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Brentwood Local Plan: Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) Planning Representations Prepared by Savills (UK) Ltd on behalf of Crest Nicholson Eastern in respect of Focussed Change 5: Land North of Orchard Piece, Blackmore (Local Plan Policy R26)
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Brentwood Local Plan
Planning Representations November 2019
Classified as General
Contents
1. Introduction
2. Land North of Orchard Piece: Local Plan History
3. Rebuttal to Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) and Supporting Evidence Base October 2019
Appendices
Appendix 1: Land North of Orchard Piece Vision Statement
savills.co.uk
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Brentwood Local Plan
Planning Representations November 2019
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Representations
1.0 Introduction
1.1 These representations have been prepared by Savills (UK) Ltd on behalf of Crest Nicholson Eastern (Crest) in response to Brentwood Borough Council's "Addendum of Focussed Changes to the Pre Submission Local Plan (Regulation 19)". They relate to "Focussed Change 5 Policy R26: Land North of Orchard Piece, Blackmore" which seeks to reduce the allocation's quantum of development from approximately 30 to 20 dwellings. This follows the site's original allocation (Reg 18 Plan) for approximately 40 dwellings which continues to be supported by the Plan's technical evidence and all statutory consultees.
1.2 We have previously submitted representations on behalf of Crest to earlier consultation versions of the Plan; including the Strategic Growth Options in 2015, the Draft Local Plan in 2016, the Draft Local Plan Preferred Site Allocations in 2018 and the Pre Submission Local Plan February 2019.
1.3 A Vision Statement prepared by Thrive Architects is enclosed at Appendix 1. This Statement articulates how approximately 40 dwellings can be delivered as part of a high quality, generously landscaped scheme. The illustrative layout shown carefully considers the site's opportunities and constraints and has been informed by detailed technical studies undertaken in liaison with statutory consultees.
1.4 In responding to this consultation, these comments take into account Paragraph 35 of the NPPF which requires Local Plans to be sound. To meet this requirement they should be positively prepared, justified, effective and consistent with National Policy.
2.0 Land North of Orchard Piece: Local Plan History
2.1 Land North of Orchard Piece was allocated for housing in the Preferred Options Local Plan (2018) for approximately 40 dwellings. The Draft Local Plan's supporting evidence base justifies why this quantum is entirely suitable despite it representing a lower density than required by Policy HP03 which seeks a net density of at least 35 dwellings per hectare, equating to 53 dwellings. The Plan's evidence base, BBC's officers and all statutory consultees formally supported a site capacity of approximately 40 dwellings.
2.2 However, the subsequently published Pre Submission Local Plan (February 2019) reduced the quantum of homes allocated to approximately 30 dwellings. The single paragraph justification provided in the supporting Sustainability Appraisal (SA) states "Ahead of the 8th November 2018 Extraordinary Council meeting the Council worked to explore potential adjustments to the strategy, as previously published, in light of representations received, with the Council reaching the tentative conclusion that, whilst all of the
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January 2018 allocations remain suitable, there was a need to reduce the number of homes allocated to certain sites38" Footnote 38 then states "Specifically: the yield of the two adjacent sites at Blackmore was reduced by 26 homes to take account of the potential need for surface water flooding measures on site."
2.3 Savills submitted formal representations in response stating:
"Ardent Consulting Engineers have undertaken detailed technical work relating to flooding and drainage to inform proposals for the site. In terms of drainage the site is located within fluvial Flood Zone 1 (less than 0.1% chance of flooding in any year or a 1:1000 year chance). The Brentwood Strategic Flood Risk Assessment (SFRA - Nov 2018) shows that the Site is in an area that is not vulnerable to groundwater flooding.
Some residents have noted incidents of surface water ponding along Redrose Lane during excessive periods of rainfall. However, the area noted is beyond the eastern boundary of the site where the watercourse is culverted under Redrose Lane. Given the local topography, the flooding depth in Redrose Lane has a negligible impact upon the site. As a precautionary measure, it is intended that the minimum floor level of the proposed dwellings in the north east corner of the site will be raised by approximately 300mm. In addition, ditches along the boundary of the development could be implemented.
The engineered Sustainable Drainage System (SuDS) will of course provide a betterment to the existing situation by managing/controlling the flow of surface water discharge rates into the surrounding network. CNE continue to liaise with both ECC and the EA in this regard.
