The land at Priests Lane (R19) should be removed from the Local Development Plan.

Evidence base flawed.
> Transport Assessment did not include traffic along Priests Lane, despite assurances from the Council that a traffic assessment would be done. Done at a time which did not include greatest flow of school traffic.
> There will be an increase in traffic from the proposed development of 1,000 houses in Shenfield travelling to the A127 and this has not been taken into account.
The impact of Crossrail also not taken into account.
> Proposed new road accesses from Priests Lane inappropriate and hazardous, as Priests Lane narrow and not designed for an increase in traffic. Already severely congested at peak times and potentially dangerous.
> The site does not meet relevant sustainability conditions: access, transport network, mitigation of impact on local services, increased pollution and resulting effect on health.
> Junction of Middleton Hall Lane and Priests Lane already a pollution hotspot; no account has been made of this.
> Priests Lane was never intended to be a main distributary artery, which it has now
become. Residents have pointed out that as such it does not comply with the Essex design guide with respect to road and pavement width.
Local Plans should address not only housing but also traffic concerns, healthcare and
education needs to be NPPF Compliant.
> The Sustainability review refers to traffic as a concern, but no mitigation options have been identified.
> there is a lack of provision for developing the required infrastructure for health and education needs as a result of the proposed developments. This will lead to even greater traffic congestion and pollution.
The land at Priests Lane should be removed from the Local Development Plan.

No specific amendment proposed.

This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Local Plan Regulation 19 public consultation.
Please be advised that for all of the consultation points below, the Council would like to attend the future oral hearings as part of the Plan's Examination in Public.
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for the Basildon Borough that may arise from Brentwood Borough Council's Local Plan and determine whether it considers it to be compliant with necessary legislation and whether it meets the tests of soundness.
1) Is the Brentwood Borough Local Plan 2016-2033 legally compliant?
The Council has reviewed the Brentwood Borough Local Plan 2016-2033 and supporting documents. It considers that whilst it disagrees with aspects of the Plan from a soundness perspective that it is however legally compliant.
2) Does the Brentwood Borough Local Plan 2016-2033 meet the tests of soundness?
The Council does not believe that the Brentwood Borough Local Plan 2016-2033 meets the tests of soundness in all of its policy areas. It therefore makes the following 1 representation in support of an aspect of the Plan and 17 representations where it considers the Local Plan is unsound and requires modifications to make it sound.
Supporting Representations
Consultation Point: Chapter 1
Soundness - Effectiveness & Compliance with National Policy
Paragraph 26 of the National Planning Policy Framework (NPPF) asserts that effective and on-going joint working between strategic policymaking authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, it considers that joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. To demonstrate effective and on-going joint working, strategic policy-making authorities should
planning.policy@brentwood.gov.uk
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prepare and maintain one or more Statements of Common Ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these.
A major step forward for effective cooperation has been the Memorandum of Understanding that was signed between Basildon, Brentwood, Castle Point, Essex County, Rochford, Southend-on-Sea and Thurrock Councils to form the ASELA. This has ensured that there is now a more coordinated, collective working on a 'place vision' for the sub region, which recognises one of the key delivery tools will be a statutory Joint Strategic Plan (JSP). A Statement of Common Ground has also been agreed between the ASELA to ensure it is embedded into the Local Development Schemes of all the local planning authorities with resources committed to its preparation during 2019/2021. This will ensure it sets the foundations for planning at a broader spatial level, determining how growth and infrastructure can be better coordinated to positively influence place-making in South Essex and provide a more prosperous area for people to live, work, study and visit. The Statement of Common Ground recognises that the planning landscape of South Essex is not perfect and not all authorities can wait for the JSP to be completed before their Local Plans are advanced. It accepts that the JSP will have to be mindful, in particular of Basildon, Brentwood and Castle Point's and the reality that their Local Plans are already too advanced to be paused.
The Council has noted Brentwood Council's commitment in paragraph 1.13 to work as a member of ASELA on a process to develop a long-term growth ambition that would underpin strategic spatial, infrastructure and economic priorities across the wider sub-region. It is acknowledged that this is in accordance with the South Essex JSP Statement of Common Ground - June 2018; of which Basildon and Brentwood Borough Councils are one of the seven joint signatories.
