brentwood.gov.uk

INTRODUCTION: Paras 1 To 9. Object In November 2017, the Department for Communities and Local Government wrote to the Council expressing its concern about the lack of progress being made towards the adoption of a 2004 Act Local Plan, and putting it on notice that the Borough was on a short list of councils where Government intervention, in the local plan, process was being considered. Whilst there is an imperative on the Council to progress, and adopt, a new Local Plan as quickly as is practicably possible - and the publication of the Preferred Site Allocations document is, therefore, welcomed - a general concern has to be raised that, in its attempt to progress matters as quickly as possible, much of the evidence base, upon which the spatial strategy and individual site allocations are based, are still a 'work in progress' and have yet to be made public, in anything but a draft summary form. In this respect, it is particularly noted that: The Housing and Economic Land Availability Assessment (HELAA) has yet to be published. The Site Assessment Methodology and Summary of Outcomes (SAMSO) January 2018 document remains a 'working draft', with only a brief summary, as to the reasons why potential sites have been rejected, having been published (there is no detailed breakdown or analysis available setting out how sites have been scored / ranked in accordance with the assessment criteria). The Green Belt study, which should underpin and inform all potential Green Belt releases, has not yet been completed, with 'working drafts' only currently being available in respect of Part 1 and 2 assessments. The important Part 3 and 4 assessments (individual sites and review of Green Belt boundaries) do not appear to have been commenced. In the absence of key 'evidence base' documents, it is difficult to comment on the merits, or otherwise, of any of the proposed site allocations. It is also difficult to make a comparison between the respective merits of sites rejected by the Council and those put forward in the Preferred Site Allocations document. This is a fundamental weakness in the Council's approach and the publication of the Preferred Site Allocations document is premature until more progress has been made in respect of the underlying evidence base. As a result, a general objection has to be made to the timing, and content, of the Preferred Site Allocations document and, in particular, to all proposed Green Belt releases. Whilst it is undoubtedly the case that significant Green Belt land will need to be released, in order to meet the development needs of the Borough up to 2033, the Council is not yet in a position to make a meaningful comparative assessment of the merits, or otherwise, of potential Green Belt sites.PART 1: VISION - Paras 26 and 27. Object Whilst the Council's vision for the Borough is generally supported, the evidence base (for the reasons identified above) does not yet support the conclusion that the Dunton Hills Garden Village is the most sustainable way of meeting the development needs of the Borough up to 2033 (and beyond). It is particularly noted that the 'Garden Village' strategy scores poorly in respect of a General Support The Council's decision to revise housing need, from 362 dwellings per annum to 380 dwellings per annum, is consistent with the latest population data and best practice guidance and is generally welcomed. This section of the document does not, however, explain how the Borough Council has, either explicitly or implicitly, taken into account the requirements of Paragraph 47 of the NPPF (e.g. the 5% and 20% buffers). Whilst Paragraph 43 notes the DCLG's recent consultation on producing a standardised methodology for calculating local housing need (a matter which is also set out in the recent consultation on proposed changes to the NPPF), which could increase Brentwood's need to 455 dwellings per annum, or by 1,480 units over the Plan Period, the proposed way of dealing with this (bringing forward the development of Dunton Hills Garden Village earlier in the local plan period, is not considered adequate. The Borough Council either needs to commit to allocating additional sites (in this emerging Local Plan) or to undertaking an early review (immediately after the Plan has been adopted). PART 1: HOUSING SUPPLY - Paras 51 to 56 and Figure 7. General Comment Paragraph 55 notes that the Council received a number of representations, in relation to the 2016 Draft Local Plan, to the effect that there was a lack of information about the site assessment methodology and overall SHLAA / HELAA. As identified above, this situation has not changed, such that it is not possible, on the basis of the information published on the Council's website, to make a meaningful assessment of the merits of the proposed site allocations or the sites which have been rejected by the Council. PART 1: SUMMARY OF PROPOSED HOUSING LED ALLOCATIONS - Paragraphs 57 to 68 and Figure 8. Object Again, the main criticism of this part of the Preferred Site Allocations document, relates to the lack of information, in the evidence base, to support the various figures, and assumptions, set out therein. In particular, there is little information to back up the figures for 'completions', 'extant permissions', 'forecasts forward' and 'windfalls' as set out