Policy 7.4: Housing Land Allocations
Support
Draft Local Plan
Representation ID: 15163
Received: 28/04/2016
Respondent: CEG Land Promotions Limited
Agent: CODE Development Planners Ltd
Supports policy and suggested mix and phasing contained in Appendices 2 and 3.
The allocation of a new garden village on a site largely in a single ownership, requiring no third party land and planned in a comprehensive way through the preparation of a master plan will help to ensure the achievement of an appropriate mix of uses, phasing and early delivery.
See attached
Object
Draft Local Plan
Representation ID: 15208
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Recommend that the site at Sawyers Hall Lane is identified as a Housing Land Allocation in the Local Plan, and that the site is released from the Green Belt.
The site at Sawerys Hall Lane is available, the location is suitable, development is achievable. Recommend that the site is brought forward within the first five years of the plan period.
The site is able to secure the long-term future of Hopefield Animal Sanctuary (and this approach to the proposals has been agreed in principle with the existing occupier).
The proposals are also able to deliver a range of social, economic and environmental benefits to Brentwood and would meet the Council's strategic objectives
See attached
Comment
Draft Local Plan
Representation ID: 15255
Received: 03/05/2016
Respondent: London Borough of Havering
Havering welcomes the decision not to progress with the A12 corridor site which was adjacent to the Havering borough boundary.
See attached
Comment
Draft Local Plan
Representation ID: 15264
Received: 29/04/2016
Respondent: Tesco Stores Limited
Agent: GL Hearn
Recommended that Policy 7.4, and supporting Figure 7.2, is revised to include the site at Sawyers Hall Lane as a Housing Land Allocation.
The sequential approach towards site selection and delivery is supported, however the delivery of identified sources of housing supply is questionable, and it is recommended that the housing target is increased.
In the SA the site at Sawyers Hall Lane achieves the same overall "score" as the three allocated Greenfield Green Belt sites in Brentwood.
See attached
Object
Draft Local Plan
Representation ID: 15307
Received: 04/05/2016
Respondent: Site owner 75 Pear Tree Lane
Agent: Wingfield Planning Consultancy
The proposed draft allocations are heavily reliant upon the Dunton Hills Garden Village, which relies upon acceptance from Basildon Council. Furthermore, the draft plan does not allow for any strategic growth within the north of Brentwood, hence runs the risk of effectively killing off the planned growth of the towns and villages that comprise the north of Brentwood.
Doddinghurst should be allowed to grow in a controlled and sustained manor to help provide much needed market and affordable housing.
See attached.
Object
Draft Local Plan
Representation ID: 15317
Received: 04/05/2016
Respondent: Wiggins Gee Homes Ltd
Agent: David Russell Associates
The other strategic greenfield sites, Officer's Meadow, Shenfield; Honeypot Lane, Brentwood; and Nags Head Lane, Brentwood, are all included in Appendix 3's Housing Trajectory. All are shown as starting delivery in 2018. This is less than two years from now and, in our opinion, it is unlikely that delivery from these sites will start much before end of 2020, beginning of 2021.
See attached.
Object
Draft Local Plan
Representation ID: 15319
Received: 04/05/2016
Respondent: Wiggins Gee Homes Ltd
Agent: David Russell Associates
It is the smaller allocations that are likely to make an early contribution to meeting what is already a significant housing shortfall in Brentwood Borough. The last Five Year Deliverable Housing Supply Assessment, published in June 2014, recorded a 4.3 year supply, well below the level required by the NPPF.
See attached.
Object
Draft Local Plan
Representation ID: 15321
Received: 04/05/2016
Respondent: Wiggins Gee Homes Ltd
Agent: David Russell Associates
There are 9 allocations with potential to deliver early in the plan period and help relieve the current significant shortfall in supply. These allocations have a total capacity of around 390 new dwellings and are:
Wates Way Industrial Estate
Essex County Fire Brigade HQ
Warley Training Centre
Westbury Road Car Park
Chatham Way/Crown Street Car Park
Hunter House Western Road
Sow and Grow Nursery Pilgrims Hatch
Ingatestone Garden Centre
Ingatestone Bypass
Among these, 2 are currently town centre car parks, a further 2 are public service establishments, whose future may be liable to further public service review. Added to this would be the delivery from planning permissions already given but yet to be implemented; an allowance from permitted development conversions of offices to
residential, and a windfall site allowance. The net result is an annual production of around 150 to 200. This leaves the Draft Local Plan struggling to meet its target.
