brentwood.gov.uk

Minor amendment to Green Belt boundary to include this area

Covering letter: RE: LAND FORMING PART OF THE SOW N GROW NURSERY SITE R07 AT 346, ONGAR
ROAD, PILGRIMS HATCH, BRENTWOOD.
BRENTWOOD DISTRICT LOCAL PLAN SUBMISSION DOCUMENT.
CONSULTATION RESPONSE FOR MRS HEATHER DUNBAR.

I am instructed as Agent, by Mrs Heather Dunbar, (and separately by the Armiger family), as the owners of nearly all the land comprising the Sow N Grow Nursery Allocated Site and Bungalow and dwelling, and part of 346, Ongar Road, as defined in Policy R07, and as shown on the plan on page 324 to respond on their behalf to the Local Plan Regulation 19 Consultation.
Please find enclosed a completed Response Form on behalf of Mrs Dunbar together with a supporting Statement of Response to be read together with this covering letter.
The Statement sets out the background to the inclusion of the site in the Submission Local Plan, and includes reference to pre-application advice taken with regard to the land owned by the Armiger family, their purchase of further freehold land under the former telecoms mast operated by O2, and formerly owned by Pinnacle Towers, to complete their assembly of their site.
There is also a reference to the potential development of the land they own within the Allocated Site (R07) by way of a scheme showing 42 dwellings as previously submitted to and commented upon by the Local Planning Authority in the pre-application advice process. (See Appendix 2 to the Response Statement submitted with this letter).
The Response Statements submitted confirm that the whole of the land south of the trackway to the allotments is owned by Armiger family members. It is considered to be previously developed land. Itis currently within the defined green belt. There are exceptional circumstances for a boundary change. There are short term tenants occupying the commercial buildings and the dwellings in their ownership are occupied by the Armiger family or by residential short term tenants. The Armiger owned part of the site is therefore readily capable of being made available for development for residential use within the first five years of the development plan period.
Likewise it is confirmed that Mrs Dunbar is willing to bring that part of the site defined in the Plan and
on page 324 for development in the early part of the Plan period within her ownership, separately,
and it is likely that this area could accommodate up to five dwellings with a private access driveway.
As this is a smaller site with potential for build out by smaller local builders in the early part of the Plan period, this Allocated Site will provide housing delivery in the early part of the Housing Trajectory
pending larger site allocations coming forward in due course, but where infrastructure investments
are required. See part of Policy SP02A which states:
"Provision is made for 7,752 new residential dwellings (net) to be built in the borough over the Plan period 2016-2033 at an annual average rate of 310 dwellings per year to 2022/23, followed by 584 dwellings per year from 2023/24-2033".
The Response Statement further confirms the Armiger family land is part of the Allocated Site and lies to the south of, and limited by, a trackway running approximately east/west, giving allotment holders access to the back-land allotments. This trackway is not in the ownership of the Armiger Family, nor is it in the ownership of Mrs Heath Dunbar the owner of the land north of the trackway. The site ownership plans in Appendix 1 to the submitted Statement confirm. The land allocated in the Sow N Grow Site owned by Mrs Dunbar comprises part of the garden to Rose Cottage, 346 Ongar Road, Pilgrims Hatch. The Statement to the Response confirms this and a title plan is submitted to confirm the extent of ownership. The Local Planning Authority has taken some considerable time to prepare and produce this Submission Copy Plan, and following the change in National Planning Practice Guidance by Sir Eric Pickles, pre-application advice matters have been left in abeyance by the Armiger Family for some years. The land owned by Mrs Dunbar has not been included in the pre-application advice application and can be seen to be separated from it by the trackway.
Nevertheless it is previously developed land as defined in the National Planning Policy Framework Glossary (Annex 2), and it is in this highly sustainable location adjoining an urban neighbourhood and can provide dwellings for the same sound reasons that the larger site shown in the Plan on page 324 was selected and allocated. It too can be brought forward by a willing owner. This is an important and material consideration for the site and the Plan so it can be adopted to deliver housing in the Brentwood area as early as possible and the allocation of this site can achieve this.
The Statement for Mrs Dunbar sets out why the Local Plan is considered to fully meet the requirements and criteria for the adoption of a Local Plan for the Examination in Public. The Statement also refers to case law for Local Plans, particularly with regard to green belt boundaries. Plans do not have to be ideal or perfect in all respects. Some minor suggestions are submitted for the Examiner's discretion.
The earliest adoption of the Plan and the whole of the Allocated Site is supported and would be welcomed. It is supported by all the Armiger family and also by Mrs Dunbar, as the Sow N Grow Site R07 without amendment. The Plan is considered to be the result of up to date pro-active plan making, based upon firm evidence and analysis, accords with the National Planning Policy Framework (and the Housing Delivery Test) and legally compliant. It is therefore sound.
Furthermore the Local Plan is considered to now have a comprehensive evidence base to fully and properly review all available brownfield/ previously developed land for future development, both within, and without the defined settlement boundaries of the District and in the Green Belt. The inclusion of the Sow N Grow Nursery and land adjoining as shown in the Plan on page 324 is a clear example of these matters being achieved, with a readily developable and sustainable site being allocated in response to the Call for Sites, the Brownfield Register and the Consultations. It is understood that at the Council Meeting in November 2018 the Councillor objecting to the inclusion of the Allocated Site withdrew objections.
The Plan is therefore supported for the earliest adoption and it is trusted that this Letter, the Response Form, and Supporting Statement submitted for Mrs Dunbar are brought to the Examiner's attention. Mrs Dunbar would like to attend the Examination in Public in due course. I should be pleased to discuss matters arising from this Letter, Response Form, and Statement, with the Local Planning Authority should it wish to do so.
Yours sincerely
Alan Wipperman BA MRICS MRTPI C Dip AF Copy: Mrs Heather Dunbar

Submission includes a response form, covering letter and a formal statement. (attached).

I consider that the Local Plan is both sound and legally compliant, having regard to the delivery of assessed housing need in accordance with the Housing Delivery Test as set out in the National Planning Policy Framework 2018, and in the Local Plan, over the Plan period. As also set out in the submitted Statement and the Cover Letter. It is important that the Local Plan delivers the housing needed over the Plan period in a sustainable manner by the selection of appropriate sites for development well served by public transport, whether by way of large such as at Dunton Hill, but also and just as importantly, by way of smaller sites, especially within and next to urban neighbourhoods, and comprising previously developed land. Pilgrims Hatch has been appropriately defined as such a neighbourhood in the Settlement Hierarchy. This is supported. Where there is previously developed land, this should be allocated for development as a priority, even if within the green belt; especially where located next to urban neighbourhoods where local services and public transport are available. The Sow N Grow site is just such a site and accordingly, the green belt boundaries can be amended accordingly, reflecting the exceptional circumstances prevailing. The approach is sound and effective, and this is also supported. I therefore strongly support the Plan, the allocation of this site, and Policy R07.