brentwood.gov.uk

Thank you for providing us with the opportunity to engage in the consultation on the Council's Pre-submission Publication Draft Local Plan (Regulation 19). We write on behalf of our clients, Messers A, J and C Courage, who own the freehold of the Eagle and Child Public House, Shenfield. The site is subject to a planning application submitted in February 2019 and we fully support the proposed allocation of the site for residential development.
As a general comment, we note that the National Planning Policy Framework (NPPF) requires all Local Plans to apply the presumption in favour of sustainable development (para 11). It states that local planning authorities should positively seek opportunities to meet the development needs of their area and Local Plans should meet objectively assessed needs with sufficient flexibility to adapt to rapid change. They should be consistent with the principles and policies of the NPPF and should be aspirational but realistic. Plans should be deliverable and the scale of development identified in the plan should not be subject to such obligations and policy burdens that their ability to be developed viability is threatened.
Paragraph 35 of the NPPF requires Local Plans to be sound and in order to meet this requirement they should be:
Positively Prepared - be based on objectively assessed development requirements, consistent with achieving sustainable development.
Justified - be the most appropriate strategy based on proportionate evidence.
Effective - be deliverable over its period and based on effective joint working.
Consistent with National Policy - enable the delivery of sustainable development in accordance with
the policies of the NPPF.
As a general comment, we support the consultation exercise that is being held and the allocations of this site in order to meet the employment needs of the Borough.
The Site
The site is in Shenfield, on the southern side of Chelmsford Road, between Hutton Road and Shorter Avenue and opposite Shenfield Park. The site extends to approximately 0.24 hectares and is broadly L-shaped. The public house is located in the western part of the site, with an extensive garden to the rear, and the eastern part of the site comprises hardstanding used for car parking. The existing building dates from the 1930's but has a 1950's extension and rises to two storeys in height. The existing building is not statutorily or locally listed, nor is it located within a conservation area. The public house is currently leased with a break available in 2019, making it available for development.
The site is located within a predominantly residential context. Directly to the north of the site is a row of residential dwellings with the playing fields and Shenfield Cricket Club beyond. Adjacent to the site at the eastern boundary is Sawyers Court; a retirement housing development rising to 2.5 storeys. To the south of the site is Ardleigh Court which comprises a series of residential apartment buildings between two and three storeys. The west of the site is bound by residential properties fronting Chelmsford Road (Nos. 7, 9, 11 and 11a) and Hutton Road (No. 20 and Nos. 1-4 Gabriel Mews).
The site is located within Flood Zone 1, which indicates that the site has a low probability of flooding. There are a number of trees on the site, predominantly located to the rear of the existing building, none of which are subject to Tree Preservation Orders. The site is located approximately 350m northwest of a number of high street facilities located on Hutton Road, including convenience stores, banks, post office, restaurants and takeaways, cafes and bars, pharmacy and hair and beauty salons. There are a number of educational facilities in the area surrounding the site, including Shenfield Day Nursery (approx. 100 metres southwest), St Mary's Primary School (approx. 230 metres west) and Shenfield High School (approx. 1km northeast). With regards to healthcare facilities, Rockleigh Court Doctor's surgery is located approximately 320 metres southeast of the site.
The site is located approximately 550 metres from Shenfield National Rail Station, which is located to the south east of the site on Hutton Road and provides TFL Rail and Greater Anglia services towards London Liverpool Street as well as Greater Anglia services to a number of destinations within Essex and East Anglia including Southend Victoria, Clacton on Sea, Colchester Town, Braintree and Ipswich. In addition, from December 2018 Shenfield will provide Crossrail / Elizabeth Line services to central London. The site is located approximately 2.5km (3 minute drive) from the nearest intersection with the A12 which provides links to central London as well as to Essex and East Anglia.
Background
We have previously submitted representations on behalf of the landowners to earlier consultation versions of the emerging Brentwood Local Development Plan; including the Draft Local Plan Preferred Site Allocations. We have also recently submitted a planning application for the redevelopment of the site to provide 15 residential dwellings (LPA. 19/00268/FUL).
