Return the indicative dwelling yield to 75. Do not make the Addendum changes to the plan.

1.1 The following representations are made on behalf of The Ursuline Sisters Brentwood
Charitable Incorporated Organisation (CIO) - "the Sisters" - and form two parts.
1.2 Firstly, specific comment is made on the proposed changes to Policy R19 (Land at Priests
Lane, Shenfield) - Focussed Change 3, the large part of which is land within the Sisters'
ownership.
1.3 Secondly, representations are made on the soundness of the approach set out within the
Addendum of Focussed Changes to the Pre-Submission Local Plan (the "Consultation
Document"), which sees the reduction in allocation numbers across four sites and their
reallocation to the Dunton Hills Garden Village Strategic Allocation (sites under Policy R18,
R25 and R26) to within the latter part of the Plan Period - Focussed Changes 1-5.
1.4 The proposed changes to these four allocations sees a total loss of 70 units and their
reallocation to the Dunton Hills Garden Village Strategic Allocation (DHGV), increasing its
allocation to 2,770 units (Policy R01).
1.5 In respect of the Land at Priests Lane, Shenfield, a loss of 30 units is proposed to a
provision of "around 45 homes".
1.6 In responding, we confirm The Sisters' objection to the 5 focussed changes as set out
within this Consultation Document. The basis of this objection is that the proposed delivery
of the housing, as set out within Appendix 1 of the Consultation Document is not achievable
or viable, and that the Plan should be considered as unsound. Furthermore the
reallocation of the 30 units from Policy R19 is not justified or supported by any evidence
and ignores the evidence presented by the landowner.
2.0 Focussed Change 3
Lack of Evidence to Support Reduction
2.1 It is noted generally that the Focussed Changes Consultation is centred upon five key
Policies in relation to four housing sites. The objective to achieve some reduction in
housing numbers on those identified sites and to lump the reduced number into the key
Dunton Hills Garden Village Strategic location. We strongly object to the general thrust of
that approach as it will leave the Plan unsound. Brentwood Council are relying too strongly
on one strategic release which has knock-on consequences for the plan as a whole. The
focus of this objection is in relation to Policy R19 (Land at Priests Lane, Shenfield)
reduction from "around 75" to "around 45 homes".
2.2 There is no explanation for the proposed decrease. The Local Authority evidence base
initially accepted and proposed in the Consultation Plan, January 2016, Priests Lane was
suitable for 130 dwellings. The land owners and their agents had worked closely with
Brentwood Council Officers and Essex County Council Highway Officers to show that in
terms of highway infrastructure the site was capable of accommodating at least that amount
of housing.
2.3 It had also been acknowledged by Officers during the course of many years discussion that
the Priests Lane site was the Council's most sustainable housing site. That position has
not changed.
2.4 There have been significant poorly informed objections from local residents and it is political
pressure that has brought the continued reduction in housing on the subject site.
2.5 We had shared with the Local Authority many reports that the land owners had secured
including two from Waterman Infrastructure and Environment Limited that had helped assist
the masterplanning of the site and which reflected concerns raised by residents as to the
unsuitability of Priests Lane and criticisms of the condition of the local footway links. The
conclusion from the Pedestrian Environment Review is that there is a good system of
footpath links, that third party criticism relates predominantly to highway maintenance
issues and that as a consequence of development the introduction of formal crossing points
in one or two locations would be a major benefit to the local footpath network providing
significant improvements to pedestrian safety and ease of access to the key centres of
Brentwood and Shenfield.
2.6 The Highways Technical Note concluded that the site is ideally located in a sustainable
location that MfS visibility splays are achievable. Predicted traffic impact and junction
assessments demonstrate that a potential residential development of up to 130 dwellings
will have a limited impact on the immediate and wider highway network. Finally that a
development of up to 130 residential units can be accommodated in this location accessed
from Priests Lane via a draft Essex Design Guide Type D "Access Road" arrangement.
Deliverability
2.7 This is one of the most, if not the best deliverable site within the Borough. It has remained
vacant for some 18 years and is easy to develop with no constraints. Flood Risk
Assessment has been prepared and a Drainage Strategy developed, there are no
ecological or tree constraints. All previous versions of the Consultation Local Plan, 17, 18
and 19 had shown the early deliverability of this site. From the baseline year of 2016/2017
the site is shown as delivering some houses, in 2020/2021 with realistic numbers for 2021,
2022, and 2023. It is possible given the status of the land its interest from the housing
industry that nearly all the housing could be brought forward by the end of 2022. Thus it
falls in a small category of allocated sites that will come forward in the early Plan period.
There is an over reliance by the Local Authority on larger sites not assured until the middle
to latter part of the Plan period. Indeed, full deliverability will not be achieved by 2030-
2033.
3.0 Focussed Change 1 - 5
3.1 The Focused Change 1 proposes changes to Policy R01 (I): Dunton Hills Garden Village
Strategic Allocation (DHGV) (page 252 of the Pre Submission Local Plan, February 2019).
Section B and D are amended to increase the DHGV housing provision from 2,700 to
2,770.
