brentwood.gov.uk

In regards to Spatial Strategy: We 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 much longer to deliver. We support the spatial strategy, as set out at paragraph 31, to focus upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with the NPPF (paragraphs 17 and 111). It is also in accordance with the draft policies in the new NPPF consultation proposals March 2018; Chapter 11 reinforces and strengthens this aim. However, we do not consider that the capacity of brownfield sites has been fully explored. The Site Assessment Methodology and Summary of Outcomes (January 2018) states that the approach was to prioritise using brownfield land first and then consider growth in settlements in terms of their relative sustainability linked to services and facilities. However, the process actually discounts sites where they are considered to be in an unsustainable location, which included sites in the Green Belt with no connecting boundary to an existing urban area, before considering the potential to exploit brownfield land. This has resulted in sites such as site 183 being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable. Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail. Paragraph 32 of the NPPF requires that: "...the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure". On this basis, it is considered that the site is sufficiently sustainable to support a small to mid-sized residential development. In regards to Dunton Hills Garden Village: We object to this policy to propose a new settlement to deliver 2,500 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged. We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF. It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example nearby Uttlesford District Council. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings. Adopting the lag of seven years and a Plan adoption date before the end of 2019 would mean there would be no deliveries on site until 2026. There are no circumstances that suggest that Dunton Hills Garden Village can deliver more quickly than the seven years recommended by the above research. As such, we object to the reliance on this site for such a large proportion of the Borough need and consider that a greater number of smaller sites should be allocated to allow for flexibility and earlier delivery. In regards to Housing Need: We object to the planned housing need on the basis that it is insufficient to meet the Borough's needs. Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The consultation document assumes a housing need of circa 380 dwellings per annum or 7,600 dwellings across the plan period (2013-33). However, the Department for Communities and Local Government consultation on the methodology for a standardised approach to calculating local housing need in England demonstrates a housing need of 454 dwellings per annum in Brentwood Borough, an increase of 74 dwellings per year over the planned figure. Whilst it is appreciated that under the current timetable the Borough are expecting to take advantage of the transitional provisions in the draft NPPF currently open for consultation, the Plan should nevertheless take account of Governments direction of travel. A cursory 'overprovision' of only 663 dwellings does not do enough to account for the significant upward housing pressure in the Borough. Whilst the transitional provisions currently open for consultation in the draft NPPF suggest that any plans submitted this year will be examined under the old (current) NPPF, the Brentwood Local Plan is still at a relatively early stage of production. We also consider the current timetable, which allows only six months to consider representations to the current consultation and publicise and submit the Regulation 19 Plan, to be extremely ambitious. As such, the deadline to take advantage of the transitional provisions could well be missed. In this instance, the Council will have to go back to Regulation 18 stage to consider the new housing need. However, planning for the higher housing need at this stage will enable for the Plan to continue to examination, even if this deadline is missed. The "fallback position", should the Council need to accommodate this significant increase in housing need, is consideration of whether the delivery of Dunton Hills Garden Village could be accelerated to increase its dwelling yield within the plan period. However, this has not been fully explored and, as set out in our comments in relation to the Dunton Hills allocation, the current anticipated delivery is ambitious, making accelerated delivery wholly unrealistic. Failing to meet the objectively assed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound. Notwithstanding the above objection to the quantum of the housing need, we also object to the proposed strategy to deliver this need. Figures 8 and 9 demonstrates how the housing need will be met. These show an intention to deliver 663 dwellings in excess of the identified need of 7,600 dwellings. However, this includes both a windfall allowance and "Forecast Forward - additional completions and permissions between 1st April 2017 and 31st March 2018". Both of these figures are uncertain and taken together total 757 which exceeds the 'overprovision' of 663 dwellings. The plan does not appear to include any non-implementation allowance, therefore, in order to meet the objectively assessed need every single extant consent, allocation, permitted development, plus the "forecast forward" and windfall allowance must come forward during the plan period in order to meet the minimum need requirement. As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF. In regards to Settlement Heirachy: Whilst we support the classification of Ingave as a "Category 3 - Large Village", we object to the inconsistent treatment
of this settlement in comparison to other settlements occupying the same level in the hierarchy. For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave. The moratorium of growth in these villages is contrary to the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities (paragraph 55). The new draft NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 80). Allocation of additional land for housing at Ingrave 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.