Object

Representation ID: 15309

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The housing completions have been below target since 2012 and are unlikely to meet the new target until 2018, a projection that we would regard at best as hopeful. We believe the problem stems partly from promotion of sites by the Council through the Local Plan process that either have little hope of being implemented or at least are subject to serious constraints. We believe the Local Plan as it stands runs a serious risk of being found unsound against national policy as set out in the NPPF's paragraphs 14 and more recent Central Government advice.

Object

Representation ID: 15311

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The A12 is a principal route for large lorries running to and from the port of Felixstowe, it also carries high volumes of car traffic. It is bad planning to allocate land for new housing in such close proximity to a major source of air pollution in Brentwood.

Among the recommendations made in "Every Breath We Take" is the following:
"Protect those most at risk. Children, older people, and people with chronic health problems are among the most vulnerable to air pollution. Public services must take account of this sproportionate harm through local tools such as planning policies for housing and schools ..."

Comment

Representation ID: 15312

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Site 159 at Crow Green Lane is relatively small, with a capacity of up to 70 or so dwellings together with local community infrastructure. The site's benefits include:

a sustainable location in terms of access to existing local community and commercial facilities including schools
 well served by existing public transport services
 situated immediately adjacent to an established residential area
 site has wholly defensible boundaries
 can be serviced by the utilities
 appropriate site access, as discussed with the Council's Highways
 does not flood
 one ownership
 readily available
 readily achievable
 and therefore ideally suitable.

Comment

Representation ID: 15313

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Policy 7.2 as drafted sets out a self-build requirement for sites with capacity of 100 or more dwellings.

Site 159, despite having a smaller capacity, but the provision of some plots for self or custom builders would be something the owner is willing to explore.

Comment

Representation ID: 15314

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

There are uncertainties surrounding the provision of affordable housing as a result of proposed changes to national policy

The owner is willing to include a good proportion of affordable housing in developing Crow Green Lane site (159), even a higher level than the minimum requirement, provided that development of the whole site remains financially viable.

Comment

Representation ID: 15315

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Figure 5.11 covers the period 2016 to 2033, but it would have been more logical for it to cover the whole of the plan period, namely 2013 to 2033.

Appendix 3 sets out projected housing completions on a year by year basis. However, Appendix 3 only includes 18 of the 22 allocated sites listed in Appendix 2. We assume that the Housing Trajectory shown at Figure 5.11 includes the four allocations missing from Appendix 3, and has allocated them on a year by year basis.

Comment

Representation ID: 15316

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Appendix 3 sets out projected housing completions on a year by year basis. However, Appendix 3 only includes 18 of the 22 allocated sites listed in Appendix 2. Missing are:

 Dunton Hills Garden Village - 2500 dwellings
 Victoria Court, Victoria Road, Brentwood - 40 dwellings
 Baytree Centre, Brentwood - 200 dwellings
 Ingatestone Garden Centre - 60 dwellings.

Object

Representation ID: 15317

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The other strategic greenfield sites, Officer's Meadow, Shenfield; Honeypot Lane, Brentwood; and Nags Head Lane, Brentwood, are all included in Appendix 3's Housing Trajectory. All are shown as starting delivery in 2018. This is less than two years from now and, in our opinion, it is unlikely that delivery from these sites will start much before end of 2020, beginning of 2021.

Object

Representation ID: 15318

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The Doddington Road site is programmed to start delivery in 2020. We have objected strongly to this allocation in past consultations, as the land lies astride a major trunk road, the A12.

Object

Representation ID: 15319

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

It is the smaller allocations that are likely to make an early contribution to meeting what is already a significant housing shortfall in Brentwood Borough. The last Five Year Deliverable Housing Supply Assessment, published in June 2014, recorded a 4.3 year supply, well below the level required by the NPPF.