brentwood.gov.uk

Reinstate the dwelling number to 40 for site R26.

Brentwood Local Plan: Addendum of Focused changes to the Pre-Submission Local Plan (Regulation 19)
Focused change 5: Land North of Orchard Piece, Blackmore (Policy R26)
Submitted by C. Blythe
1. I object to the Addendum of Focused changes to the Pre-submission Local Plan (Regulation 19) in respect to the "Focused change 5 Policy R26: Land North of Orchard Piece, Blackmore" which seeks to further reduce the sites allocation of dwellings from 30 to 20. The site's original allocation of approximately 40 dwellings continues to be supported by technical evidence and all statutory consultees. I believe this should be reinstated to address the shortage of housing stock within Brentwood Borough.
2. To recap my previous representations, I support the Preferred Options Local Plan (2018) (Reg18) which was the outcome of a ten-year process that was positively framed, technically researched, and involved local residents in exhaustive consultations (which I have participated in since 2011). I support the Preferred Options Local Plan's sequential land-use approach, in particular in relation to Policy R26 which supports Policy NE9 8.88 (p228) and Policy NE13: 8.115 (p238). In particular Policy R26 supports item 2.8 (p21) and would serve to help satisfy SP01: SP02: HP01 (for specific details please refer to my representation of 19 March 2019).
3. However, I do not agree with the Pre Submission Local Plans reduction of units from 40 to 30 or subsequent focused change of Policy R26 that the allocation be reduced from 30 to 20. As identified throughout the process there is an acute need at a local level for both private and affordable housing. There is no technical justification for this change. According to Policy HP03 "Residential development proposals will generally be expected to achieve a net density of at least 35 dwellings per hectare net or higher." Accordingly the net area of this site (1.52 hectares) this would equate to around 53 units. Therefore, given the need to provide sufficient housing supply for the coming 15 years an allocation of approximately 40 units should be reinstated. The initial allocation would preserve and enhance the character of Blackmore, as it would be entrusted to a builder with a demonstrated capacity for delivering housing of a very high standard.
4. Under policy R26 new housing will give priority to those with "demonstrable local connection and those over 50". As there is currently insufficient housing stock for downsizing in Blackmore and the local area, the number of dwellings should not be reduced.
5. With regard to concerns about surface water flood risk relating to the Site (Policy R26), this does not correspond with my knowledge of the site. However in order to be fully informed, Ardent Consulting Engineers have conducted a detailed technical analysis relating to flooding and drainage on the Site. It has been demonstrated that the Site is not in an area vulnerable to groundwater or fluvial flooding. Even so, Crest Nicholson Eastern, the builder who would deliver housing on this Site has taken note of the concerns of local residents in its proposed design for the Site. The Sustainable Drainage System that would be put in place will provide a betterment to the existing situation by managing/controlling the flow of surface water discharge rates into the surrounding network. No technical objection from either Essex County Council or the Environment Agency has been raised in regard to an allocation of 40 dwellings. Aecom's SA (October 2019) concludes that the Focused Changes have positive implications in respect of 'Community' reflecting that the changes have been developed in response to concerns raised by residents. The Local Plans (Reg 19) evidence base therefore confirms the reason for reducing the quantum of development is purely political and contrary to technical evidence and advice of statutory consultees that concludes an allocation of 40 dwellings is suitable for the site.
6. The updated evidence base provides no planning or technical justification for the reduction in unit numbers. In respect of "Focused change 5 Policy R26: Land North of Orchard Piece, Blackmore" I would like to request that the wording of the site allocation be amended to reinstate the allocation of approximately 40 dwellings on this site to ease the housing shortfall and to ensure the Local Plan remains sound. This change would be in accordance with the technical evidence and advice from statutory consultees.
7. Please include both this representation and my previous one of 19 March 2019 as part of the documentation to be submitted for independent examination. I would like to be kept informed of the process, thank you.