Add Salmonds Grove to the local plan.

Land at Salmonds Grove, Ingrave
Strutt & Parker on behalf of BPM Investments Ltd
November 2019
Consultation Response - Brentwood Local Plan Addendum of Focussed Changes
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1.0 Introduction and Background
1.1 This representation on the Brentwood Borough Council's Addendum of Focussed Changes (AFC) to the Pre Submission Local Plan (PSLP) is made by Strutt & Parker on behalf of BPM Investments ltd.
1.2 BPM Investments hold the promotion agreement for Salmonds Grove, Ingrave. The site has been promoted to the Council through the previous Local Plan consultations including objections to the Regulation 19 PSLP Consultation. The site is identified in those earlier Representations. The site has been considered by the Council through its Strategic Housing Land Availability Assessment (SHLAA) 2011, the Site Specific Sustainability Appraisal (SA), and the January 2018 Site Assessment Methodology, under Site Ref. 067a and 067b. Representations to the Regulation 18 consultation were also submitted highlighting many of the same concerns raised at Regulation 19.
1.3 The site is on land currently allocated as Green Belt in the Brentwood Replacement Local Plan (2005) and is immediately adjacent to the settlement boundary of Ingrave and Herongate. The site is in a sustainable position on the eastern boundary of Ingrave, in an area of residential character, and would make a logical extension to the settlement boundary for a modest number of dwellings. The suitability of the Site for delivery of dwellings in the early period of the Plan with negligible impact on the Green Belt and surrounding landscape is pertinent to the AFC consultation.
1.4 Concerns regarding the soundness of the PSLP as set out in our representations remain, and are not repeated here to avoid duplication. This representation focuses on the proposed focussed changes to the PSLP, set out in the AFC. These comprise the following:
1. Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,700" to "at least 2,770 homes in the plan period";
2. Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";
3. Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";
4. Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"; and
5. Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
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1.5 The AFC explains that the modifications are proposed due to concerns raised through consultation on the PSLP relating to proposed allocations R18, R19, R25 and R26, necessitating a reduction in the number of additional homes these proposed allocations can suitably accommodate (Focussed Changes 2-5).
1.6 The AFC explains that the total loss of 70 homes across the four aforementioned sites will be off-set through proposed focussed change to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the AFC does confirm that the overall number of new homes will not be increased, merely that there will need to be a faster rate of delivery at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than previously projected (para.5 AFC).
1.7 A critical matter raised in our previous representations is the over reliance of large strategic allocations that inevitably take a considerable time to bring forward (para. 2.28-2.34 and appendix 3 and 4 of our PSLP representations). The AFC exacerbates this failing by increases the proportion of development to be delivered at the strategic allocation of DHGV, from 34.6% of the total housing (44.3% of allocations) to 35.6% (45.5% of allocations)(see: AFC p.7; amendments to Figure 4.2).
1.8 To emphasise the impact of this approach, and the validity of our previous representations on this matter, changes are required to the delivery rate for new homes and is set out in the changes to the Housing Trajectory (AFC pp.10-15). This confirms a reduction in delivery rates until 2026/27 which is only accounted for in the final three years of the Plan (2030/31-2032/33). This is considered to be a distict failure of the Plan especially when alternative sites exist that can better meet the shortfall in the short term.
1.9 We therefore have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply stating that Dunton Hills Garden Village will deliver at a greater rate than previously suggested, at just a fast enough rate to account for the shortfall created by the need to reduce the proposed capacities for site R18, R19, R25, and R26.
1.10 The PSLP as amended by the AFC remains unsound. However, in our view it is capable of being made sound. Our concerns and suggested approach to addressing these is set out in this representation.
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2.0 Concerns with proposed focussed changes
2.1 The AFC identifies that the number that proposed allocations R18, R19, R25 and R26 will deliver is required to be reduced by a total of 70 from the figure identified in the PSLP.
2.2 The AFC explains that the justification for this reduction is, in short, that these four sites are no longer considered suitable to accommodate the quantum of development identified in the PSLP.
2.3 We have no details of the evidence supporting this view, providing a revised assessment of the sites' capacities; and none appear to have been published as part of the consultation.
2.4 However, it must be recognised that the NPPF requires:
a) Local Plans to provide a strategy to meet housing needs with sufficient flexibility to be able to respond to rapid change; and
b) Housing requirements to be considered as minimums.
2.5 In light of the above requirements, it is necessary for the Council to take a conservative and precautionary approach in assessing the potential capacity of sites for housing for the purposes of demonstrating that the strategy will meet housing needs. This does not of course mean that policies should restrict capacities, merely that the trajectory should not be overly optimistic.
2.6 As such, regardless of whether the proposed focussed changes to R18, R19, R25 and R26 are ultimately implemented following the current consultation, the trajectory accompanying the Local Plan cannot rely on these sites to deliver the number of dwellings originally proposed in the PSLP.
