Allocate additional site to delivery at least 70 additional homes in the early years of the plan period (2022/23 - 2024/25). Site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above

1.0 Introduction and background
1.1 This representation on the Brentwood Borough Council's Addendum of Focussed Changes to the Pre Submission Local Plan (AFC) is made by Strutt & Parker on behalf of Turn2Us.
1.2 Turn2Us is a national, registered charity with a mission to fight poverty in the UK and Ireland, helping individuals who are struggling financially to gain access to financial help. Each year the charity assists several million people in a range of different ways. It has seen a steady increase in the number of people turning to the charity for help in recent years. The charity receives no Government funding. It is through donations and legacies that it raises funds, and the charity is committed to ensuring long-term financial sustainability
1.3 Turn2Us is the freeholder of the majority of the area of land between Hutton Village, Rayleigh Road and Church Lane. A small portion of this land, located immediately adjacent to the existing settlement and adjoining Rayleigh Road and Hutton village, measuring 2.4 ha is being actively promoted by Turn2Us for residential allocation in the Council's new Local Plan.
1.4 Strutt & Parker have made representations on the Brentwood Borough Pre-Submission Local Plan (February 2019) (PSLP) on behalf of Turn2Us and in relation to this land at Rayleigh Road, Hutton (site reference 219 in the Council's plan-making process).
1.5 Concerns regarding the soundness of the PSLP set out in our representations made remain, but are not repeated here to avoid duplication.
1.6 This representation focuses on the proposed focussed changes to the PSLP, set out in the consultation draft of 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";
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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".
1.7 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).
1.8 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 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).
1.9 We 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.
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.
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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 as to what may be delivered.
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.
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.
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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 Dunton Hills Garden Village 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 (see paragraphs 35-38) 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. At the time of our PSLP representations, it was based on an optimistic assumption that the Brentwood Borough Local Plan would be adopted in 2019. Clearly there is now no such prospect. Indeed, given the current stage in the process and the extent of delays, even adoption before the end of 2020 would now be challenging.
2.11 The PSLP proposes that Dunton Hills Garden Village will comprise around 4,000 dwellings (2,700 to be delivered by 2033). A study by NLP (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? (November 2016)) reviewed 70 strategic sites which have delivered / will deliver more than 500 dwellings. The study reviewed sites varied in size (from 504 to 15,000 dwellings) and location. The study identified that the average planning approval period for schemes comprising more than 2,000 dwellings was 6.1 years. Following planning approval, the study found that a period of 0.8 years could be expected before the first completions on such sites. In short, it would be appropriate to allow for a period of 7 years from anticipated first planning application before first completions. Indeed, given the NPPF requirement to ensure a flexible strategy, it would be prudent to allow for longer.
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 until 2027/28 at the earliest, 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 wholly inappropriate to assume Dunton Hills Garden Village will accommodate an even greater number of dwellings by 2033 than the PSLP did.
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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 previously found that the average delivery rate for schemes comprising over 2,000 dwellings was only 161 dwellings per annum.
2.17 The further 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.
Delivery of homes delayed and five-year housing land supply
2.18 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.
2.19 As we noted at paragraph 31 of our representations on the PSLP, the Borough currently is 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.
2.20 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.
2.21 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).
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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
2.22 As noted early within this representation, 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.
2.23 As such, it is critical that the Local Plan is not overly reliant on a limited number of sites.
2.24 However, the PSLP placed great reliance on Dunton Hills Garden Village to meet development needs.
2.25 Rather than address this concern, the AFC has simply placed even greater reliance on Dunton Hills Garden Village to meet the Borough's needs.
2.26 Such reliance on a single scheme is neither effective nor consistent with national policy.
Specialist accommodation for an ageing population
2.27 Proposed allocation R19 is one of the sites the Council has revised down the projected capacity of. In the case of R19, down from 75 to 45 dwellings. The AFC states that the reasons for the reduction in projected contribution from this site include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitat impacts; and flooding.
2.28 The PSLP also suggested that there was "potential" for proposed allocation to accommodate a care home of around 40 beds. As noted in our PSLP representations, the PSLP provides little confidence there is reasonable prospect of a care home being delivered through development of this site.
2.29 In light of the additional concerns now set out in the AFC, prospects of provision of specialist accommodation to meet the needs of older people are further diminished.
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Overview
2.30 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.
2.31 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.
2.32 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.
2.33 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.
2.34 The AFC does not address the potential implications for the provision of accommodation for older people in light of the concerns it has identified in respect of proposed allocation R19. It neither explains why the site's potential to accommodate a care home is unaffected by the concerns it identifies, nor propose anything to address potential shortfall of this form of specialist accommodation assuming its potential to be provided here is affected.
2.35 The AFC not only fails to ensure the Local Plan is sound, but it actually exacerbates problems that were present in the PSLP.
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2.36 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.
