales for granting of consent or delivery of the site. Indeed, the case officer indicated that should no agreement be reached regarding the Viability Assessment, the application would have to be returned to committee.
Assuming that agreement can be reached and the permission granted as per the committee report, the site will deliver no affordable housing and no commuted sum for off-site provision. As such, it will not deliver local needs.
The former scrap yard site has planning permission granted for 85 residential units with a section 106 agreement to provide 24 of these dwellings as affordable dwellings on-site plus a financial contribution to provide a further 8 affordable dwellings off-site. It is not clear whether a specific site for the off-site provision has been identified and we are not aware of any sites for this purpose in Mountnessing.
Combined, these two sites provide less than half of the required level of affordable housing so fail to meet the localised affordability needs of Mountnessing and those of the Borough.

Paragraph 7.9 of the Draft Plan is unequivocal that there is a "significant need for additional affordable housing" in the Borough. This is evidenced by the SHMA.
Policy 7.2 requires residential development proposals to "provide an appropriate mix of dwelling types, sizes, tenures and specialist accommodator to meet the specific needs of existing and future households in the Borough"
Policy 7.5 requires a minimum of 35% of affordable housing on sites of 11 or more dwellings to be provided on-site, with only fractions being provided through a financial contribution. This allows for situations where the full affordable requirement cannot be provided and requires the developer to provide evidence as to why it is unviable and negotiate a level of affordable housing provision which is achievable.
Under this emerging policy, of the combined total of 172 dwellings with permission/resolution to grant in Mountnessing, 60 would be required to be affordable housing. However, these sites provide only 24 on-site affordable dwellings, or 14%. This falls considerably short the 35% required. Even if the additional 8 dwellings are included (which it is assumed will not be provided in Mountnessing since no amendments to the village boundary are proposed), the provision would be only 19%.
Whilst it is appreciated that as brownfield sites, the reduction in affordable housing may well be justified on viability grounds, this does not change the fact that there is an under provision of affordable housing for Mountnessing under the Draft Plan.
Mountnessing Parish Council objected to the Thoby application on the basis of a lack of affordable housing, confirming that the development, "...will not address the current situation where even small houses are unaffordable for many people especially the younger generation."
This underprovision of affordable housing is an unsound approach since it fails to meet the policy tests within the NPPF (which requires the needs identified in the SHMA to be met) and those of the draft Plan itself. As such, additional greenfield land must be released adjacent to Mountnessing, which will be able to deliver this affordable need.
Allocation of additional land for housing at Mountnessing would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services. Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, including high vacancy rates in the three retail units within the village and led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).
One such suitable site is Land Adjacent to Mountnessing Primary School, (site 073 under the Strategic Growth Options Consultation and SHLAA site G093). Previously promoted by Crest Nicholson under an option agreement, it is now being promoted directly by the Landowner with Sworders acting as Planning Consultants on the Landowner's behalf.
This site could be sensitively developed to provide short term delivery of much needed private and affordable homes of up to 18 units.
The site is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact, it would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary. It is situated close to the existing retail units and is thus more likely to support these than the two recently applied for developments at Thoby Priory and Mountnessing Roundabout, which are some distance from the village. Occupants of these two new developments are far more likely to drive directly to higher order facilities in other towns than residents who live within easy walking distance of existing village facilities.
The site adjacent to Mountnessing Primary School does not serve any of the purposes of the Green Belt in accordance with the NPPF and no constraints have been identified that would prevent its development for residential use.
The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan period. This site is identified as the only suitable residential site at Mountnessing.
As such, Land adjacent to Mountnessing Primary School should be allocated for residential use to serve the needs of Mountnessing and contribute towards the Borough's needs.