Work on the JSP is at an early stage with Regulation 18 consultation due to take place during 2019, followed by Regulation 19 in 2020, with examination in public and adoption not expected to be until 2020/2021. It will cover a longer plan period extending to 2038; slightly longer than both the Basildon and Brentwood Local Plans. Paragraph 1.38 of the Brentwood Borough Local Plan references that its own allocations can contribute towards some of the delivery of early growth during the JSP plan-period; a position that is also applicable for the soon to be submitted Basildon Borough Local Plan 2014-2034. It is welcomed that the Brentwood Borough Local Plan has mirrored the intent of the Basildon Borough Local Plan in Paragraphs 1.35-1.38 that following the adoption of the JSP, it may be necessary to review the Plan, at least in part, to ensure any opportunities for additional growth and infrastructure provision in the Borough, that may otherwise be additionally identified in the JSP, can be realised. The Council fundamentally supports this policy approach as meeting the soundness tests of being a) effective and b) in accordance with national policy.
The Council considers this to be compatible to its own position and underpins the collective efforts to get an "effective mechanism" in place to address strategic, cross boundary matters in a more holistic and planned manner that has greater potential to realise positive outcomes to South Essex communities. Looking ahead, the Council embraces the opportunity presented by Brentwood Borough Council being part of the ASELA and the JSP, in order to tackle strategic, cross-boundary matters holistically to ensure sustainable growth solutions are achieved that benefit all communities.
Objecting Representations
Consultation Point: Whole Plan
Soundness - Effectiveness, Justified & Compliance with National Policy
Paragraph 26 of the National Planning Policy Framework (NPPF) asserts that effective and on-going joint working between strategic policymaking authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. The Council, as a neighbouring Borough and Duty to Cooperate body, has reviewed and considered previous versions of the Local Plan and its preparatory documents and submitted relevant representations under Regulation 18 consultations. The Council formally wishes to express its disappointment that given fundamental
evidence has been 'in development', but not published during much of its preparation. It has been significantly difficult, therefore, to digest the Plan's rationale and approach as it has evolved. This includes the entire Green Belt Review, Housing and Economic Land Availability Assessment, Landscape Sensitivity and Capacity Study, Local Plan Viability Assessment and Transport Assessment which were not published until the month before Brentwood Council considered the Publication Local Plan in November 2018. It is accepted that not all evidence can be completed by each consultation stage and much may remain as a continual draft until Regulation 19, however it is considered this has created a lack of transparency during critical plan-making stages and contributed to the scale of representations from Basildon Council for its Regulation 19 response.
During 2017/2018, officers from Basildon, Thurrock and Essex County Councils, facilitated by an officer from Rochford District Council, jointly sought to understand and address with Brentwood Borough Council how the Brentwood Borough Local Plan, in particular the Dunton Hills Garden Village (DHGV) strategic allocation, could impact on neighbouring authority areas, particularly in terms of infrastructure and service provision. Meetings were held, and correspondence exchanged, in an effort to seek solutions and resolutions to previous Regulation 18 objections/ observations from all three Councils. The intention was to appreciate the evidenced rationale for identifying the DHGV strategic allocation and ensuring neighbouring authorities could engage more effectively to identify and manage cross-boundary impacts. Despite this engagement, it is considered that not all information and assurances sought from Brentwood Borough Council have been provided and this brings into question the soundness of the rationale and choices made in the Brentwood Borough Local Plan.
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As such, all of Basildon Council's previous responses to Regulation 18 consultations are enclosed as supplementary evidence to the Regulation 19 consultation; affirming that many of the comments made in respects this consultation response have been raised previously, but remain unanswered or inadequately addressed. It is uncertain how the Plan has been informed by this previous input. It is considered that this is not a justified approach and has resulted in a Plan which is less effective at tackling strategic, cross-boundary issues.
Consultation Point: SP02: Managing Growth, Paragraphs 4.15-4.16 and Appendix 1
Soundness - Effectiveness, Justified & Compliance with National Policy
It is acknowledged that Brentwood Borough Council commissioned David Couttie Associates (DCA) in 2013 to undertake a Strategic Housing Market Assessment (SHMA) and define its Housing Market Area (HMA). This concluded that Brentwood Borough's administrative area was a self-contained HMA. This is different to the Basildon Borough, which is a sub-area (with Castle Point) of the much larger South Essex HMA, which also incorporates Rochford, Southend on Sea and Thurrock. The Brentwood SHMA, which was most recently updated in November 2018, forms part of the evidence base for identifying the Objectively Assessed Need (OAN) for housing in Brentwood Borough. However, NPPF/2019 (published after the Publication Local Plan was approved by Brentwood Borough Council in November 2018, in February 2019) now requires housing needs to be calculated in accordance with the Standard Methodology set out in national Planning Practice Guidance.
