The vision for Brentwood borough contains a clear understanding of the characteristics of the borough which are worthy of protection and enhancement while at the same time recognizing the need for new development designed to encourage future investment and meet the housing needs for current and future generations.
It is important to firstly recognize and secondly ensure that new development complements the borough's character as a 'borough of villages' set within a high-quality network of green infrastructure, parks and connected green corridors. A clear vision of this kind is enabling the local plan process to assess the development options and all reasonable alternatives against their ability to deliver the vision.
See additional evidence.

The Promoters of DHGV fully support all the strategic objectives and particularly those strategic objectives which aim to set the policy background to delivering and managing a sustainable (SO6-7), well connected (SO4), high quality designed (SO4) and creation of community (SO19-20) form of development, all set within and contributing to a rich connected network of Green Infrastructure (SO17). Assessments carried out so far by the Promoters, with input from a variety of stakeholders have confirmed confidence that DHGV can deliver against these strategic objectives. Further detail is contained in attached representations.

Earlier stages of the local plan process involving consultation and accompanying assessments - contained most particularly in relevant Sustainability Appraisals have presented a logical narrative to the spatial strategy contained in the current Regulation 18 consultation document. As detailed in paragraph 6.3.2 of the Sustainability Appraisal Interim Report January 2018, the option of developing a new community between West Horndon and Basildon has featured in the appraisal of reasonable spatial strategy alternatives within the 2015 and 2016 Interim SA Reports. In our view, the draft spatial strategy is properly set to achieve the Vision and Strategic Objectives of the Plan and has properly considered the various other options for growth. In the case of the contribution to be made by DHGV the Promoters have confidence in being able to deliver the form, scale and timing of development required to make its contribution towards achieving the Spatial Strategy

We welcome the Council's acceptance to prepare a Plan designed to meet the full Objectively Assessed Housing Need (OAHN). The work undertaken by PBA on behalf of the Council and contained in the Strategic Housing Market Assessment Part 1 (January 2018) (SHMA) appears to be a robust and up to date assessment of OAHN. The Council are therefore correct to rely upon this evidence in the current stage of the local plan process.
As stated in paragraph 7.18 of the SHMA though Objectively Assessed Need is not a science. Small changes in input data over time can have significant impacts on the levels of need. The NPPF (paragraph 158) urges Councils in preparing their local plans to ensure they use the most up to date and relevant evidence. We would therefore urge the Council to ensure that the OAHN is monitored closely and kept under review as the later stages of the local plan process progress. In the meantime, we are satisfied that the conclusion to seek to meet the full OAHN of 380 dwellings per annum is robust and a sound element of the current Regulation 18 consultation draft.
We also support the Regulation 18 consultation draft where it properly notes that the Government's proposed standardized objectively assessed housing needs methodology indicates a need for Brentwood to deliver a capped figure of 454 dwellings per annum. The Promoters fully support the Council's approach to recognizing the implications of adopting the standardized methodology and are fully engaged in the Council's appropriate investigation of how DHGV might contribute towards meeting this higher figure. Further comment is contained in paragraph 2.5.4 of these representations.
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The Regulation 18 Plan evidence base requires some further clarification in respect of its assessment of specialist elderly persons accommodation referred to paragraphs 46 - 50. The SHMA Part 2 at paragraphs 6.3 - 6.14 attempts to assess the level of need for specialist elderly persons accommodation within the plan period by using the Strategic Housing for Older People tool developed by the Housing Learning and Improvement Network. In our view, this is a reasonable tool for assessing the likely level of specialist housing requirements for elderly persons in general but because it is, as confirmed in paragraph 6.8 of the SHMA, driven by demographic changes and does not take into account peoples' aspirations it is likely to be less accurate in assessing the level of need for Care Homes in Use Class C2. Paragraph 6.14 of the SHMA Part 2 suggests a need for an additional 424 spaces over the next 20 years. The problem with this demographic only assessment approach is that it is likely to over-estimate the actual need because it fails to take into account the traditional desire of elderly people to avoid taking accommodation in an institutional care home and also fails to recognize the greater variety of specialist housing options now available which are designed to allow elderly people to maintain their independence for longer. The HAPPI Spectrum published by the Housing our Ageing Population: Panel for Innovation (HAPPI) identifies a range of options which are available as specialized housing where personal care and support can be arranged or provided within the development together with shared facilities and activities. These include sheltered retirement homes, very sheltered homes, extra care housing, retirement villages and close care facilities.
Paragraph 72 of the Regulation 18 Plan suggests the provision at DHGV of "two large [care] homes -204 beds in total". While the Promoters do not object to the principle of providing elderly persons accommodation on site - indeed it is welcomed as part of creating an inclusive community - before committing to policy a precise provision requirement for two large care homes it will be important to be clear about the level and type of need. Alternatively, our recommendation would be to maintain flexibility and include in policy a requirement to provide specialist accommodation for the ageing population. Such flexibility would allow the Promoters and the Council to assess properly the level and type of requirements at the time of application submission and appropriately integrate that housing with the community. If, on the other hand, further detailed assessment or clarification of need and accommodation type is gathered then inclusion into the allocation policy would be entirely acceptable.
The Promoters are currently assessing the ability of DHGV to accommodate specialist pitches for Gypsy and Traveller households. It is noted that in Fig 13 of the Regulation 18 Plan DHGV has been identified in Step 6 of a sequential testing exercise for consideration of a possible 30 (approx) pitches. We are not yet convinced by the available evidence that sufficient need has been identified to justify the accommodation of this number of pitches, or in the DHGV location. Firstly, the Gypsy and Traveller Accommodation Assessment (October 2017) identifies a need within the borough for only 12 additional pitches for Gypsy and Traveller households which meet the planning definition contained in the Planning Policy for Traveller Sites. There is no explanation of why the Plan seeks to identify accommodation of additional pitches for households which do not meet the planning definition. Secondly, the Promoters are not persuaded that DHGV is a suitable location for such a large concentration of pitches, particularly in view of the fact that the sequential test has identified other more suitable sites to meet the need.

In our view, the Council has undertaken a robust and sound assessment of housing land supply and have continued to ensure that the evidence base is as up to date as possible and proportionate to the relevant stage of Local Plan preparation.

The Promoters of DHGV support the identification of DHGV as the principal strategic housing led allocation and believe that the site is both suitable and deliverable.
See additional documents and representations under Part 2 of the Plan.

The Promoters of DHGV fully support the need to provide a variety of house types including those suitable for specialist elderly persons accommodation. The precise nature of elderly persons accommodation requires further assessment before inclusion of references in policy to a prescriptive form of accommodation.
See additional documents and reference under Specialist Accommodation Needs.

The Promoters of DHGV are not persuaded of either the need for or the suitability of DHGV as a suitable location for a large concentration of Gypsy and Traveller pitches, particularly in view of the fact that the sequential test has identified other more suitable sites to meet the need.
See additional documents and reference under Specialist Accommodation Needs.

See additional documents