brentwood.gov.uk

The reasonable strategy would be to remain at 75 houses for site R19.

Brentwood Borough Council have proposed a number of focussed changes to the Pre-Submission Local Plan.
My representations relate primarily to Focussed Change 3 [Policy R19 (Land at Priest's Lane, Shenfield): Reduction from "around 75" to "around 45" homes] and the effect on the proposed Dunton Hills Garden Village (DHGV).
My representations consider whether the Change meets the Test of Soundness as set out in paragraph 35 of the National Planning Policy Framework.
Policy R19 covers an area of urban open space in Shenfield. This comprises two independent sites, the 4.5 Ha Ursuline School Playing fields (HELAA ref 044) and my 0.6 Ha Land off Bishop Walk (HELAA ref 178). Although these two sites have different use histories and planning attributes (site 178 is a disused private stables and paddock), the Council have set policy R19 to cover both together (please refer to my previous representations objecting to this approach).
The reason for the change to Policy R19 is purely due to representations from local residents concerning development on R19 and another nearby site. The Addendum document paragraph 1.3 explains that the key concerns included:
"inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitat impacts; and flooding."
The relevance of these concerns when considering site 178 in isolation have already been disputed.
However, in response to the representations, the Focussed Changes seek to remove 50 houses from the locality (30 of which from R19) and re-allocate them to the proposed DHGV development. This is despite the negative impacts identified by Aecom in their October 2019 Sustainability Appraisal.
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Aecom's Sustainability Appraisal (SA) of the Brentwood Local Plan, with Addendum, dated October 2019:
Aecom have appraised the Focussed Changes with respect to twelve sustainability topics. It is important to highlight their findings as they relate to R19, and more particularly site ref 178.
Air quality: Site R19 is in close proximity to the town centre Air Quality Management Area (AQMA). The proposed reduction in housing numbers in the locality is 50 (30 reduction from R19). Aecom say that any reduction in pollution from omitting 50 houses would be "marginal", and so the opposite must also be true, that retaining 50 houses would also be "marginal".
Consequently the effect of adding or omitting just 30 houses on R19 will be less than "marginal" and for the smaller number of houses proposed on site 178 alone there would be virtually no effect at all.
Furthermore, Aecom also point out that as R19 is close to the town centre and schools (1km to the town centre and 2km to Brentwood Station), there will be a high incidence of walking, cycling and use of public transport, which will reduce the number of private car journeys. This is all to be encouraged for sustainability. Cars also have an alternative route to avoid the AQMA, and so the impact is reduced still further.
More significant is the adverse effect of reallocating the houses to DHGV and in paragraph 2.2.10 of the Aecom Addendum a red warning flag is raised: " ...in the light of the new evidence available which serves to highlight an air quality issue associated with the A127 corridor that might be said to be of national significance (on the basis that National Government is seeking to intervene). In the light of this new evidence there is an increased degree of concern associated with DHGV, from an air quality perspective and this is compounded, albeit marginally, by the Focussed Changes."
Overall, Aecom concluded that there are "uncertain negative effects" of reducing the housing numbers and diverting them to DHGV. Consequently, based on the air quality expert evidence, the R19 change is not justified.
Biodiversity: Aecom concluded that the effect of reducing the number of houses in the locality was "not likely to be significant". So given that adding or omitting 50 houses (30 on site R19) is not considered to be significant, the R19 change is not justified.
Climate Change Mitigation: No effect
Community and well-being: Paragraph 2.5.2 states that the primary concerns of local residents were the residential character and road access.
Site 178 already has a road access off Priest's Lane and so residents' concerns relate entirely to the Ursuline's School Playing Fields site 044, which does require a new road access and highways improvements.
Concerning residential character, there is already a conflict between the low density of the older houses in the area and the density ordinarily required by the planners in new developments. For example, Bishop Walk (the road off Priest's Lane from which site 178 is accessed) was built out twenty years ago at 15 dwellings per hectare, yet the current local plan requires double this density. This would not reflect the local character.
Following pressure from local residents, the numbers of houses included in the plan for R19 had already been reduced from 130 to 75, matching the 15 dwellings per hectare in Bishop Walk. Further pressure has now resulted in this focussed change to R19 to cut the numbers to 45 dwellings, which
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is just 9 dwellings per hectare. This density is not consistent with National Policy to maximise the land use, does not represent sustainable development and no longer reflects the density in Bishop Walk.