2.7 In terms of the AFC's proposed solution to addressing the shortfall resulting from the revised assessment of proposed allocations, this is evidently unsound - it is neither justified, consistent with national policy nor effective. Furthermore, it fails to ensure the Local Plan can be considered positively prepared.
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Projected First Year of Completions for Dunton Hills Garden Village
2.8 Appendix 1 to the PSLP provided a housing trajectory based on the proposed allocations. This suggested that 100 dwellings will be completed at Dunton Hills Garden Village in 2022/23. From 2023/24, projected completions fluctuated between 150 and 300 dwellings per annum. Section 2 of our representations considered this in some detail.
2.9 The AFC sets out a revised trajectory to respond to the proposed focussed changes. This shows no change to the number of dwellings projected for DHGV in any year between 2022/23 and 2029/30, and that the first homes (totalling 100 for the year) will still be completed in 2022/23.
2.10 Within our representations on the PSLP we explained that it was wholly unrealistic to suggest that 100 dwellings could be delivered at Dunton Hills Garden Village as soon as 2022/23 (see paragraphs 2.24-2.33). We provided details of two current projects by Arebray Development Consultancy and advised that large strategic sites will take longer to deliver that smaller sites, highlighting a scheme with no major constraints taking 3yrs to deliver the first dwellings after outline permission had been granted. This is supported by other delivery reviews, such as the study by NLP - Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? (November 2016).
2.11 At the time of our PSLP representations, the delivery of DHGV was based on an optimistic assumption that the Brentwood Borough Local Plan would be adopted in 2019. Clearly there is now no such prospect.
2.12 Given the delays to the Local Plan process, and assuming - optimistically - that the Brentwood Borough Local Plan will be adopted in 2020, the trajectory should not show completions at Dunton Hills Garden Village early in the Plan unless robust evidence can be provided to demonstrate that it will come forward quicker than other schemes of comparative size.
2.13 Not only does the above give rise to significant concerns that the PSLP will not ensure housing needs are met in the early years of the plan period, it demonstrates that it would be entirely inappropriate or the AFC to identify DHGV as delivering a greater number of homes by 2033 than the PSLP did. Indeed, the changes proposed in the AFC should have reduced the delivery of homes at DHGV within the Plan period, not increase it.
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Proposed Changes to Dunton Hill Garden Village Delivery Rate
2.14 The housing trajectory within the AFC shows that the number of dwellings per annum to be delivered at Dunton Hills Garden Village will increase from 250 to 275 for 2030/31 and 2031/32, and from 250 to 270 in 2032/33.
2.15 However, no evidence has been presented as justify the increase in projected delivery rate for these years.
2.16 The projected delivery rates for Dunton Hill Garden Village set out within the PSLP were already ambitious - the NLP study referred to above found that the average delivery rate for schemes comprising over 2,000 dwellings was 161 dwellings per annum. Indeed, the analysis shows that the biggest schemes will 'on average,
2.17 deliver fewer than 200 dwellings per annum'. The DHGV proposals would, if realised, exceed the sales rates identified at the Eastern Expansion Area for Milton Keynes (268pa). Specific circumstances for this delivery are explained in a case study within the same report, stating that:
'Serviced parcels with the roads already provided were delivered as part of the Milton Keynes model and house builders are able to proceed straight onto the site and commence delivery. This limited the upfront site works required and boosted annual build rates. Furthermore, there were multiple outlets building-out on different serviced parcels, with monitoring data from Milton Keynes Council suggesting an average of c.12 parcels were active across the build period. This helped to optimise the build rate.' (NLP Start to Finish (November 2016 p.15)
2.18 There is no indication that a similar approach will be taken at DHGV in order to secure such high annual rates of delivery. This is particularly the case from such an early stage in the Plan following adoption for a site that would need to be released from the Green Belt (the rate increases to 250pda in 2024/25 and 300pa from 2026/27, decreasing to 275 in 2030/31).
2.19 The additional increase proposed by the AFC is not justified; is ineffective in ensuring delivery; and risks a shortfall in the timely provision of housing, rendering the Local Plan inconsistent with the NPPF and incapable of being considered positively prepared.
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Delivery of Homes Delayed and Five-Year Housing Land Supply
2.20 There is an acute need for new homes within Brentwood Borough. The provision of new homes within the early years of the plan period is critical.
2.21 As we noted at paragraph 31 of our representations on the PSLP, the Borough is currently significantly short of having a five-year housing land supply as required by the NPPF. It would be wholly inappropriate to delay provision of housing.