Therefore, although the principle of the site's allocation is fully supported, the reduction in quantum of homes from 40 to 30 homes does not align with detailed technical evidence."
3.0 Rebuttal to Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) and Supporting Evidence Base October 2019
3.1 Focussed Change 5 of the Addendum proposes to reduce the allocation's capacity further, from approximately 30 to 20 dwellings:
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3.2 Although the consultation document provides no supporting text, the "Sustainability Appraisal (SA) of the Brentwood Local Plan Report Addendum" simply states (Para 2.8.1):
"None of the four sites that see a reduction in homes under the Focussed Changes are subject to a fluvial flood risk, and the Environment Agency did not raise any objection to allocation of any of the sites in question. However, Site R26 Land North of Orchard Piece, Blackmore (10 homes decrease) is subject to a notable degree of surface water flood risk constraint - see Figure 2.1, which shows "extent of surface water flood risk" with risk categorised as either "high" (dark blue), "medium" (blue) or "low" (light blue)."
3.3 However, the current mapping used by the EA shows that less that 10% of the site is impacted by "high" risk surface water flooding with the majority "low" risk. As stated in our previous Reg 19 representations, some residents have noted incidents of surface water ponding along Redrose Lane during excessive periods of rainfall but beyond the eastern developable boundary of the site. Given the local topography, the flooding depth in Redrose Lane has a negligible impact upon the site.
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3.4 However, as a precautionary measure, it is proposed that the minimum floor level of the proposed dwellings in the north east corner of the site will be raised by approximately 300mm. In addition, ditches along the boundary of the development could be implemented. The engineered Sustainable Drainage System (SuDS) will of course provide a betterment to the existing situation by managing/controlling the flow of surface water discharge rates.
3.5 CNE continue to liaise with both ECC and the EA in this regard, both of which have no technical objections to our proposals for approximately 40 dwellings.
3.6 Aecom's SA (October 2019) also concludes at 9.15.1 "The appraisal finds that that the Focussed Changes have positive implications in respect of: 'Community' objectives, reflecting the fact that the Focussed Changes have been developed in response to concerns raised by local residents; and 'Flood risk' objectives, given the surface water flood risk issue at Site R26."
3.7 The Local Plan's Reg 19 evidence therefore confirms that the reason for reducing the quantum of development from approximately 40 to 20 dwellings is purely political and is contrary to both technical evidence and the advice from statutory consultees which concludes that a scheme of approximately 40 dwellings is entirely suitable.
3.8 The SA also refers to other concerns raised by the residents of Blackmore including inadequate access and the disproportionate level of housing allocated to the village compared with other category 3 settlements.
3.9 The Local Plan's evidence base confirms that Land North of Orchard Piece can be suitably accessed via Redrose Lane which is reflected in Policy R26 and supported by ECC Highways.
3.10 Blackmore is a Category 3 Settlement which is defined as a village that provides day to day facilities for local residents, where limited urban extensions are encouraged to meet local needs. However, it is unique in comparison to other Category 3 Settlements due to its more clearly defined spatial configuration and range of centrally located village services. In contrast, the majority of the Borough's other villages are characterised by more linear, sporadic settlement boundaries preventing logical extensions. Meeting housing needs at Blackmore is also critical in terms of addressing localised affordability issues and retaining the viability and vitality of local shops and services.
3.11 Meeting local housing need is even more essential given the conclusion of the SA underpinning this consultation which states "The Focused Changes are found to have negative implications in respect of Housing....There is also a need to consider a notable contextual change, namely the fact that Local Housing
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Need (LHN) is now understood to be higher than was the case at the time of the Pre-submission Plan / SA Report."
3.12 In conclusion, to ensure the Plan is Sound, we therefore request that the wording of the site allocation be amended to reinstate the capacity of the development to approximately 40 dwellings, in accordance with the technical evidence and advice from statutory consultees.
3.13 The appended Vision Statement articulates how approximately 40 homes can be delivered in the short term to meet Blackmore's needs as part of a high quality, generously landscaped scheme, reflective of the density, pattern and character of existing surroundings.
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Brentwood Local Plan
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Appendices
Appendix 1: Land North of Orchard Piece, Blackmore - Vision Statement