in Figure 8 - Housing Growth. PART 1: SETTLEMENT HIERARCHY AND ACCOMMODATING GROWTH - Paragraph 75 and Figure 14. Support The proposed settlement hierarchy and, in particular, the classification of Doddinghurst and Kelvedon Hatch as Large Villages / Village Service Centres is supported. For the reasons set out above, however, the position regarding Dunton Hills and West Thorndon has to be reserved although, it is accepted, that if these sites do come forward, as strategic allocations, then they should be Village Service Centres. PART 1: INFRASTRUCTURE PLANNING - Para 76. Support The need to plan for the level of infrastructure, needed to support housing and economic growth, is fully supported. PART 2: HOUSING SITES Object The Council's 'sequential approach' to the identification of housing sites is, for the reasons set out above, generally supported, as is the identification of those sites, as set out in Figure 9: Proposed Housing-Led Allocations, which fall within the following categories:- 1. 'Brownfield' land. 2. 'Greenfield' land within the Brentwood Urban Area and other Settlement Boundaries. However, and because of the paucity of the evidence base, and the fact that work on the HELAA and Green Belt Study (Parts 3 and 4) is still ongoing, it is difficult to make an assessment as to the merits of the proposed Green Belt releases and / or the comparative merits of the sites which the Borough Council has discounted. Whilst the 'sequential approach' to the release of Green Belt sites is supported, a holding objection has to be made to those allocations falling within the following categories: 3. Sites on the edge of the Main Settlements. 4. Sites on the edge of Village Service Centres and Larger Villages. 5. Strategic Allocations. Indeed, and until the evidence base has progressed further, and, in particular, until the drafts of Parts 3 and 4 of the Green Belt study are available, the Borough Council cannot be certain that a strategic Green Belt release is needed, or, if it is, how much development it needs to deliver within the local plan period. Accordingly, and at this stage, a holding objection has to be made in respect of all potential Green Belt releases. PART 2: HOUSING SITES - FAILURE TO INDENTIFY LAND AT ASHWELLS LODGE, BLACKMORE ROAD, DODDINHURST AS A HOUSING ALLOCATION. Object An objection is raised to Part 2 of the Preferred Site Allocations document, as it fails to identify Land at Ashwells Lodge, Blackmore Road, Doddinghurst (Site Ref: 188) as a potential housing allocation. Appendix 6, of the Site Selection Methodology and Summary of Outcomes: Working Draft (SSMSO:WD) document indicates that the site has been discounted because of its potential 'Green Belt impact'. The SSMSO:WD does not, however, quantify, for any site (whether a draft allocation or discounted site) potential impacts and it is, therefore, impossible to draw any conclusions as to the merits of any particular site and / or whether the Council's decision is 'sound'. Ashwells Lodge lies adjacent to the northeast boundary of Doddinghurst (see attached plan) and fronts Blackmore Road (opposite Dill Tree Farm and Dill Tree Health Centre). It comprises the main house, with outbuildings to the rear, and two small paddocks. It extends to some 1,85 ha and there are substantial tree and hedge lines to all boundaries. The settlement of Doddinghurst lies to the east, Dill Tree Farm and Dill Tree Health Centre lie to the north. A farm complex lies to the west, across a small field, with a copse bounding to the southwest. The site is visually contained by existing development and landscaping. The attached plan shows how the site could be developed to provide in the region of 32 residential units, at a density of 17.2 dwellings per hectare. Access would be taken via Blac The site does not occupy an isolated position in the Green Belt. Indeed, it fronts one of the main thoroughfares - Blackmore Road - in this part of the Borough, with there being bus stops, served by frequent services, some 50m to the east. This is a sustainable, accessible, site. Stage 3 - Sustainability Appraisal Appendix 3 of the Draft Local Plan Interim Sustainability Appraisal - January 2018 scores potential sites against a criteria based methodology in relation to 17 categories which are:- 1. AQMA. 2. SSSI. 3. Nature Reserve. 4. Ancient Woodland. 5. Local Wildlife Site. 6. Woodland. 7. GP Surgery. 8. Primary School. 9. Secondary School. 10. Conservation Area. 11. Scheduled Ancient Monument. 12. Registered Park or Garden of Historic Interest. 13. Listed Building. 14. Flood Zones 2 and 3. 