2.22 The AFC proposes that the reduction in supply from sites identified as contributing to housing delivery from as early as 2020/21 be compensated for by an increase in the number of new homes to be provided between 2030/31 and 2032/33. In short, upon identifying that fewer homes will be delivered in the early years of the plan period, it is proposed to rectify this through increasing delivery at the end of the plan period. Such an approach is, in our view, wholly inappropriate, and contrary to the NPPF's call to significantly boost the supply of homes.
2.23 We identified within our PSLP representations that the PSLP would not ensure a five-year housing land at all points in the plan period (particularly in the early years). Rather than rectify this defect such that the Local Plan is capable of being found sound, the AFC merely exacerbates this flaw.
Reliance on Dunton Hills Garden Village
2.24 As noted above, the Local Plan is not simply required to provide a strategy for meeting development needs - the NPPF requires it to be sufficiently flexible to be able to respond to rapid change. As such, it is critical that the Local Plan is not overly reliant on a limited number of sites.
2.25 However, the PSLP is heavily reliant on Dunton Hills Garden Village to meet development needs with 34.6% of housing being delivered at the Garden Village, and 44.3% of all allocations. Rather than address this concern, the AFC has simply placed even greater reliance on Dunton Hills Garden Village to meet the Borough's needs with 35.6% of all development at the Garden Village (45.5% of allocations - AFC p.7; amendments to Figure 4.2).
2.26 Such a heavily reliance on a single allocation is neither effective nor consistent with national policy and does not provide flexibility in the Plan. The AFC compounds this failure.
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Summary of Concerns
2.27 The Council acknowledges four proposed sites may not be able to suitably accommodate the numbers previously cited in the PSLP. As such, the Local Plan housing trajectory must be amended to reflect these doubts, and suitable contingency measures should be put in place. Such measures are necessary irrespective of whether or not the policies relating to these four proposed allocations are modified to refer to the quantum of development the Council now consider the sites suitable to accommodate.
2.28 The modifications proposed by the AFC fail to ensure the Local Plan is capable of being found sound. The modifications place further reliance on one site (Dunton Hills Garden Community) to meet development needs, and further reduce the ability of the Local Plan to be able to respond to changing circumstances.
2.29 There is no justification for the suggestion that the delivery rate of Dunton Hills Garden Village can be increased for the three years the AFC suggests, and the number of new homes delivered through this site through the plan period increased. The assumed delivery rate prior to the AFC was already ambitious. In addition, the projected first year for completions is looking increasingly unrealistic given the delays to the Local Plan.
2.30 The AFC acknowledges that fewer dwellings will be delivered by the PSLP in the early years of the plan period, but the proposed increase to compensate for this is not until the end of the plan period, leaving a shortfall in the short term.
2.31 The AFC not only fails to ensure the Local Plan is sound, but it actually exacerbates problems that were present in the PSLP.
2.32 We consider the issues acknowledged within the AFC can be addressed and the PSLP can be made capable of being found sound. We set out the suggested approach to achieving this within Section 4 of this representation.
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3.0 Other Soundness Concerns Resulting from Delays to the Local Plan
3.1 We noted at para 2.11-2.12 of our PSLP representations that the NPPF requires strategic policies to look ahead over a minimum of 15 years from the date of adoption. Within the same paragraphs we noted that an additional 2 years' worth of development should be planned for given the likely timescales for adoption. As the district is predominantly Green Belt and NPPF requires Local Plans to ensure that the Green Belt will endure beyond the plan period, policies should account for needs beyond this period.
3.2 It is now clear that the Local Plan will not be adopted in 2019. As such, the Local Plan's strategic policies are, as currently proposed, falling short of the required period from adoption. This is evidently contrary to the NPPF's requirement to cover a minimum of 15 years. This could have been addressed in the focused changes.
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4.0 Modifications to Address Concerns
4.1 In order to address the issues set out above, it is considered necessary to ensure the Local Plan compensates for the reduction of 70 dwellings that will now not be delivered in the early years of the plan, by identifying whether other suitable, available and deliverable sites are available that could also deliver early in the Plan period. This necessitates identifying additional allocation(s).
4.2 As a site capable of delivering between 24 dwellings (SHLAA Appendix 6; site 67a) and 50 dwellings (SHLAA Appendix 6; Site 67b), Salmonds Grove represents an ideal site to respond to the above.
4.3 As set out within our representations on the Local Plan, the Council already has sufficient evidence to demonstrate that site 67a (and 67b) are suitable, available, and achievable for residential development, either site can be delivered in the short term and an allocation would be justified, effective, consistent with national policy, and contribute towards ensuring the Local Plan is positively prepared.
4.4 It is also essential that the PSLP is amended to ensure the Local Plan will contain strategic policies which cover at least 15 years.
4.5 The above changes are considered to be necessary in relation to the matters addressed by the AFC. Our concerns in respect of the soundness of the PSLP in relation to other matters are set out in our earlier representations.