3.2 Appendix 1 of the Consultation Document sets out the projected delivery through the Plan
Period from 2016/17 to 2032/33. The first line of that table shows the DHGV allocation
delivery (page 10 of the appendix) and the first column erroneously states a change from
2700 to 2750 - this should read 2770. The final 3 columns of that line represent the final 3
years of the plan period. They show the additional 70 units to be delivered in these years,
with 25, 25 and 20 units through years 2030/31, 2031/32 and 2032/33 respectively.
3.3 These 70 units are taken from the following sites in the following Years in the Plan Period:
* Focussed Change 2 - Land at Crescent Drive Shenfield (+5 units) - Year 2023/23
* Focussed Change 2 - Land at Crescent Drive, Shenfield (-25 units) - Year 2023/24
* Focussed Change 3 - Land at Priests Lane, Shenfield (-30 Units) - Year 2022/23
* Focussed Change 4 - Land North of Wollard Way, Blackmore (-10 units) - Year
2024/25
* Focussed Change 5 - Land South of Redrose Lane/North of Orchard Piece,
Blackmore (-10 units) - Year 2022/23
3.4 The Focussed Changes 2 - 5 therefore see the reduction in delivery of 70 Units through
the Plan Period Years 2023 - 2025, with them redistributed to DHGV through Years 2030
to 2033.
3.5 Before considering the ability of the DHGV allocation to deliver within the stated timeframe,
it is important to note that projected delivery through the early years of the Plan Period,
2016 - 2022, is only 264 dwellings per annum (dpa) which falls way below the annualised
requirement of 456dpa - See Consultation Document Appendix 1. Indeed the proposed
loss of 35 units from 2022/23 sees its provision also fall below the average requirement, to
440. The first 7 years of the 17 year Plan Period is projected to deliver 2,027 units of the
required total provision of 7,752. This sees the remaining 10 years needing to make a
provision of 5,725, of which 2770 is proposed for the DHGV allocation. This equates to
48% of all supply in the latter 10 years of the Plan Period. In overall terms DHGV accounts
for 35% of provision.
3.6 The Plan is, therefore, significantly reliant on the DHGV allocation to meet the overall
supply of housing and in particular in the latter 10 years of the Plan Period from 2023 to
2033 to achieve significantly higher levels of provision to offset the 'slow start'.
3.7 It is therefore imperative that the projected timing and rate of delivery of the DHGV
allocation is realistic and viable. Where it is not, the Plan will fail to meet Policy SP02
housing delivery objective. Where this delivery timetable cannot be viewed as robust, the
Plan must be deemed as being unsound.
3.8 There are significant concerns about the robustness of this delivery timetable and this
position is only compounded by these focussed changes which remove deliverable unit
numbers from the early/middle part of the Plan Period and add them on to the end.
3.9 The current delivery programme identifies that the DHGV allocation is anticipated to begin
delivering units in the Year 2022/23, with the first 100 of the 2770 allocation being made
and the remainder being delivered in the following 9 years at an average of 297 dpa.
3.10 There are two issues in respect of this programme. Firstly, the achievability of the DHGV
delivery start date; and the subsequent rate of delivery from there on.
DHGV Housing delivery commencement
3.11 At the date of this consultation, the Plan predicts delivery at DHGV to commence within the
next 3 - 4 years. The Council's current LDS sets out a timetable for the Adoption of the
Plan (Regulation 26) to be achieved by Q3 of 2020. From this point of Adoption, delivery of
housing on the DHGV will need to be achieved within 2-3 years.
3.12 Credible research by NLP1 indicates that sites over 2,000 dwellings take an average of
around seven years from the submission of the first planning application to the delivery of
the first dwellings on site.
3.13 In the case of DHGV, very little work has been undertaken to form part of the Evidence
Base to demonstrate that the delivery of housing is achievable within 2 or 3 years from the
best case Adoption of the Local Plan.
3.14 While this research shows that Greenfield Sites do come forward at a quicker rate, the
DHGV site presents a significant number of challenges in masterplanning and bringing
forward development. These include large areas of the site being sited within the Flood
Zone 3, its location within the Green Belt, the need to make highways improvements at key
junctions and work to improve air quality along the A127 within Basildon. Furthermore
there is a need to work cooperatively with the adjoining Basildon Council to ensure
settlement coalescence is avoided and discussions between the Councils have taken place
in respect of agreeing a Landscape Corridor. While a study has been undertake and
signed off by both, Brentwood Borough Council has not utilised this work in determining the
extent of development and thus this issue remains unresolved.
3.15 Masterplanning of the site has not yet commenced. Development across the allocation will
likely involve multiple outlets (house builders) and while this can see increased housing
delivery rates, the key matter will be agreeing and publishing a masterplan which will allow
for planning applications from the various outlets to come forward. The challenges to
achieving a masterplan, as highlighted in para. 2.14 above, to address the site specific
needs of the allocation are substantial and will require significant work to resolve prior to
the completion of a masterplan and the commencement of the first phase of development.