Comments on the Pre-Submission Publication Draft Local Plan
The Pre Submission Draft Local Plan seeks to provide 7,752 residential dwellings during the plan period (2016- 2033). These dwellings will be delivered at an average rate of 310 dwellings per year to 2022/23, followed by 548 dwellings per year from 2023/24-2033. Draft Policy SP02 'Managing Growth' states that new development within the borough will be directed towards the proposed site allocations.
Site Allocation
The Pre-Submission Draft Local Plan seeks to allocate the site for residential development (Policy R18). The emerging allocation seeks the delivery of 20 dwellings on the site within the first five years of the Plan. We welcome the additional consultation and site allocation and in particular we would like to take this opportunity to express our strong support for the proposed allocation of the site for residential development.
Sustainability
The site is located within the development boundary of Shenfield and comprises previously developed land. At the national level, a key principle of the NPPF is the re-use of previously developed, or brownfield land. This principle has informed the Council's emerging spatial strategy, which seeks to develop land sequentially with brownfield land and sites within settlement boundaries being prioritised for development. The proposed allocation of the site for redevelopment is therefore wholly in accordance with national and local policy objectives.
The Council cannot currently demonstrate a five year housing land supply but, in order to meet the objectively assessed need for housing, proposes to significantly increase its housing delivery target within the emerging Local Plan. The redevelopment of brownfield sites will be key to meeting these needs and is expected to deliver up to 74% of the total delivery across the Plan period. The site at the Eagle and Child Public House is a preferable site and necessary in order to ensure the Council meets its objectively assessed housing need. In addition, the intention for the site to be delivered within the first five years of the Plan will help the Council to demonstrate a five year supply of land for housing. The NPPF at paragraph 11 outlines an underlying presumption in favour of sustainable development through both plan-making and decision-taking. This is reflected within the emerging Local Plan which seeks to focus new development on sites which are accessible to public transport.
The site is located in an accessible location with good public transport links to London and other locations within Essex and East Anglia, as well as good connections with the local highway network. In addition, the site is well supported by community facilities such as schools and healthcare providers, as well as local retail provision. Furthermore the site is not within an area at risk of flooding, and as set out above, comprises a brownfield, previously developed location. Therefore the site is considered to be a sustainable location for development and its allocation is supported by national policy and the Council's emerging strategies. It is considered that the draft site allocation will promote sustainable development, and is therefore in accordance with draft Policy SP01 'Sustainable Development'.
Deliverability
Our client owns the freehold to the site and there is a break in the existing lease in 2019 which would make the site available for redevelopment. The site is therefore considered to be deliverable for residential development within the next five years, in line with the Council's intentions as set out in the draft allocation. The site has no overriding constraints which will mean the site cannot be delivered. In respect of the allocation it is proposed to be allocation for around 20 new homes. Whilst the current planning application is for 15 dwellings it is considered appropriate to allocate the site for around 20 new homes to provide flexibility as to what is delivered on the site.
Summary
We consider that the emerging Local Plan is being prepared in line with the requirements of the NPPF in order to meet local needs. The Publication Draft Local Plan been prepared as part of a comprehensive plan-making process including the consideration and testing of a number of growth options and alternatives. The Plan has been positively prepared with significant involvement from local residents and stakeholders including consultation on the Strategic Growth Options in 2015, the Draft Local Plan in 2016, Call for Sites in 2017, and the Preferred Site Allocations in 2018. Given the advanced stage of the local plan process, the proposed site allocations, including that of our client's site, have therefore been well informed and are considered to be robust.
Overall the site is considered to be a sustainable location for development, in the first instance because it comprises previously developed land within an established settlement boundary, but also because it is located in an accessible location. In addition, the site is considered to be available for development and new residential dwellings can be delivered within the first five years of the new Local Plan. Its allocation for the delivery of 20 new residential dwellings is considered wholly appropriate and is strongly supported.
Conclusion
We trust that the above is of assistance in the preparation of the new Local Plan for Brentwood. We would like to be kept up to date with the progress of the Local Plan and look forward to future opportunities to engage and we reserve our right to appear at the Examination in Public.
We look forward to confirmation of receipt of these representations. Yours sincerely
Catherine Williams
Associate Director