Basildon Borough Council has acknowledged that this has seen the OAN for Brentwood Borough change three times over the course of the last year as follows:
* In January 2018, the Brentwood SHMA January 2018 identified an OAN for Brentwood of 380. This was calculated using the SHMA Planning Practice Guidance that underpinned the NPPF/2012;
* In July 2018, NPPF/2018 was launched introducing the standard methodology for calculating objectively assessed housing need. The standard methodology requires the use of the most recently published household projections as the starting point. At that time, the 2014-based CLG Household Projections formed that starting point resulting in an OAN for Brentwood of 452 homes per annum; and
* In September 2018, 2016-based ONS Household Projections were published, revising the starting point for the standard method calculation. For Brentwood Borough, these projections showed a reduced rate of household growth going forward, resulting in a reduced housing requirement for Brentwood of 350 homes per annum.
It has been noted by Basildon Council that the Brentwood Borough Local Plan uses this latest 2016 projection to define the minimum OAN target.
The reduced rate of household growth in the 2016-based ONS Household Projections was highlighted as a nation-wide issue driving down the OAN calculations in around two-thirds of authorities, although not Basildon. This resulted in the standard methodology only identifying around 215,000 homes per annum supply for England against a national policy target of 300,000 homes per annum. Consequently, in October 2018 MHCLG launched a consultation on technical changes to the standard methodology, seeking for authorities to continue using the 2014-based CLG Household Projections in the interim. On the 19 February 2019, the Government's response to this consultation was published indicating that the Government will be making clear in national Planning Practice Guidance that the 2016-based ONS Household Projections should not be used for the standard methodology calculation, and the 2014-based CLG Household Projections should be used instead.
The Brentwood Local Plan therefore, which makes provision for 456 homes per annum does meet just over its full OAN for housing, having regard to the standard methodology calculation of need based on the 2014 CLG Household Projections (452 homes per annum), as explained in required by Planning Practice Guidance (Paragraph: 004 Reference ID: 2a-004-20190220 and Paragraph: 005 Reference ID: 2a-005-20190220) that has been adjusted following the Government's response to the technical consultation.
The Brentwood Local Plan, however, as drafted and approved by Brentwood Council in November 2018, sets out in Paragraphs 4.15-4.16 that the housing target for Brentwood is set at 350 homes per annum and it proposes an annual housing supply buffer of 20% taking total supply of 456 homes per annum. This was considered at the time as offering additional flexibility throughout the plan period. This is now not the case as the 2016-based ONS Household Projections must be discounted, as above, with the baseline reverting to the 2014-based projections. This results in a Plan which will now have an insignificant flexibility in its land supply; a component which was considered justified and fundamental to the Plan's strategy when it was approved in November 2018.
When this new position is viewed alongside the variable housing target, it is considered this could cause the plan to be less effective and justified. The initial housing target of 310 homes per annum between 2016 and 2023, should, according to the Plan, increase to 584 homes per annum beyond 2023. It is noted that this increase is substantially reliant on the new Dunton Hills Garden Village (DHGV) in the Southern Brentwood Growth Corridor, which according to the Housing Trajectory set out in Appendix 1 is expected to commence housing delivery in 2023/24, within the first five years of the Plan. That scheme is expected to deliver at the initial ambitious rate of 100 homes per annum upwards from thereon, reaching 300 homes per annum by 2026. These are considered to be overly optimistic delivery assumptions for such a large scale Green Belt allocation, which whilst mostly in a single land ownership that could facilitate delivery, still requires for the boundaries of the Green Belt to be amended on adoption of the Plan (assuming it is found lawful and sound), detailed masterplanning, essential infrastructure programming on-site and off-site to ensure sustainable development can be achieved. It is not clear from any published evidence how such a delivery rate has been formulated having acknowledged these issues and therefore this is challenged in terms that it is not justified.
Summary: As a result in the change to the NPPF, the Plan also now has very little flexibility within its land supply should anything happen to cause delivery of homes to become delayed during the plan period; which was a fundamental principle to the Plan's strategy approved in November 2018. There is an unjustified over-reliance on DHGV in the Southern Brentwood Growth Corridor to
contribute towards supply at an accelerated rate. The Council therefore objects to Policy SP02, 4.15-4.16 and Appendix 1
Modification: 1) The Local Plan must be adjusted to incorporate previously discounted development sites, particularly in the Central Brentwood Growth Corridor to restore the flexibility in site supply across a broader range of spatial locations, thereby improving the Plan's effectiveness and deliverability. 2) The methodology to the Local Plan's Housing Trajectory needs to be published and open for comment and challenge of its assumptions.