15. Special Landscape Area. 16. Green Belt. 17. Agricultural Land. The sites are then put into 5 categories:- Dark Green - site performs particularly well. Light Green - site performs well. No shading - no issue in terms of the relevant criterion. Amber - site performs poorly. Red - site performs particularly poorly. As to be expected, every site (of the 300+ that were considered) performed poorly, or particularly poorly, in respect of one or more categories. The subject site is rated as having no impact upon a particular issue, or as performing well in 9 of the 17 categories (i.e. over 50%). It performs poorly in relation to 7 categories (SSSI, Ancient Woodland, Local Wildlife Site, Primary School, Listed Building, Green Belt and Agricultural Land) and only 'particularly poorly' in respect of 1 category (access to a Secondary School). The site performs as well as many other sites, including a number which have been identified in the Preferred Site Allocations document for Development. The Appraisal, as set out in the Draft Sustainability Appraisal, indicates that the site should move forward for detailed Stage 4 assessment. Stage 4 - Detailed Assessment The main criteria used in this stage of the assessment are described at paragraph 3.22 of the SSMSO:WD document. In this respect:- Flood Risk. The site lies within Flood Zone 1 and is not at risk of flooding. Green Belt. The site currently lies within the Green Belt and, therefore, it's development will lead to a loss of openness. However, the site is visually contained by existing development and landscape features and, therefore, the impact on the Green Belt outside of the site, itself, will be limited and can be mitigated through boundary landscaping. The Green Belt Study Working Draft (GBSWD) document includes the subject site within Parcel 41A. It assesses the contribution that each Parcel makes to the first four purposes of Green Belt which are:- 1. To check the unrestricted sprawl of large built up areas; 2. To prevent neighbouring towns merging into one another; 3. To assist in safeguarding the countryside from encroachment; and 4. To preserve the setting and special character of historic towns. In order to assess the contribution that each Parcel makes to Purpose 1, the GBSWD considers the 'containment' of the Parcel in terms of how well the land, or the features within it, contain existing settled areas and prevented urban sprawl. The Parcels are then put into three categories - 'Well-Contained', 'PartlyContained' and 'Not Contained' - with Parcel 41A falling within the middle, 'Partly-Contained', category. In terms of Purpose 2, the Parcels are put into four categories - 'Critical Countryside Gap', 'Import Countryside Gap', 'Minor Countryside Gap' and 'Non Critical Countryside Gap'. Parcel 41A falls in the highest category - 'Critical Country Gap'. Two categories were used in respect of Purpose 3 - these being 'Mixed Functions within Countryside' and 'Functional Countryside'. All Green Belt land to the north of A12, in the Borough, is defined as falling into the latter category. Finally, and in respect of Purpose 4, three categories were used - 'Limited Relationship with Historic Town', 'Moderate Relationship with Historic Town' and 'Strong Relationship with Historic Town'. Parcel 41A has a 'Limited Relationship with Historic Town'. Overall, Parcel 41A is deemed to make a moderate / high contribution to the first four Purposes of the Green Belt. This ranking is primarily due to the fact that the Parcel includes all that land between Doddinghurst and Kelvedon Hatch and thus helps to separate the two settlements (Purpose No. 2). The Green Belt Study Working Draft is, due to its very nature, a high level analysis dealing with large parcels of land and cannot take full account of the fact that, within each parcel, the contribution made by individual sites will vary. The main Purpose which the subject site serves is to restrict the extension of Doddinghurst to the east (Purpose 1). Whilst Parcel 41A (of which it forms a part) does maintain the gap between Doddinghurst and Kelvedon Hatch (Purpose 2), the loss of the subject site to the Green Belt, would not significantly harm that function. This is because the site forms a natural extension to Doddinghurst and is well-contained. Boundaries of the Green Belt in this location are ill-defined on the ground and there is large farmstead to the west. The site is well-contained, its development would create a logical, and defensible, boundary and its loss would not cause any significant diminution of the gap between the two settlements. Landscape: The site is not subject to any landscape designation and, being visually self-contained, it would not have a significant impact upon the character of the open countryside or surrounding area. Highways: The site lies in an accessible location on a major transport artery and bus route through this part of the Borough. Visibility, in both directions, from the access is good. There are pavement links (going east) into Doddinghurst and the speed limit, on this part of the road, is 30mph. Historic Assets: Dill Tree Farm, which lies opposite the site, is a listed building. The site could, however, be developed in a manner which causes no material harm to its setting. The are no registered parks or conservation areas in the vicinity. Ecology Designations: Church Wood, which lies adjacent to the southwest corner of the site, is designated as a County Wildlife Site. The nearest SSSI lies to the north of Kelvedon Hatch (The Coppice). Utilities: There are no known utility constraints in the Doddinghurst area. Education: The subject site has good access to Doddinghurst Church of England Junior School, with Secondary Schools being located in the main urban areas of Brentwood and Shenfield. Health Facilities: The site lies opposite the modern Dill Tree Health Centre. A detailed Site Assessment demonstrates that the site is suitable, available and deliverable for housing and should be allocated in the forthcoming Submission Draft Local Plan. See attached