See attached.
Object
Draft Local Plan
Representation ID: 15322
Received: 04/05/2016
Respondent: Wiggins Gee Homes Ltd
Agent: David Russell Associates
The Local Development Scheme states that the new Local Development Plan is scheduled for adoption by the second quarter of 2017. Even if this is achieved, its
land allocations will still need to be based on very robust foundations.
See attached.
Comment
Draft Local Plan
Representation ID: 15323
Received: 04/05/2016
Respondent: Wiggins Gee Homes Ltd
Agent: David Russell Associates
Site 159 is a greenfield Green Belt site, but the Council needs sites with a high degree of certainty about its deliverability like this. Otherwise, it faces continuing challenges through the plan preparation and appeal processes.
See attached.
Object
Draft Local Plan
Representation ID: 15324
Received: 04/05/2016
Respondent: Mr. N & R Hart and Mr. K & P Watson
Agent: Wingfield Planning Consultancy
Object to the Policy on the basis that clients site at Hatch Rd, Pilgrims Hatch has not been identified as Housing Land Allocation. The site should be allocated for the following reasons:
- Site allocation will allow for a logical extension of Pilgrims Hatch in accordance with the Green Belt purposes in the NPPF.
- Will allow for clear and planned growth of Pilgrims Hatch within what is a derelict former brownfield site. Site was used as a commercial nursery.
- The site has been previously developed and whilst the buildings have since disappeared from the site, their foundations exist and the land remains contaminated and derelict. Allocation and development of the site will allow the remediation work to take place for decontamination.
- Opportunity to positively enhance the environmental and ecological quality of the site through a development led proposal.
- The site offers a defensible boundary to ensure the development of it would not result in urban sprawl or encroachment into the open countryside.
See attached
Object
Draft Local Plan
Representation ID: 15325
Received: 04/05/2016
Respondent: Mr. N & R Hart and Mr. K & P Watson
Agent: Wingfield Planning Consultancy
Proposed draft allocations are heavily reliant upon the Dunton Hills Garden Village, which relies upon acceptance from Basildon Council. Furthermore, the first draft does not allow for any strategic growth within the north of Brentwood.
See attached
Object
Draft Local Plan
Representation ID: 15338
Received: 05/05/2016
Respondent: Ford Motor Company
Agent: Iceni Projects Limited
Ford notes that the land north of its car park (north of Eagle Way), known as the 'Council Depot, The Drive, Warley - site reference 081' has been allocated for residential development.
Ford has assumed that the employment designation to the north of Eagle Way, Warley is retained within the Draft Local Plan. Ford believes that an appropriate policy should be included within the Brentwood Local Plan which provides future flexibility for the redevelopment of this site for range of land uses should the car park become surplus to Ford's requirements during the Plan period.
Should the site become surplus to requirement during the Plan period, then there should be no requirement for Ford to justify the loss of employment on this land as it has not previously been used for employment uses - only ancillary car parking. A more flexible policy wording for Ford's land to the north of Eagle Way may assist in realising or enhancing this development aspiration in future years.
See attached
Support
Draft Local Plan
Representation ID: 15349
Received: 05/05/2016
Respondent: Countryside Properties
Agent: Colliers International
It is welcomed that a range of smaller sites have been allocated for residential development and will enable the Council to maintain a rolling five year land supply.
see attached
Object
Draft Local Plan
Representation ID: 15351
Received: 05/05/2016
Respondent: Countryside Properties
Agent: Colliers International
The requirement set out at Policy 7.4 for planning applications submitted in advance of the indicative phasing to only be approved if further tests are undertaken is overly onerous. It is our opinion that the phasing estimates set out at Appendix 2 should be viewed as indicative, rather than forming the basis to introduce additional barriers to the delivery of allocated sites that have already been rigorously tests to ensure their suitability for development.
see attached
Comment
Draft Local Plan
Representation ID: 15401
Received: 19/03/2016
Respondent: Hopefield Animal Sanctuary
Hopefield Animal Sanctuary is a popular and important local community facility, but only has a lease that expires in 2022 and are keen to secure a long-term future.
