R12 - Land at Hunter House, Brentwood

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Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22598

Received: 19/03/2019

Respondent: Mr Philip Mynott

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Site R12 should never have been retained in the final version of the plan. [Should take design led approach to density and retain office space].

Change suggested by respondent:

Remove site R12

Full text:

Policy R12 - Land At Hunter House
The original Council proposal for numbers of residential dwellings at this site was 22. I myself attended a Pre App meeting with the landowners at which a very senior council Planning Development officer said that the developers' then intended application for 50 units was "trying to fit too much on the site." Despite this, the Council seems subsequently to have simply taken the developers' wish to have this number of units on the site as its evidence that the site can take such a number, and abrogated its role as a Planning Authority. 48 residential units on 0.21 Ha equates to 228 dwellings per Hectare - a number which nears no relation to the density of other sites with Western Road addresses (thereby making the application of the Plan's HP03 (Residential Density) A., "Proposals for new development should take a design led approach to density which ensures schemes are sympathetic to local character..." impossible on this site). For comparison other town centre sites proposed in the Plan have densities of 166 dwellings per Ha (Westbury Road Car Park, R11); 104 dwellings per Ha (Brentwood railway station car park, R10); and 94 per Ha (Chatham Way Car park, R13). The only other site with a comparably high, in fact higher, density is the William Hunter Way site (R14), which is within a handful of meters of R12 - so that both will, of course, exacerbate each other's negative effects.
This site proposal is seriously flawed, even on the most fundamental level. Its removal of a thriving town centre employment site for the sake of residential use already looks peculiar in commonsense terms. It also flags up the conspicuous lack of any sub-paragraph in the Plan's SP01 intended to defend employment sites to sit alongside SP01 D.j.), which defends against the loss of residential units. The council's persistence with R12 as a Local Plan site also apparently ignores the specific advice it received from Lichfields, its own Local Plan employment consultants, in the Brentwood Economic Futures Study. This advice (which was received in December 2017) stated firstly that the council "may want to consider other sites for offices given the new allocations are all located a reasonable distance away from public transport nodes and high quality amenities", and secondly that "consideration could be given to gaining an Article 4 Direction to stop the conversion of offices to residential units through permitted development rights". To me, reading between the lines this is very clear advice to the council to prevent the loss of employment sites in the town centre - where, of course, you are close to "public transport nodes and high quality amenities", and where the vast majority of the office conversions are taking place. And yet not only is the council ignoring its consultants' advice on seeking to prevent such losses (it has still made no move to introduce an Article 4 process), but is persisting with LDP proposals, plural, which exacerbate them (the Wates Way site (R15) on Ongar Road, and, potentially, the Sow and Grow nursery site, also on Ongar Road (R07) are other examples).
An officer employed by Brenwood Council to advise on development possibilities said in my hearing only on Monday March 18th that ~"Brentwood is short of small industrial units". It is, and it should be both defending and creating more small employment sites near town centres, not proposing to eradicate them.