brentwood.gov.uk

On behalf of our client, Ms. Lunnon, we hereby submit further representations on the
Preferred Site Allocations Document in respect of land to the North of Hay Green Lane,
Hook End. The JTS Partnership had previously put forward representations for residential development on behalf of our client that could contribute to the housing land supply in this part of the Borough. There were two parcels of land put forward under the previous Call for Sites under references HELAA172173 & HELAA172595, comprising 3.34 and 0.22 hectares. The site is bordered by residential development to the south and west with Mill House Farm and industrial uses to the east of the site. This representation reinforces those earlier submissions, but also should be read in the context of The JTS Partnership generic representations which criticises the Council for not, as yet, undertaking a full and comprehensive view of the Green Belt boundaries around each settlement. This area of land which is in the Green Belt is considered to be a logical rounding off of the Green Belt in this location and seen in the context of established ribbon development opposite the site to the south where infrastructure is already in place. Preferred Site Allocations January 2018 It is noted from a review of the draft Site Allocations and the Sustainability Appraisal of the Brentwood Local Plan, that the LPA have provided little or no additional housing in villages, where one would expect some limited development going forward. There is a need for some limited development in these villages and towns in order to sustain those villages and it is considered that the proposed development would be a small but meaningful way of providing some limited housing in this village location. Housing Allocations: It is noted that the local authority have only allocated a total of 169 new dwellings to larger villages out of a total of 8263 new housing allocations. This is considered to be wholly inadequate and there should be a greater emphasis in providing more housing on the edge of these villages and settlements. As previously highlighted to the LPA in earlier submissions on this site, this proposal would represent a natural rounding off of the Green Belt in this location. NPPF Consultation: The latest consultation on the revised National Planning Policy Framework (NPPF) includes a measure proposed in last year's Budget requiring 20 per cent of councils' housing supply pipeline to comprise small sites, subsequently defined as those smaller than half a hectare. It is noted from a review of all sites currently put forward, that the council fall significantly short of this target. Sustainability Appraisal [January 2018] Furthermore, the Sustainability Appraisal produced by AECOM highlights the lack of site allocations in smaller settlement areas despite being in conflict with Government Guidance and in particular the Housing White Paper which was published in February 2017. Paragraphs 6.5.20 of that Sustainability Appraisal states the following: 6.5.20 "The 2016 Draft Plan did not propose allocation of any sites; however, subsequent detailed work by the Council to examine site options - including through detailed Green Belt review -led to the identification of several development opportunities. There is also a strategic context, in light of the 2017 Housing White Paper, which supports smaller sites and growth at villages, and "expect(s) local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently find it hard to live where they grew up." We would recommend that the Council review all or part of this site as it is completely enclosed and not seen from wider viewpoints, seen in the context of established ribbon development to the south woodland to the north and Mill House Farm and employment uses to the east. There are no overriding physical constraints to the development of the site which is available, suitable and achievable. Nor is there is there any obstruction to the early deliverability of this site. It is considered that the site is highly suitable for residential development, is sustainable, and would accord with the Government objective of ensuring that an adequate and continuous supply of housing is appropriately identified to meet future housing requirements, particularly where the Local Planning Authority are unable to demonstrate an adequate 5-year housing land supply. We would ask that the Local Authority allocate this site as part of their Site Allocations for future development in the district as without some greater allocation to the larger villages, we would consider the emerging Plan to be unsound.