The 2.8 ha of land at Crow Green Lane, Pilgrims Hatch owned by Wiggins Gee Homes Limited is in single ownership, available now, and could be used for much needed affordable housing. It is not subject to objections from other major parties to the Local Plan preparation process. It does not have serious implications for local and regional infrastructure. It is located in the Local Plan's A12 Growth Corridor, enjoying far better environmental and social conditions than some of the other allocations being proposed in this Corridor. Its effect on the Green Belt would be negligible compared to DHGV.

Brentwood Local Development Plan
Addendum of Focussed Changes to the Pre
Submission Local Plan
(Regulation 19) Consultation
1. The focussed changes amount to reducing the capacity of proposed housing land allocations R18, R19, R25 and R26 by a total of 70 units, and transferring it to the Dunton Hills Garden Village Strategic Allocation Policy R01 (I).
2. The focussed changes document sets out reasons for reducing the estimated capacity of allocations R18, R19, R25 and R26. The reductions are being made as a result of concerns expressed in responses to the Pre-Submission Local Plan consultation earlier this year. These concerns related to a range of factors including development in the Green Belt, access, traffic generation, impact on wildlife and the natural environment, and flood risk. All of these factors would have been considered by the Local Planning Authority (LPA) in their original selection of these sites for inclusion in the Pre-Submission draft. This underlines the subjective nature of many planning criteria, the need for flexibility and the avoidance of fixed attitudes in the evaluation of development land allocations.
3. As brief as they were, at least some justification underlies reducing R18, R19, R25 and R26's potential capacity. No justification is given for transferring this lost capacity to the Dunton Hills Garden Village Strategic Allocation. Perhaps the LPA thinks there is no need for an explanation. Dunton Hills Garden Village is a big enough hole in which to lose an extra 70 houses without having to think about any alternative solution.
4. As we made clear in our representations to the Pre-Submission Local Plan consultation, we think Dunton Hills Garden Village is surrounded by too much controversy and too many outstanding issues over the timing of housing delivery and the capacity of local and regional infrastructure to fully support this strategic proposal. Brentwood's immediate neighbours continue to maintain strong opposition to the proposal, as was made clear in the report to the Policy, Resources & Economic Development Committee at their meeting on 11 September 2019.
5. The LPA is surely ill-advised to regard Dunton Hills Garden Village as a sort of "cure-all" repository for the Borough's planning problems, when it is the subject of such a degree of uncertainty and controversy. There is a very simple solution as to where to re-locate the 70 or so units lost from R18, R19, R25 and R26; the 2.8 ha of land at Crow Green Lane, Pilgrims Hatch that we have been promoting on behalf of the owners, Wiggins Gee Homes Limited. Here is a site, in single ownership, that is available now, which could be used for much needed affordable housing. It is not subject to objections from other major parties to the Local Plan preparation process. It does not have serious implications for local and regional infrastructure. It is located in the Local Plan's A12 Growth Corridor, enjoying far better environmental and social conditions than some of the other allocations being proposed in this Corridor.
6. The Crow Green Lane site's only sin is its location in the Metropolitan Green Belt. But then so are many of the Plan's other proposed allocations. Its effect on the Green Belt would be negligible compared to the strategic hole that would be created by Dunton Hills Garden Village Policy R01 (I), threatening the Green Belt's integrity in this part of Essex.
7. The Pre-Submission Local Plan would be made more sound by transferring the 70 dwellings from allocations R18, R19, R25 and R26 to the certainty of the land at Crow Green Lane, rather than the uncertainty and controversy of the proposed Dunton Hills Garden Village.
8. This representation should be read in conjunction with our clients' responses earlier this year to the Pre-Submission Local Plan Consultation. We confirm we are agreeable to this representation being passed to the Inspectorate along with previous representations.