brentwood.gov.uk

Larger sites often take longer to deliver housing, because they typically have complex ownership structures and require significant investment in infrastructure. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that for sites of over 2,000 dwellings, the average timeframe between the validation date of the planning application and the delivery of the first dwelling was just under seven years. This compares with just under three years for smaller sites of up to 99 dwellings and therefore, whilst it is justified to reduce the housing allocation at the sites in Shenfield and Blackmore, the 70 dwellings should be re-distributed to suitable smaller developments rather than being added to DHGV.
Smaller sites are often able to come forward more quickly than larger sites because they are typically in single ownership and require less investment in infrastructure. They also attract smaller, more local housebuilding companies that would not be present on larger sites, enable more early deliveries and constitute a more sustainable approach towards meeting the housing need.
Brownfield sites should also be prioritised in line with the requirements of the NPPF, which states in paragraph 137 that:
'before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development'.
As a result, brownfield land should be utilised, with greenfield land being released only when all sustainably located, available and deliverable sites have been identified as allocations.
In contrast, Brentwood Borough Council propose relying entirely on the delivery of a single, large, greenfield site to be able to demonstrate and maintain a five-year supply in the early plan period - a method that has been criticised by several inspectors at Local Plan Examinations in Braintree District, Tendring District and Colchester Borough Council in relation to North Essex Garden Communities.
Due to the location of the Dunton Hills Garden Village allocation, a significant proportion of Brentwood's housing would be located on the Borough boundary with Basildon. The settlement would adjoin Basildon's Green Belt and although it was once intended for both Councils to locate settlements in this area, Basildon no longer propose this. It could therefore also be considered that the authorities have not complied with their duty to co-operate.
In conclusion, we object to the re-distribution of 70 dwellings into the Dunton Hills Garden Village allocation, considering instead that the dwellings should be re-allocated to more suitable smaller sites and brownfield land. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged, particularly when suitable alternative sites are available.

These representations are submitted in response to the publication of:
Brentwood Borough Council Local Plan Consultation on Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)
We object to the following change to the Pre-Submission Local Plan:
* Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,770 homes in the plan period".
We support the following changes to the Pre-Submission Local Plan:
* Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes".
* Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes".
* Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes".
* Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
We support the reduction in housing numbers at the allocation sites in Shenfield and Blackmore, as this is justified by the evidence base.
However, we object to the re-distribution of the 70 dwellings to the Dunton Hills Garden Village (DHGV) allocation, because it would mean that fewer homes would be delivered in the early years of the plan. The reliance on DHGV to deliver such a large proportion of the Borough's housing need within the early years of the plan is too great, particularly when smaller sites are available, some of which are brownfield.
Larger sites often take longer to deliver housing, because they typically have complex ownership structures and require significant investment in infrastructure. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that for sites of over 2,000 dwellings, the average timeframe between the validation date of the planning application and the delivery of the first dwelling was just under seven years. This compares with just under three years for smaller sites of up to 99 dwellings and therefore, whilst it is justified to reduce the housing allocation at the sites in Shenfield and Blackmore, the 70 dwellings should be re-distributed to suitable smaller developments rather than being added to DHGV.
Smaller sites are often able to come forward more quickly than larger sites because they are typically in single ownership and require less investment in infrastructure. They also attract smaller, more local housebuilding companies that would not be present on larger sites, enable more early deliveries and constitute a more sustainable approach towards meeting the housing need.
Brownfield sites should also be prioritised in line with the requirements of the NPPF, which states in paragraph 137 that:
'before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development'.
As a result, brownfield land should be utilised, with greenfield land being released only when all sustainably located, available and deliverable sites have been identified as allocations.
In contrast, Brentwood Borough Council propose relying entirely on the delivery of a single, large, greenfield site to be able to demonstrate and maintain a five-year supply in the early plan period - a method that has been criticised by several inspectors at Local Plan Examinations in Braintree District, Tendring District and Colchester Borough Council in relation to North Essex Garden Communities.
Due to the location of the Dunton Hills Garden Village allocation, a significant proportion of Brentwood's housing would be located on the Borough boundary with Basildon. The settlement would adjoin Basildon's Green Belt and although it was once intended for both Councils to locate settlements in this area, Basildon no longer propose this. It could therefore also be considered that the authorities have not complied with their duty to co-operate.
In conclusion, we object to the re-distribution of 70 dwellings into the Dunton Hills Garden Village allocation, considering instead that the dwellings should be re-allocated to more suitable smaller sites and brownfield land. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged, particularly when suitable alternative sites are available.