brentwood.gov.uk

Policy R19 covers two entirely separate sites. As the landowner of the Westernmost site (HELAA ref 178) I stand by my previous representations submitted in earlier stages of the local Plan development and these should be available to view unedited on the Brentwood Borough Council website and considered in full by the Planning Inspectorate.
Regarding Policy R19, the Council have already reduced the number of homes from 130 to 75 and now (under Focussed Change 3) they are proposing to reduce the numbers further to 45. This Change has arisen solely because of concerns from the public.
I do not believe that this policy has been positively prepared in a "Sound" manner as required by the National Planning Policy Framework. There is no evidence that this reduction in numbers on site R19 has any technical basis as the land is capable of accommodating far more homes (130 originally proposed by the planners) and the alternative proposed by this Focussed Change is to move most of the development down to Dunton in the Green Belt. This cannot be considered as sustainable development.
Most people want to live in easy reach of a town centre, and the most appropriate location is the available urban site at R19. Moving homes to the edge of the Borough where there are currently few schools, shops, health facilities and transport links is only going to add to congested roads and pollution. This is not sustainable.
The Aecom Sustainability Report analysed the effects of the changes with respect to site R19 and the conclusion was that these were nearly all negative. The changes cannot therefore be Justified, based on the expert evidence, and the alternative of keeping the numbers at 75 offer a better alternative.
Aecom have also expressed concerns that reducing the numbers of houses at R19 to 45 could adversely affect the viability of the development. At the same time, they explained that loading more houses on the Dunton Hills Garden Village is a risky strategy as there are many planning and infrastructure issues still to resolve. The targets for housing delivery may well be missed, whereas the small development on site 178 will be built out in a much shorter time period.
Finally, reducing the number of houses on site R19 and reducing the density of development is not making best use of a valuable resource. Land in a sustainable urban location with established infrastructure (roads, schools etc) is a valuable commodity and taking the hierarchical approach at the heart of the Local Plan and National Planning Policy Guidance, development should be prioritised here before squandering precious Green Belt that can never be replaced.
In my opinion the Focussed Change at R19 is unsound.