A residential allocation on this site will help achieve this objective as it will allow Tesco to guarantee our ongoing freehold occupation on part of the site in addition to providing us with a freehold replacement site in another suitable location.
Hopefield Animal Sanctuary is pleased to provide comments on the Brentwood Draft Local Plan which is currently at formal public consultation.
The animal sanctuary is located to the north east of Brentwood Town centre, along Sawyers Hall Lane, and has been in operation for the last 25 years.
We are a popular and important local community facility but only have a leasehold interest in the site that expires in 2022 and are keen to secure a long-term more certain future.
A residential allocation in the Local Plan on the Sawyers Hall Lane site will help achieve this objective as it will provide the framework on which Tesco can guarantee our ongoing freehold occupation on part of the site in addition to providing us with a freehold replacement site.
We have a good working relationship with Tesco and agree that the site is capable of accommodating up to 450 new homes in addition to retaining and improving the Hopefield visitor facilities, stables and some grazing land.
Under these proposals, Tesco would also replace the lost grazing land with an additional freehold site in another suitable location. We consider these off-site arrangements acceptable and have recently had detailed discussions with them on a site within their ownership that we would be prepared to move to.
Securing our long term future and the operation of the animal sanctuary is our main priority and we urge the Council to recognise that this is a once in a generation opportunity for the sanctuary and one that we hope can be fulfilled.
Given that the site has previously been identified as a potential housing site, we wholeheartedly support the proposals currently being prepared by Tesco Stores Limited.
Object
Draft Local Plan
Representation ID: 15424
Received: 06/05/2016
Respondent: JTS Partnership LLP
Of the five sites that have been identified for release from the Green Belt, site 079A is considered to have a 'Low-Moderate' assessment rating, sites 022, 023 and 032, 087, 235 are considered to have a 'Moderate' racing, whilst 034 has a 'Moderate-High' rating. A 'Moderate' rating is defined as being where "development of the site will moderately affect the site's contribution to the purposes of the Green Belt" and where either: -
- Three, or all, Green Belt Purposes is assessed to a Moderate Level; or
- One Purpose of the Green Belt is assessed to a High Level and at least two Purposes are assessed to a Moderate Level; or
- Two Purposes are assessed to a High Level and the other two Purposes limited to a Low level."
Given that the Assessment also lists 50 sites that are either within the 'Low-Moderate' or the 'Low' assessment rating, the Council has failed to take into account their own Evidence Base in identifying sites and when informing their Local Plan strategy. As a result, it is considered that the Local Plan, as it stands, is unsound.
See attached
Comment
Draft Local Plan
Representation ID: 15502
Received: 09/05/2016
Respondent: Mr Richard Lunnon
Agent: JTS Partnership LLP
It is evident that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken.
Sites, such as that submitted, form the allocation of a parcel of land fronting Hay Green Lane, Hook End, should be considered by the Local Planning Authority as smaller development, which meet the criteria of infill development and combined with other similar sites, can provide considerable housing numbers to help the Council achieve their objectively assessed needs.
See attached
Comment
Draft Local Plan
Representation ID: 15590
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
Policy 7.4 refers to Figure 7.2, which provides a list of housing land allocations but does not provide detail on form, scale and access as required under paragraph 157 of the NPPF. Whilst it is not considered appropriate that a Local Plan is overly prescriptive in terms of development requirements, it is deemed necessary that policies and criteria for each allocation site are provided to assist decision makers in considering development proposals (NPPF, para 154). Equally, an Applicant should be provided with guidance to ensure an appropriate planning application for those sites allocated can be submitted.
It is therefore considered appropriate that the DLP is revised to include individual policies on allocated development sites containing criteria against which subsequent proposals can be assessed. This will ensure that the Plan is 'Consistent with national policy', 'effective' and therefore "sound" in this regard.
