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The Council should consider through the Examination process additional allocation(s) within the Central Brentwood area in order to maintain its supply buffer and reduce the uncertainty and risks associated with the current Plan in relation to failing to meet housing need in areas where the need is derived. In this regard, HLM would also encourage the Council again to consider the evidence submitted as to the benefits of allocating or safeguarding Land west of Ongar Road for residential development.

Focussed Change 1 increases the minimum number of dwellings to be delivered at Dunton Hills Garden Village by 2032/33 by 70 dwellings to 2,770 dwellings. Whilst the change is a relatively small increase, given the absence of evidence to support the rate of delivery proposed, an objection is maintained.
It is noted from the Sustainability Appraisal Addendum (paragraph 2.9.3) that it concluded there is a degree of increased risk associated with reliance on this site, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery. Although it also noted discussions between the Council and site promoter indicated this was deliverable, it maintained there was an uncertain negative implication for the achievement of the Housing objectives.
Therefore, given the concerns shared with the authors of the Sustainability Appraisal, and in the absence of any evidence to demonstrate the amended number of dwellings is capable of being delivered within the Plan period, an objection is made to the focussed change on the grounds of soundness that it is not justified, as required by the Framework.
Appendix 1: Schedule of Focussed Changes
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that it does not demonstrate a five year supply on adoption of the Plan.
Focussed Change 13 within the Schedule amends the Local Development Plan Housing Trajectory and reduces the five year supply of deliverable housing by 70 dwellings. This is on the basis of the Plan being adopted in 2020, and the five year supply being calculated for Years 5 to 9 of the trajectory. Whilst the change is a relatively small reduction in supply, it still further reduces supply and an objection is maintained on the grounds of soundness in that it is not consistent with national policy in failing to identify a five year supply of specific deliverable sites against the housing requirement.
Sustainability Appraisal Addendum
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that the Spatial Strategy is reliant upon the delivery of a significant level of growth away from where the vast majority of housing and employment needs of the Borough are derived (Central Brentwood Growth Corridor). The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraph 2.9.4) that this concern is now acknowledged.
HLM also submitted an objection to the Pre-Submission Local Plan on the grounds that the housing provision within Policy SP02 does not reflect the minimum number of homes needed. The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraphs 2.9.3 and 2.9.5) that it is acknowledged the minimum number of homes needed (Local Housing Need) now equates to 454 dwellings per annum, which as a consequence means the Plan no longer makes any provision for a housing supply buffer. The Addendum therefore notes that the absence of a buffer, and the greater reliance upon one site (Dunton Hills Garden Village) to meet the housing need in a location some distance from where the need is largely derived (Central Brentwood) places a greater degree of uncertainty and risk that the Housing objectives will not be met.
As housing affordability is acknowledged as a significant concern for the Borough, HLM would respectfully request the Council consider through the Examination process additional allocation(s) within the Central Brentwood area in order to maintain its supply buffer and reduce the uncertainty and risks associated with the current Plan in relation to failing to meet housing need in areas where the need is derived. In this regard, HLM would also encourage the Council again to consider the evidence submitted as to the benefits of allocating or safeguarding Land west of Ongar Road for residential development.