3.0 Other soundness concerns resulting from delays to the Local Plan
3.1 As we noted in our PSLP representations (paragraph 12) the NPPF requires strategic policies to look ahead over a minimum of 15 years from the date of adoption. Within the same paragraph we noted that even assuming (optimistically) adoption of the Local Plan in 2019, the PSLP would only cover a 14-year period and as such does not conform to national policy.
3.2 It is now clear that the Local Plan will not be adopted in 2019. Adoption before the end of 2020 is considered optimistic. Before the end of 2021 is more realistic. As such, the Local Plan's strategic policies would - as currently proposed - only last for 13 years at best; more likely, they would cover a 12-year period from adoption.
3.3 This is evidently contrary to the NPPF's requirement to cover a minimum of 15 years.
4.0 Curing defects
4.1 In order to address the issues set out within this representation, it is necessary to ensure the Local Plan compensates for the reduction of 70 dwellings to be delivered in the early years of the plan period resulting from the revised capacity assessment of four proposed allocations in an effective and justified manner, and one which ensures the Local Plan is consistent with national policy and positively prepared. In this instance, this necessitates identifying additional allocation(s) which:
a) Together, in total, will deliver at least 70 additional homes; and
b) Can deliver this number of homes in the early years of the plan period (2022/23 - 2024/25).
4.2 Furthermore, additional allocations should also include those which will contribute towards meeting the accommodation needs of older people, given that the Council has identified concerns relating to a proposed allocation in which the PSLP states there is potential for a care home.
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4.3 As a site capable of delivering approximately 60 homes along with extra care accommodation (Use Class C2), allocation of site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above.
4.4 As set out within our representations on the Local Plan, the Council already has sufficient evidence to demonstrate site 219 is suitable, available, and achievable for residential development along with extra care accommodation; can be delivered in the short term; and that its allocation would be justified, effective, consistent with national policy, and contribute towards ensuring the Local Plan is positively prepared.
4.5 In addition, and separately, it is imperative to amend the PSLP to ensure the Local Plan will contain strategic policies which cover at least 15 years. As such, the plan period should be extended to 2036 and modifications proposed to ensure development needs for this period are addressed.
4.6 For the avoidance of doubt, the above actions are considered necessary in relation to the matters addressed by the AFC. We have identified separate and additional concerns (along with suggested actions to cure such defects) in respect of the soundness of the PSLP as a whole within our previous representations made at the appropriate time. These concerns remain.

Allocate additional site to delivery at least 70 additional homes in the early years of the plan period (2022/23 - 2024/25). Site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above.

1.0 Introduction and background
1.1 This representation on the Brentwood Borough Council's Addendum of Focussed Changes to the Pre Submission Local Plan (AFC) is made by Strutt & Parker on behalf of Turn2Us.
1.2 Turn2Us is a national, registered charity with a mission to fight poverty in the UK and Ireland, helping individuals who are struggling financially to gain access to financial help. Each year the charity assists several million people in a range of different ways. It has seen a steady increase in the number of people turning to the charity for help in recent years. The charity receives no Government funding. It is through donations and legacies that it raises funds, and the charity is committed to ensuring long-term financial sustainability
1.3 Turn2Us is the freeholder of the majority of the area of land between Hutton Village, Rayleigh Road and Church Lane. A small portion of this land, located immediately adjacent to the existing settlement and adjoining Rayleigh Road and Hutton village, measuring 2.4 ha is being actively promoted by Turn2Us for residential allocation in the Council's new Local Plan.
1.4 Strutt & Parker have made representations on the Brentwood Borough Pre-Submission Local Plan (February 2019) (PSLP) on behalf of Turn2Us and in relation to this land at Rayleigh Road, Hutton (site reference 219 in the Council's plan-making process).
1.5 Concerns regarding the soundness of the PSLP set out in our representations made remain, but are not repeated here to avoid duplication.
1.6 This representation focuses on the proposed focussed changes to the PSLP, set out in the consultation draft of 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";
2
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".
1.7 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).
1.8 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 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).
1.9 We 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.
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.
3
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 as to what may be delivered.
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.
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.
4
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 Dunton Hills Garden Village 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 (see paragraphs 35-38) 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. At the time of our PSLP representations, it was based on an optimistic assumption that the Brentwood Borough Local Plan would be adopted in 2019. Clearly there is now no such prospect. Indeed, given the current stage in the process and the extent of delays, even adoption before the end of 2020 would now be challenging.
2.11 The PSLP proposes that Dunton Hills Garden Village will comprise around 4,000 dwellings (2,700 to be delivered by 2033). A study by NLP (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? (November 2016)) reviewed 70 strategic sites which have delivered / will deliver more than 500 dwellings. The study reviewed sites varied in size (from 504 to 15,000 dwellings) and location. The study identified that the average planning approval period for schemes comprising more than 2,000 dwellings was 6.1 years. Following planning approval, the study found that a period of 0.8 years could be expected before the first completions on such sites. In short, it would be appropriate to allow for a period of 7 years from anticipated first planning application before first completions. Indeed, given the NPPF requirement to ensure a flexible strategy, it would be prudent to allow for longer.