See attached.
Comment
Draft Local Plan
Representation ID: 15593
Received: 10/05/2016
Respondent: Mr Lee O'Connor
Agent: JTS Partnership LLP
Sites, such as that at 365 Roman Road, Mountnessing (see supporting site location plan), should be considered by the Local Planning Authority as smaller windfall development, which meet the criteria of infill development and combined with other similar sites, can provide considerable housing numbers to help the Council achieve their objectively assessed needs.
See attached
Comment
Draft Local Plan
Representation ID: 15598
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
Considered appropriate that the DLP is revised to include individual policies on allocated development sites containing criteria against which subsequent proposals can be assessed. This will ensure that the Local Plan is 'Consistent with national policy', 'effective' and therefore "sound" in this regard.
See attached.
Object
Draft Local Plan
Representation ID: 15628
Received: 10/05/2016
Respondent: Basildon Borough Council
In relation to identified housing land supply, it would appear from the evidence base that Brentwood Borough Council has not carried out a Strategic Housing Land Availability Assessment (SHLAA) since 2011. Basildon Borough Council made it clear in its response to Brentwood Borough Council regarding the Brentwood Borough's Local Plan Strategic Growth Options in early 2015 that it would expect the SHLAA to be updated before a Local Plan for Brentwood is progressed. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments to help inform the emerging Local Plan, and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply. It is not clear how any of the proposed housing sites included in the Draft Local Plan have been put forward and how the sites are justified as suitable without crucial supporting evidence which is missing including recent landscaping, ecology and open space evidence.
See attached.
Comment
Draft Local Plan
Representation ID: 15665
Received: 10/05/2016
Respondent: Tony Hollioake
Agent: JTS Partnership LLP
It is evident that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken.
See attached
Comment
Draft Local Plan
Representation ID: 15669
Received: 10/05/2016
Respondent: Southend on Sea Council
We note in Policy 5.2 'Housing Growth' and supporting text that Brentwood Borough Council seeks to fully meet objectively assessed housing needs within the Brentwood Borough boundary. We note, however, that the plan does not appear to acknowledge that Brentwood may need to consider assisting other constrained neighbouring authorities within adjoining housing market areas to meet unmet housing need, in accordance with national policy and guidance, if this need cannot be met within that particular housing market area.
See attached
Comment
Draft Local Plan
Representation ID: 15674
Received: 10/05/2016
Respondent: Anglian Water
Anglian Water has made an initial assessment of the impact of the proposed housing, employment retail and leisure allocation sites on existing water and water recycling infrastructure located within Anglian Water's area of responsibility. This will need to be revisited when planning applications are submitted to the District Council and we are approached by developers as part of the planning application process. A copy of the initial assessment made by Anglian Water is included with this consultation response.
In relation to the strategic sites identified in the Local Plan it would be helpful to cross refer to the requirements of Policies 10.13 (Flood Risk) and (Sustainable Drainage) to ensure that these development proposals which are of strategic significance provide sufficient evidence relating to foul drainage and surface water management and the timing of any required improvements.
See attached.
Comment
Draft Local Plan
Representation ID: 15677
Received: 10/05/2016
Respondent: Anglian Water
For a number of the allocation sites there is a pumping station located on the site or within close proximity of the site. A 15 metre distance between the boundary of the pumping station and the curtilage of any new dwelling should be maintained in order to reduce the risk of nuisance or loss of amenity. The design layout for these sites should take this into account.
See attached.
Comment
Draft Local Plan
Representation ID: 15705
Received: 11/05/2016
Respondent: Mrs P R Tredget
Potential to include land at the back of Grange Close, Ingrave, Essex. The land is of approximately 3 hec
See attached.
Comment
Draft Local Plan
Representation ID: 15802
Received: 11/05/2016
Respondent: Persimmon Homes Essex
This policy should provide details of how regularly the Council will assess the Borough's current situation to determine whether there is a need to bring forward sites ahead of their phasing for development. This will ensure that the Council can demonstrate a robust 5 year housing land supply and not open themselves up to speculative applications.