Aecom have also expressed their concern that cutting the numbers in this way could adversely affect the scheme viability. I agree. The scheme will still require expensive road layouts, suds drainage schemes, services infrastructure, other site costs, management on-costs, fees and CIL etc and these are having to be spread over fewer and fewer houses.
The cut in numbers then conflicts with and jeopardises other policies in R19 looking to increase the supply of smaller units and discounted affordable units as the costs cannot reasonably be borne by the reduced scheme finances. As a solution, there needs to be some flexibility in these policies bearing in mind that the local character along Priest's Lane and Bishop Walk is for large high value houses, which is probably what the local residents are looking to replicate, whilst there is no local character to replicate for land along the Southernmost margins. With cheaper land values along these railway margins, this is logically where any subsidised housing units could be located.
It is noted that Aecom concluded that the Focussed Changes have a positive effect in respect of Community Objectives solely in recognition that the changes were in response to local pressure. Otherwise, the omission [or retention] of 30 units was said to be of "limited significance".
Economy and employment: No effect.
Heritage: No effect
Flooding: Despite concerns from residents about flooding (noted in paragraph 1.3 of the Focussed Changes document), Aecom confirmed site R19 is not subject to fluvial flood risk and the Environment Agency raised no objection to development.
Housing: Aecom were highly critical of the proposed change to shift the balance of housing away from the Brentwood/Shenfield urban area, where housing needs are highest, and instead concentrate housing at a single large site (DHGV), where there was an increased risk in terms of delivery. They also noted that the Local Housing Needs figure had also increased from 350 dwellings per annum on January 2019 to currently 454, effectively matching the proposed housing supply and wiping out the previous buffer of over-supply. Consequently delivery at DHGV is increasingly critical and increasingly risky. The expert assessment from Aecom was that the changes had "uncertain negative implications" and so the R19 change is not justified.
Landscape: Aecom reported that decreasing the number of homes on R19 and moving them to Green Belt land at DHGV only added to the Significant negative effects of developing on the Green Belt at DHGV. Consequently, the R19 change is not justified.
Soils: No effect
Waste: No effect
Water quality and water resources: No effect
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Conclusion
I maintain that the proposed reduction in housing numbers at R19 is not justified as it is not "an appropriate strategy, taking into account the reasonable alternatives and based upon proportionate evidence." [NPPF para 35.b].
The original housing numbers considered reasonable by the planners were three times the 45 houses now proposed in the Focussed Change. This latest reduction from 75 to 45 has once again come about purely as a result of representations from local residents and political pressure. I have written previously explaining that most of the concerns relate to issues on the adjoining site, not site 178, and my representations remain on file for the inspector.
Turning to Aecom's updated Sustainability Appraisal, this provides an expert opinion on the Focussed Changes with respect to R19 and I put this forward as evidence to assess the soundness of the policies, with particular reference to site 178.
The only positive effect of the Focussed Change was with regard to Community objectives, because the Change was a response to local pressure. However this was only described as being of "limited significance".
All other significant effects of the Focussed Change were negative.
 Site 178 does not have an air quality issue. However, moving more houses to DHGV would have "an uncertain negative effect"on air quality at the already problematic A127.
 On Communities and wellbeing, there is a conflict in policies between maximising the density to achieve best value from the land, and the proposed reduction in numbers. As Aecom point out, this is now at a level when the scheme viability is called into question, and other policies in R19 for social housing, for example, are brought into conflict. This all looks like a political decision that has not been properly thought through.
 Aecom were highly critical of moving the housing away from the urban areas where they were most in demand. Also, locating them at DHGV was a risky option in terms of delivery within the plan period. The recent rise in the Housing Needs numbers has also wiped out any contingency within the supply, and so the risk of failing to meet the targets has increased
 Moving houses from R19 to DHGV increased the already significant negative effect on landscape as this involves building on the Green Belt.
Taking account of all the negative indications in Aecom's report, the conclusion is that adopting the Focussed Change at R19 would not be an appropriate strategy and the reasonable strategy would be to remain at 75 houses. The policy is not sound.