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 until 2027/28 at the earliest, 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 wholly inappropriate to assume Dunton Hills Garden Village will accommodate an even greater number of dwellings by 2033 than the PSLP did.
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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 previously found that the average delivery rate for schemes comprising over 2,000 dwellings was only 161 dwellings per annum.
2.17 The further 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.
Delivery of homes delayed and five-year housing land supply
2.18 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.
2.19 As we noted at paragraph 31 of our representations on the PSLP, the Borough currently is 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.
2.20 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.
2.21 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).
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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
2.22 As noted early within this representation, 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.
2.23 As such, it is critical that the Local Plan is not overly reliant on a limited number of sites.
2.24 However, the PSLP placed great reliance on Dunton Hills Garden Village to meet development needs.
2.25 Rather than address this concern, the AFC has simply placed even greater reliance on Dunton Hills Garden Village to meet the Borough's needs.
2.26 Such reliance on a single scheme is neither effective nor consistent with national policy.
Specialist accommodation for an ageing population
2.27 Proposed allocation R19 is one of the sites the Council has revised down the projected capacity of. In the case of R19, down from 75 to 45 dwellings. The AFC states that the reasons for the reduction in projected contribution from this site include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitat impacts; and flooding.
2.28 The PSLP also suggested that there was "potential" for proposed allocation to accommodate a care home of around 40 beds. As noted in our PSLP representations, the PSLP provides little confidence there is reasonable prospect of a care home being delivered through development of this site.
2.29 In light of the additional concerns now set out in the AFC, prospects of provision of specialist accommodation to meet the needs of older people are further diminished.
7
Overview
2.30 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.
2.31 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.
2.32 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.
2.33 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.
2.34 The AFC does not address the potential implications for the provision of accommodation for older people in light of the concerns it has identified in respect of proposed allocation R19. It neither explains why the site's potential to accommodate a care home is unaffected by the concerns it identifies, nor propose anything to address potential shortfall of this form of specialist accommodation assuming its potential to be provided here is affected.
2.35 The AFC not only fails to ensure the Local Plan is sound, but it actually exacerbates problems that were present in the PSLP.
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2.36 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.
3.0 Other soundness concerns resulting from delays to the Local Plan
3.1 As we noted in our PSLP representations (paragraph 12) the NPPF requires strategic policies to look ahead over a minimum of 15 years from the date of adoption. Within the same paragraph we noted that even assuming (optimistically) adoption of the Local Plan in 2019, the PSLP would only cover a 14-year period and as such does not conform to national policy.
3.2 It is now clear that the Local Plan will not be adopted in 2019. Adoption before the end of 2020 is considered optimistic. Before the end of 2021 is more realistic. As such, the Local Plan's strategic policies would - as currently proposed - only last for 13 years at best; more likely, they would cover a 12-year period from adoption.
3.3 This is evidently contrary to the NPPF's requirement to cover a minimum of 15 years.
4.0 Curing defects
4.1 In order to address the issues set out within this representation, it is necessary to ensure the Local Plan compensates for the reduction of 70 dwellings to be delivered in the early years of the plan period resulting from the revised capacity assessment of four proposed allocations in an effective and justified manner, and one which ensures the Local Plan is consistent with national policy and positively prepared. In this instance, this necessitates identifying additional allocation(s) which:
a) Together, in total, will deliver at least 70 additional homes; and
b) Can deliver this number of homes in the early years of the plan period (2022/23 - 2024/25).
4.2 Furthermore, additional allocations should also include those which will contribute towards meeting the accommodation needs of older people, given that the Council has identified concerns relating to a proposed allocation in which the PSLP states there is potential for a care home.
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4.3 As a site capable of delivering approximately 60 homes along with extra care accommodation (Use Class C2), allocation of site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above.
4.4 As set out within our representations on the Local Plan, the Council already has sufficient evidence to demonstrate site 219 is suitable, available, and achievable for residential development along with extra care accommodation; can be delivered in the short term; and that its allocation would be justified, effective, consistent with national policy, and contribute towards ensuring the Local Plan is positively prepared.
4.5 In addition, and separately, it is imperative to amend the PSLP to ensure the Local Plan will contain strategic policies which cover at least 15 years. As such, the plan period should be extended to 2036 and modifications proposed to ensure development needs for this period are addressed.
4.6 For the avoidance of doubt, the above actions are considered necessary in relation to the matters addressed by the AFC. We have identified separate and additional concerns (along with suggested actions to cure such defects) in respect of the soundness of the PSLP as a whole within our previous representations made at the appropriate time. These concerns remain.