See attached.
Comment
Draft Local Plan
Representation ID: 15832
Received: 23/03/2016
Respondent: Mr Ronan Hart
Own part of site 053B to the rear of 146-148 Hatch Road, Pilgrims Hatch which has access rights from Crow Green Lane. Ask that this be considered as a suggested housing site. This could provide a doctors surgery which would benefit the Bishops Hall and Flowers Estate which do not currently have a health centre. The site is on the edge of existing housing and would provide an opportunity to allocate a good number of houses with minimal effect on existing residents.
I own, with my Brother Nick Hart, some land to the rear of 146 -148 Hatch Road, Pilgrims Hatch.
I believe our land forms part of Site Reference 053B. The rest of the site is owned by the Watson Family.
I attach to the email a copy of the Land Registry document. The land is marked is outlined in red.
We have access rights over the land marked in blue from Crow Green Lane. This means that there could be access from Crow Green Lane and Hatch Road which would reduce traffic flow.
We would ask that consideration be given to including this land within your suggested sites (for homes) in the local plan. If this was approved, we would commit for a Doctors surgery to be built within the development. The Bishops Hall Estate and the Flowers Estate do not currently have a Health Centre and would benefit greatly from a local surgery. I have relatives in Heather Close and many of the neighbours are retired people who can struggle to get to the High Street.
The site is on the edge of existing housing and would provide you with an opportunity to allocate a good number of houses. The effect on existing home owners would be minimal.
Please let me know if you need any more information.
Comment
Draft Local Plan
Representation ID: 15900
Received: 14/03/2016
Respondent: Sunbury Homes
Agent: JCN Design
Client has interest in land on Coxtie Green Road for residential development (refs 171 & 172).
This site has not been selected despite meeting the requirements for limited Green Belt release described in Policy 5.1 and the site selection tests in paragraph 7.29.
The site is within a transport corridor, a strategic location, part of a self sustaining community, nearby local services, clear defensible boundaries and will provide development swiftly.
The site is not isolated in the countryside and would be a logical extension to the existing development on the north side of the road.
Currently the scrap yard is a nuisance and would be improved with redevelopment.
An application for 12 dwellings is already being considered which confirms the site will have no significant impact, this shows it is viable.
BRENTWOOD DRAFT LOCAL PLAN: REGULATION 18 CONSULTATION
FORMER EHS METALS YARD AND 139 - 149 COXTIE GREEN ROAD, COXTIE GREEN
On behalf of Sunbury Homes, I write with regard to the borough council's draft Local Plan and the current Regulation 18 consultation exercise. My client has an interest in the land at the former EHS Metals Yard and numbers 139 to 149 Coxtie Green Road, Coxtie Green, which was identified as a potential site for residential development in the Strategic Growth Options Consultation (January 2015) under references 171 and 172.
Sites 171 (Former EHS Metal Scrapyard, Coxtie Green Road) and 172 (Land rear of 131 - 137 Coxtie Green Road) comprise a scrapyard, industrial uses and hardstanding within the Metropolitan Green Belt. It has been determined from intrusive investigations that both sites have a degree of contamination and that this has the potential to impact on adjoining land and watercourses. As well as creating an opportunity to comprehensively deal with the historic contaminative uses, redevelopment of the EHS Metals Scrap Yard will remove a use which is incompatible with adjoining residential dwellings.
Draft Policy 5.1: Spatial Strategy and Figure 5.4 set out a sequential test for the allocation of
land for development, with brownfield sites in the Green Belt considered as the second tier, to be required only if all suitable and available locations within the built-up area have been brought forward first, and prior to strategic sites (third tier), greenfield sites in the Green Belt (fourth tier) and reliance on windfall sites. The draft Local Plan acknowledges that land supply is constrained and identifies sites as far as the fourth tier in draft Policy 7.4.