Consultation Point: PC02 and PC03
Soundness - Effectiveness, Justified & Compliance with National Policy
Paragraph 80 of the NPPF establishes that planning policies should help create the conditions in which businesses can invest, expand and adapt. The Council notes the new employment land requirements and job growth needs evidence undertaken by Lichfields in 2018. It is considered the amount of new employment land being provided is broadly sufficient to ensure that the Brentwood Borough meets its overall forecast employment land needs, including forecast new needs and losses from allocations and structural change.
It is considered however that the policy makes the assumption that there are no capacity issues for existing infrastructure, or any needs for supporting infrastructure to be provided and it is considered that this lack of clarity will make the policy ineffective, unjustified and will counteract creating conditions to support business growth which the NPPF seeks. As the Local Plan does with its housing target in Policy SP02 and Appendix 1, PC02 and PC03 should therefore incorporate additional provisions to manage the release and expansion of the locations within the Southern Brentwood Growth Corridor, supported by an Employment Land Trajectory in a new Appendix, to make it more effective, justified and consistent with national policy. The Council therefore objects to Policy PC02 and PC03.
Modifications: PC02 and PC03 should be amended to incorporate a staggered delivery target for new employment land, supported by a new Employment Land Trajectory within the Plan's Appendices, to coordinate the phased release of new and expanded employment land to ensure it can be linked to specific and necessary upgrades to supporting infrastructure. This will minimise the impact growth will have on existing highway routes in particular, which could otherwise impact on cross-boundary issues within the wider South Essex economic corridor.
Specialist Accommodation
Consultation Point: HP07
Soundness - Effectiveness
The Council has noted that the Brentwood Gypsy and Traveller Local Needs Accommodation Assessment 2018 (GTAA) assessed the need for Gypsy and Traveller pitches in Brentwood Borough for the period 2016 to 2033 as being 13 pitches. It acknowledges that there were no Travelling Showpeople identified as living in the Brentwood Borough, so there are no current or future accommodation needs for this community.
The evidence is noted as identifying a requirement of 11 additional Gypsy and Traveller pitches (5 total current need and 6 total future need) to be developed between the period 2016 to 2033 and makes a further 10% allowance for Gypsy and Traveller households whose travelling status was recorded as being "unknown", increasing the need to 12 pitches. It is acknowledged that since the completion of the evidence, one Gypsy and Traveller pitch has been lost through an approved change of use application and to replace this lost pitch, the Plan has added an additional pitch to its target, meaning the total requirement of Gypsy and Traveller pitches is 13 pitches.
Whilst it is noted that Brentwood Council proposes to meet this need through the incorporation of
a minimum 5 Gypsy and Traveller pitches as part of the Dunton Hills Garden Village allocation and through the regularisation of 8 existing pitches elsewhere in the Brentwood Borough. This however implies that 8 pitches will contribute towards meeting current need and only 5 pitches towards future need, when 6 are in fact required. The Council therefore objects to Policy HP07.
Modification: The GTAA identified the need for an additional pitch to meet future needs and therefore whilst the Policy HP07 quotes a minimum of 5 new pitches to be provided within its minimum target, the Plan could be more effective by setting 6 pitches as the target.
Consultation Point: Paragraphs 6.52-6.62
Soundness - Positively Prepared & Effectiveness.
The Council is concerned that there is no acknowledgement in the supporting text to the Brentwood Local Plan as to how it will address any unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople should it arise. The Plan should therefore recognise and support the principle of this approach going forward, to ensure that there will be a technical approach in place to support any neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling Showpeople need. This will ensure that the same process is applied throughout Essex therefore making the plan more positively prepared and effective for Gypsy, Traveller and Travelling Showpeople communities. The Council therefore objects to Paragraphs 6.52-6.62.
Modification: The Essex Planning Officers' Association Protocol for Unmet Gypsy, Traveller and Travelling Showpeople Needs 2018 has been developed collaboratively across Essex under the Duty to Cooperate, including with Brentwood Borough Council. It should be referenced in the supporting text to Policy HP07 - within Paragraphs 6.52-6.62. This will help ensure that the Plan recognises and supports the principle of this approach going forward, underling the technical approach in place to support how any requests from neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling will be considered in the future and then addressed as necessary through the Plan review process.
Consultation Point: Paragraphs 6.52-6.62
Soundness - Effectiveness and consistent with national policy.
