None proposed

Re: Land at Blackmore Road (R23) & Land at Stocks Lane (R24)

We welcome the opportunity to submit representations to the above consultation on behalf of Stonebond
Properties Ltd. Stonebond are in control of two sites identified in the Pre-Submission Local Plan, which
includes the Land at Blackmore Road (ref: R23) Land at Stocks Lane (ref: R24). This submission to the
Consultation on the Addendum of Focussed Changes (AFC) is made having regard to representations
submitted at the Regulation stage consultation in March 2019 in respect of both of these sites in so far as the
Addendum has relevance and supports the comments made at that stage.

Previous representations

Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019,
and set out proposed amendments to the wording of the policies associated with the sites proposals to
increase the stated capacity of the sites, as well as amendments to the site boundary of the Blackmore Road
site.

Included with this submission is the further information that was supplied to the Council on 2
September
2019 for the consideration by Policy Resources and Economic Development Committee on 11
nd
September.
The purpose of this additional information was to suggest to the Council that R23 and R24 can accommodate
additional dwellings, over and above the stated yield within the Pre-Submission Local Plan. For ease of
reference, extracts are provided below which illustrate that the sites combined and with the changes sought
could deliver around 42 more homes in total than that currently set out in the Regulation 19 Local Plan:

The information submitted to the Council was intended to promote an opportunity for possible amendments
to the Local Plan before submission for Examination which could have been considered as part of this focused
consultation and it is regrettable that this was not considered acceptable.

The AFC does not respond to any of the recommendations made in the previous representations, nor any of
the proposals set out in the additional information provided to the Council and attached. This representation
reiterates the opportunity for the two sites at Kelvedon Hatch to make a meaningful contribution to
Brentwood's housing needs, particularly to assist in early delivery of homes in the Plan period.

Focused changes

It is acknowledged that the Council are seeking representations focussing on the AFC only with the most
notable change is the reduction in units to be provided by sites R18 and R19 in Shenfield and R25 and R26
in Blackmore, as set out below;

a) 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";
b) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around
35 homes";
c) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45
homes";
d) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to
around "30 homes"; and
e) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to
"around 20".

The AFC explains that the modifications proposed result from a review of consultation responses on the PreSubmission
Local
Plan
on
the
proposed
allocations
R18,
R19,
R25
and
R26,
necessitating
a
reduction
in
the

number
of
homes
for
these
proposed
allocations
(Focussed
Changes
2-5).



The
AFC
proposes
that
the
total
loss
of
70
homes
across
the
four
sites
will
be
off-set
through
an
increase
in

the
number
of
new
homes
to
be
provided
at
Dunton
Hill
Garden
Village
(Focussed
Change
1).

The
AFC

confirms
that
the
overall
number
of
new
homes
will
not
be
increased,
but
that
there
will
be
a
faster
rate
of

delivery

at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than
previously projected (resulting in fewer post-2033).

Representations

Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield,
we do consider that the AFC is a missed opportunity to review the capability of other sites proposed for
allocation in the Local Plan to accommodate the units to be lost at those sites rather than simply adding to
the allocation at Dunton Hills Garden Village.

To support our representations, we draw attention to requirements of the National Planning Policy Framework
(NPPF) that Plans should;

 provide a strategy to meet housing needs with sufficient flexibility to be able to respond to rapid change
(para 11) and
 Housing requirements are to be considered as minimum (para 60).
 Acknowledge the role of small and medium sites to contributing to meeting the housing requirement
(para 68)
 Make efficient use of land (paras 11, 122, and123).

Our submitted representations supporting the allocations for R23 and R24 at pre-submission stage in March
made the case that the medium sized sites at Blackmore Road and Stocks Lane can accommodate a modest
increase in the number of additional dwellings on these sites in line with the Council's spatial strategy.

We note that Appendix 1 to the AFC provides an updated housing trajectory based on the proposed
allocations. For R23 and R24 it indicates that delivery will commence 2021/22. In our representations to the
Pre-Submission Local Plan we indicated that both sites can come forward in 2020 with the delivery of 20 units
to assist the Council's shortfall in 5-year housing supply.

Reviewing Appendix 1, we have reservations that Dunton Hills Garden Village will deliver the number of
homes as soon as 2022/23. Furthermore, reliance on the site for delivery would not provide for flexibility or
acknowledge the role of smaller or medium sites in contributing to early delivery.
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. 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, it is identifying that fewer homes will
be delivered in the early years of the plan period and it is proposed to rectify this through increasing delivery
at the end of the plan period. Such an approach is, in our view inappropriate, and contrary to the NPPF's call
to significantly boost the supply of homes. This makes the early delivery of sites such as R23 and R24 entirely
credible and our proposals for the modest increase in homes that can be delivered is important to the identified
housing requirement.

Summary

This letter has set out our views on the focussed changes to the Draft Local Plan, with particular emphasis
on the role that the identified sites at Land of Stocks Lane and Land of Blackmore Road (R24 & R25
respectively) can assist the Council in meeting its requirements ahead of the Local Plan Examination.

As set out in this letter, we are responding to the contents of the AFC and specifically the housing trajectory
and redistribution of housing as identified. To support our comments, we are resubmitting the representations
previously made with regard to the two site's under Stonebond's control in Kelvedon Hatch. We reiterate
points made at Pre-submission stage that both of these sites can accommodate additional homes above the
number they are identified to assist the Council in meeting its requirement for new housing at early stages of
the Plan period, which is of critical importance given the position with the Council's 5 year housing land supply
shortfall.

Furthermore, the Pre-submission stage was prepared before publication of the revised NPPF in February
2019 which introduced important changes to the approach to identifying housing land supply and greater
emphasis on the efficient use of land. Both of these matters clearly indicate that our proposals for R23 and
R24 would be compatible with national planning policy objectives and provide justification for a review of
capacity of these sites and confirmation for early delivery against the issues we identify with the both the
timing of supply and redistribution of housing set out in the AFC.

We would welcome further liaison with the Council regarding the opportunities expressed in this and our
previous representations as the Local Plan proceeds to the examination stage. In particular, we would be
more than happy to present to the Examination a Statement of Common Ground (SoCG) with the Council to
reflect our proposals. The SoCG would confirm that sites R23 and R24 are available, suitable, and sustainable
to aid the Council to confirm certainty of early delivery. We believe that our proposals also provide for flexibility
in sources of supply to assist in the housing land requirement for the Borough.

I would be grateful to receive acknowledgment of this representation. If you require any further information,
please do not hesitate to get in touch.

Yours sincerely,
Andy Butcher