Draft Policy 7.4 Housing Land Allocations identifies sites with potential capacity for ten or more homes that should be allocated for residential development between 2013 and 2033. However, the above site has not been included in the list set out in Figure 7.2, even though it meets the requirement for limited release of Green Belt development described in Policy 5.1 and the site selection tests described in paragraph 7.29 and offers a more sustainable form of development than some of the sites that have been selected. For the record and as required by draft Policy 5.1, the site is within a transport corridor, in a strategic location that is already part of a self-sustaining community with accompanying local services, has clear defensible physical boundaries to avoid further sprawl and will provide development swiftly.
The site is close to the northern edge of the existing Brentwood Urban Area and is part of the ribbon of development that extends westwards along Coxtie Green Road from Pilgrims Hatch.
The site is not isolated in the countryside and reads as part of the transition between the built-up area of Brentwood and the rural area that surrounds it. The site would therefore be a logical and well-defined extension to the existing development on the north side of the road. The scrapyard is considered to be a nuisance and an un-neighbourly use, meaning that there is no significant harm caused by the land being changed to an alternative use. The designation of the land in agricultural use to the north as part of the Green Belt also means that there is no opportunity for the development of the site to begin a process of expansion into countryside to the north west of Brentwood. The proximity of the site to Pilgrims Hatch and northern Brentwood means that it is close to local services and facilities, including schools, shops and a health centre. Coxtie Green Road is served by a regular bus service (routes 71 and 72) and also has good access to employment areas, Brentwood's town centre, railway station and the M25/A12 junction.
Furthermore, an application for planning permission to comprehensively redevelop the site and create 12 no. new homes (reference 16/00226/FUL) is currently being considered, including proposals to remediate the substantial levels of contamination caused by the previous use and to build a mix of two, three, four and five bedroom houses, including a proportion of affordable housing. The application also confirms (as required by Policy 5.1) that the development of the site will have no significant impact on the Green Belt, visual amenity, heritage, transport and environmental quality (including landscape, wildlife, flood risk, air and water pollution). It is also anticipated that financial contributions towards social infrastructure improvements will also be secured by a legal agreement attached to the planning permission.
The site has already been promoted through the Strategic Housing Land Availability Assessment call for sites process, was identified as a potential site for residential development in the Strategic Growth Options Consultation and is now subject to an application for planning permission, demonstrating that it can be considered to be deliverable in the short term. The footnote to Paragraph 47 of the National Planning Policy Framework states that a site is considered deliverable if it meets the criteria of being (a) available now, (b) offers a suitable location for development now, (c) is achievable with a realistic prospect that housing will be delivered on the site within five years and (d) development of the site is viable. The proposed redevelopment of the site meets these four tests of deliverability.
The applicant has control over the whole site and all uses are currently "on hold" pending the commencement of redevelopment works. As such, it is currently available for development and the remediation of the site and construction of new homes could commence as soon as the necessary permissions are in place. The location of the site is described above, with its proximity to the edge of the built-up area, position on a main road and accessibility to a regular bus service meaning that it can be considered to be a suitable location for development. There is a realistic prospect that housing will be delivered on the site within five years: there are no physical, environmental, social or legal constraints upon the site that could prevent development, although it is accepted that extensive decontamination works will be required As such, upon the grant of planning permission for redevelopment for residential use, the site can be developed with new homes straight away, making it achievable in the short term. The site is already controlled by a developer and an application for planning permission is currently being considered. Based on detailed financial appraisals undertaken by Sunbury Homes and subject to agreeing appropriate contributions through the negotiation of a Section 106 Agreement, the site is a viable proposition. In short, the site passes the tests of being available, suitable, achievable and viable and can therefore be considered to be a deliverable housing site. Moreover, the site
is deliverable in the short term: it can be developed as soon as the necessary approvals are in place and, as noted above, an application for planning permission is currently being considered, emphasising that the site can be delivered for residential development in the near future.
As such, Sunbury Homes wishes to highlight that the land at the former EHS Metals Yard and 139 to 149 Coxtie Green Road passes the site selection tests set out in the draft Local Plan and that it should be included in the list of sites allocated for residential development that are set out in draft Policy 7.4 and Figure 7.2.
I trust that you will find these notes to be clear and straightforward, but if you have any queries, or should you wish to discuss the redevelopment of the site in greater detail, please do not hesitate to contact me at the above address.