brentwood.gov.uk

1. We are instructed by our clients, Sue Harrison and Matthew Dunn, to submit
representations to the Brentwood draft Local Plan, preferred site allocations,
January 2018 in respect of land at Sandpit Lane, Pilgrims Hatch, Brentwood.
2. Our position is that the Plan is currently unsound but would be made sound by
the deletion of the representation site from the Green Belt and associated
allocation for residential development.
3. We introduce the site, housing context and conclude with the justification for this
allocation as sought.
4. The site is outlined in red on the screenshot below, plus we also enclose an OS
base: (see attached)
5. The site lies to the west of Sandpit Lane, just to the south of Danbury Close, a
small cul-de-sac of bungalows which we assume were purpose-built for specialist
housing for the elderly. This road concludes with a turning head alongside the
representation site, albeit there is no connectivity.
6. Traffic calming measures are installed on the main road in the form of a
constricted carriageway, just to the south of this cul-de-sac with priority to
traffic travelling west.
7. The site itself is largely open with mature planting on all sides. There is a
footpath across the site, however this is informal and is not a prescriptive right
of way.
8. The site is in a sustainable location as it is clearly very close to Pilgrims Hatch.
There is a direct route via a public pathway from the representation site to all the shops and services provided by Pilgrims Hatch. The Blue Crown public house
is a very short walk along the pathway on the eastern side of Sandpit Lane.
Moreover Pilgrims Hatch provides easy access to the town centre via an
established network of public transport infrastructure.
9. We have already confirmed that the site open and access is deliverable without
reliance upon third-party land and we enclose a screenshot of an initial access
arrangement prepared by Highway Consultants below: (see attached)
10. We are therefore dealing with a site which is deliverable, well screened and in a
sustainable location.
11. In respect of the housing context the local planning authority has not been able
to deliver a 5-year housing land supply (5HLS) for a prolonged period of time:
this is also its current position.
12. The emerging Local Plan fairly presents a recognition that there has been a step
change in the development needs of the Country as a whole and that the need
of Brentwood as a Borough are now significantly different from when the Local
Plan was adopted in 2005.
13. There is equally a recognition that Brentwood is a "borough of villages" and that
this character should be retained.
14. The Local Plan sets the context of the importance of transport corridors to
include the A12 as well as the Ongar Road.
15. The current consultation document Local Plan also sets out the housing position
and the obligation upon the Borough to provide a significant number of new
homes over the Plan period. Taking into account a series of factors to include
anticipated demographic changes there is now a housing figure of 380 dwellings
per annum which equates to 7,600 across the Plan period which runs from 2013
to 2033.
16. Paragraph 43 of the emerging Plan reads as follows:
For the purposes of plan-making and allocations it is considered prudent at this stage to plan for housing numbers slightly above the 380 dwellings per annum figure to create some degree of flexibility and contingency should some housing sites fail to come forward as expected.
17. Paragraph 44 notes that this is a challenging figure for the borough as 380
dwellings per annum compares to an earlier figure of 132 dwellings per annum and this readily illustrates the stepped change in the obligation from providing
new housing.
18. The Plan recognises this means that there is almost a tripling in the annual
delivery rate of new homes.
19. The Plan publishes 31 housing-led allocations across a variety of sites and within
the urban area, some of which are small sites which would yield between 5 and
50 units.
20. Part 2 of the Plan then deals with the preferred site allocations.
21. We note in respect of the immediate context to our representation site "A12
corridor-urban extension site" 010 is allocated in the drfat plan for residential
purposes; namely the Sow and Grow garden centre along Ongar Road, Pilgrims
Hatch which is seen as a brownfield development opportunity to provide an
indicative figure of 38 units.
22. We logically refer to this is as it is in very close proximity to our representation
site and indeed the screenshot below taken from page 73 of the emerging Plan
shows our site just to the west of blue allocation 010, with the words "Sandpit
Lane" just about legible. (see attached)
23. There are a number of important factors which underlie the case of our
representation site. The first is that the step change in the need for housing is
significant. The context is that the local planning authority has not had and does
not currently have, at the time of writing, a 5HLS.
24. The Local Plan should be robust and sound and there should be no room for
failing to provide housing to meet needs.
25. If the local planning authority is not able to provide a robust 5 HLS then
applicants can invoke paragraph 14 of the Framework which takes a level of
control away from the local planning authority, and the local planning authority
has suffered the consequences of this in recent years.
26. The National Planning Policy Framework is clear as to these points and
paragraph 159 states that local planning authorities should meet household and
population projections.
27. Within this context, the land off Sandpit Lane will contribute towards housing
figures and ensure that the Plan is sound.
28. The local planning authority is inevitably reliant upon a multiplicity of sites and it
is impossible at this stage to conclude that all are deliverable and that they will
meet the anticipated capacity within the Plan period. A further contingency will
underlie the robust nature of the emerging Plan. There will inevitably (as is the
case with all Local Plan processes) be evidence presented in due course that a
number of these sites will not come forward or in the capacity envisaged.
29. We note that there are a number of allocations in respect of existing car parking
land and there may be real issues in terms of bringing these sites forward.
30. With regard to the description of the current representation site at Sandpit Lane
it is clearly sustainable being an easy walk to shops and services which they will
play a role in sustaining.
31. There is a clear and sufficient footpath link from the site to the services.
32. This link also takes residents to Ongar Road where they can pick up a bus into
town.
33. This site is also deliverable. It is largely open with the exception of mature
vegetation on the periphery which will be retained in the context of any
residential scheme. The access has already been investigated and we refer to
the screenshot embedded earlier from an initial design to show that the site is
deliverable within reliance upon any third-party land.
34. The site is already well screened. It is a logical and sensible addition to the
urban area of Pilgrims Hatch and consistent with the general pattern of
development in the local area to include that on the western site of Ongar Road.
35. For these reasons the application will contribute towards the soundness and
robustness of the Plan and assist the local planning authority in meeting the step
change in housing delivery which, quite alarmingly, equates to a tripling of
current provision.
36. We therefore seek the allocation of the site for residential purposes on this basis.