1 Start to Finish - How Quickly do Large Scale Housing Sites Deliver/ (November 2016)
3.16 The NLP study identifies that for larger sites (+2000 units) the average time from the first
application to permit development and the delivery of the first unit is 0.8 years. Working
backwards from the current delivery timetable, this would require detailed planning
permission to be granted for the first phase of development by the end of 2022 at the latest.
This leaves approximately 2 years from the projected Adoption of the Local Plan to submit
and achieved detailed planning permission. In light of the limited amount of work
undertaken to date in setting out a masterplan, this timeframe is considered as very
unrealistic.
3.17 The NLP study identifies that for the larger sites, the time taken to achieve planning
permission from the validation of the first application to the granting of planning consent
which permits development of dwellings on site is 6.1 years. This takes no account of the
discharging of conditions as well as all necessary building control approval prior to
development commencing on site. The NLP analysis highlights that it has been possible
for large sites within their study data to achieved planning within 2 years. However this
represents the best case scenario. Where a median average is applied, such extremes at
either end of the scale would be discounted. 2 years should not be used as a reasonable
expectation in this case. There will be many site specific issues that will have to be
resolved at the masterplan and phasing stages and such work will take considerable time.
3.18 This analysis supports our conclusion that the projected commencement of delivery of the
DHGV is extremely optimistic to the degree that it is considered unrealistic. The evidence
base provides no detailed support to this Housing Trajectory and a failure to deliver
substantial amount of housing on this projected timeframe will see the failure of the Plan to
meet the housing need.
3.19 The approach to remove proposed units from other allocations during the first half of the
plan period and redistribute them to the end of the Plan Period is unsustainable that only
further increases the likelihood of the Plan failing. As such the Plan should be considered
unsound on the basis of the unviable nature of the Housing Trajectory.
3.20 The approach should be the opposite of that being undertaken through these focussed
changes. Rather than adding greater requirement for the DHGV allocation housing in the
Plan Period, other sites that are deliverable in the short to medium term should be
assessed to achieve greater housing numbers and efficiencies to offset against the
significant risk that the DHGV allocation will not deliver the very high numbers of housing
necessary to meet the overall supply.
Rate of Delivery
3.21 The Housing Trajectory predicts that the DHGV allocation will see the delivery of 100
dwellings in its first year (2022/23) with this gradually increasing to 300 dpa by 2026/27.
The final three years predict 270-275 dpa.
3.22 These rates of delivery represent very high figures. Such delivery is highly questionable
both in terms of the physical rate of delivery and their absorption rates (sales). The NPL
study highlights an average rate of delivery for schemes of +2000 dwellings of 161 dpa.
The highest annual average build rate of the 70 schemes assessed was 321 dpa, but this
only delivered for 3 years and that project (Cranbrook, East Devon) required significant
public sector money to enable phase 2 to commence and drive forward its completion.
3.23 The projected delivery rates for the DHGV allocation are therefore at the upper end of what
the NLP study considered achievable. It is not sound to base the projected delivery of
housing at such high rates simply to accommodate the required provision within the Plan
Period. Furthermore where any delay occurred to the commencement of this delivery even
greater demand would be put on the rate of delivery going forward.
3.24 Finally, the reallocation of 70 units within these Focussed Changes from the early/middle
part of the Plan Period to the latter three years increases the likelihood of such provision
not being achieved in the Plan Period. This is unsound where such delivery is achievable
in the early part of the Plan Period. It represents a systematic approach by the Council to
minimise delivery of housing in certain areas of the Borough in favour in placing further
demand on the DHGV allocation.
3.25 Such rates of delivery are not considered to be reasonable or realistic. The Plan provides
no robust evidence to support either this rate of delivery or the ability to commence delivery
by 2022/23 and thus the proposed Housing Trajectory should be considered as unviable
and the Plan unsound.
4.0 Summary & Conclusion
4.1 In respect of the reduction in numbers at Policy R19 Land at Priests Lane, there is no
justification or evidential support for such a reduction. The landowner has provided
Highways evidence to support much higher degrees of provision that will see the efficient
use of land as required by the NPPF. Also highlighted are the many highway and
pedestrian improvements that will enhance pedestrian accessibility and the wider highway
network.
4.2 There is great uncertainty about the ability to deliver the full DHGV allocation within the
Plan Period. With a significant reliance on that allocation to achieve the full Housing
Supply, it is not sustainable to remove the provision delivery of achievable units from other
sites where such can be delivered in the early part of the Plan Period.
4.3 The projected delivery of the DHGV allocation in terms of its commencement and the ongoing
delivery rate through the Plan Period is considered to be unrealistic and unviable. It
relies on achieving the delivery of the first units within 2 to 3 years of the Adoption of the
Local Plan and then delivering housing at a very high rate through the final 7 years of the
Plan Period. While these targets may be achievable in the best case scenario, the NLP
study supports the opinion that for large projects, delivery is likely to take a much greater
amount of time. The Council provide no evidence to support such lofty targets.
4.4 These best case scenario projections should not be adopted as realistic delivery targets
through the Plan Period. Reallocating 70 units to the latter stages of the Housing
Trajectory only increase the likelihood of a failure to meet the full housing supply through
the Plan Period.