Object

Representation ID: 19877

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The Draft Plan included the industrial estates at West Horndon as proposed brownfield housing land allocations. However, the Ford Offices at Eagle Way, Warley was scheduled as an employment land allocation, where redevelopment or changes of use for non Class B uses would be permitted only in certain defined circumstances. Both sites are now preferred housing allocations.

Object

Representation ID: 19878

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

This appears to be a new site. Pub closures have been, and continue to be, a potential source of brownfield housing land. However, we think these should be regarded as windfall sites, rather than specific land allocations. The Eagle and Child is a small site (20 units). The site details note a potential business loss or relocation, this suggests the pub is still in use. Taken together with the reported existing lag of starts behind permissions already granted, it seems that there is some uncertainty about its coming forward, despite the site assessment's forecast of "early delivery".

Object

Representation ID: 19879

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Our principal concern is the uncertainty surrounding a number of these brownfield sites and the consequences for an early boost to the current serious undersupply of available housing land.

Object

Representation ID: 19880

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Site 186 was not shown as a brownfield site with potential in the 2011 SHLAA. The details for site 186 note that it was formerly used by the National Blood Service.

Comment

Representation ID: 19881

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Town centre redevelopments are complex and influenced by many factors. Whilst developments on Baytree Centre and William Hunter Way will probably happen, their timing must remain uncertain.

Object

Representation ID: 19882

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The LPA's reply set out four main reasons to explain why it has taken so long to produce a
Local Plan:
Brentwood's Green Belt location
Historic completion rates
Revisions of the OAHN
Dunton Hills Garden Village proposal
The LPA's full response mentions the need for public consultation on a Green Belt Assessment following recent legal advice. There was nothing to stop the LPA from carrying out such an assessment when the local plan process started. Given Borough's location entirely within the Metropolitan Green Belt, it is surprising that this was not one of the very first evidence collecting operations.

Object

Representation ID: 19883

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

It seems that the LPA has placed an undue reliance on brownfield sites coming forward in the hope that this would leave Green Belt land largely untouched. The fact that many of the brownfield sites being considered back in 2009, nearly 10 years ago, have reappeared in this current consultation demonstrates how far this reliance was mistaken.

Object

Representation ID: 19884

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Historic completion rates is not an excuse for failing to produce a local plan. The lack of new building in Brentwood is unlikely to be the consequence of lack of demand as the LPA's own comments but more likely the result of a lack of suitable sites or that sites that have been given permission have proved difficult to develop. Although the LPA makes much of an increasing gap between planning permissions given and the level of completions, the latest assessment of the supply of land available for housing development is 2.67 years, well below the NPPF's 5 year requirement.

Object

Representation ID: 19885

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

The LPA's full response to the Secretary of State relies heavily on the proposed Dunton Hills Garden Village proposal to speed up housing delivery within the District. It is hoped that this proposal will provide a minimum of 30% of Brentwood's housing needs during the plan period. We regard this as an optimistic assumption, to say the least. This is a joint project with another LPA; it will be reliant on the effective co-ordination of many different partners; and it will not have the type of powers and mechanisms that were available to the new towns to ensure delivery.

Comment

Representation ID: 19886

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Given the problems that remain with the delivery of brownfield sites in the District, reflected in recent housing completion rates, and the high level of reliance that the LPA is placing on Dunton Hills Garden Village, it is imperative to re-consider a modest release of Green Belt land. Otherwise it will be impossible in either the short or medium term to lift the current supply of available land from the current 2.67 years to the 5 years required by the NPPF.