Paragraph 9 of the Planning Policy for Traveller Sites (PPTS) establishes that "...local planning authorities should set pitch targets...which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring local planning authorities." There is also no mention however in the Brentwood Local Plan of the strategic and cross-boundary matter of Transit Sites, for which there is a study underway during 2019/2020 by the Essex Planning Officers' Association on behalf of all Greater Essex local planning authorities, including Brentwood Borough. Whilst it has not yet been possible to robustly assess the need for transit sites in Essex due to data inconsistencies across Greater Essex, changes have been made to the unauthorised encampment data collection process and an update to Essex Gypsy, Traveller and Travelling Showpeople Local Needs Accommodation Assessment will follow during 2019/2020 to determine whether any transit sites are needed in Greater Essex to help manage development pressures.
Whilst this cannot be included within Policy HE07 due to uncertainty, given that it is a current strategic matter for the Duty to Cooperate, with work in train to seek a resolution, it is considered more effective, for the Plan as a whole, to indicate how any such needs identified in future updates to the GTAA will be dealt with to make it more effective and consistent with the PPTS. The Council therefore objects to Paragraphs 6.52-6.62.
Modification: The Council considers the Local Plan would be more effective and more consistent with the PPTS if the strategic, cross-boundary issue of transit sites, covered by the Duty to
Cooperate were to be supported by a new paragraph explaining the context behind the issue and that it will be addressed as part of its first review.
Consultation Point: PC08 and Figure 7.7
Soundness - Justified & Effective
The Council notes that Nathaniel Litchfield & Partners prepared a Retail and Commercial Leisure Study (RCLS14) for Brentwood Council in 2014. The study identifies that Brentwood Town Centre as the main shopping centre in Brentwood Borough, with Shenfield, Ingatestone and Warley Hill providing smaller scale District Centres offering more local services, whilst smaller communities are supported by a number of village shops/local parades. The relationship between Brentwood Town Centre and larger competing centres including Basildon Town Centre is also noted, which is consistent with the Council's own evidence set out in the South Essex Retail Study 2017.
It is also acknowledged however that the Local Plan's settlement hierarchy proposes that DHGV Village and West Horndon will incorporate District Centres, similar in scale and role to Shenfield and Ingatestone. Figure 7.7 suggests this will apply to just DHGV, but caveats that this may change as a result of masterplanning or new evidence. Whilst the Council accepts that some form of local centre provision that could provide local shopping, community facilities and healthcare facilities would be a sustainable approach to the planning of any new community, helping to reduce the need to travel to larger centres to meet community needs, the positioning of the Garden Village needs to consider how it could impact on other centres and facilities in the locality, including those outside the Brentwood Borough, which may be closer and higher-order than other Brentwood Borough alternatives.
The Council cannot determine from any of Brentwood's published evidence as to what assessments have been carried out to determine the likely impact of installing new District Centres in West Hordon or DHGV on Basildon Borough's Laindon Town Centre. Assuming a central location within the site, DHGV District Centre would be around 2km to its west and West Hordon is only one stop by rail. Laindon Town Centre is the Basildon Borough's smallest town centre, which is currently undergoing a multi-million pound regeneration by Swan Housing Association to redevelop it into a new mixed use commercial and residential development called Laindon Place. It already provides a health centre, community centre, police station and library, which are all set to remain.
It is not considered acceptable as set out in footnote 10 to Figure 7.7 that the "the designation of the DHGV service centre(s) as a District Shopping Centre and/or Local Centre(s) and any subsequent Primary Shopping Area could be altered further by the South Brentwood Masterplan as this should remain a function of policy and not be delegated. The Council therefore objects to Policy PC08 and Figure 7.7.
Modification: Footnote 10 of Figure 7.7 should be amended to remove reference to the South Brentwood Masterplan as the role and order of the designated centre should be established by policy only. The Plan should have been informed by evidence which has tested cross-boundary impacts of installing new District Centres in close proximity to nearby centres including Laindon Town Centre and what measures will be taken in policy to limit any impact. If this evidence does not exist, the District Centre should be removed from DHGV, retaining some local centre provision to ensure DHGV can be sustainable and to enable the Plan to be effective and justified.
Consultation Point: Chapter 3, Chapter 6, Chapter 7 and Sustainability Appraisal
Soundness - Justified and consistent with national policy.
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. The Local Plan's Spatial Strategy is termed "Transit-orientated Growth", concentrating growth in the Local Plan in two transit corridors running through the borough. The 'Central Brentwood Growth Corridor', with the
A12, the Great Eastern Main Line to London Liverpool Street Station, and the Elizabeth Line; and the 'Southern Brentwood Growth Corridor', with the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
The Local Plan states that the site selection process for the housing allocations has been based upon the Spatial Strategy, and a sequential approach to selecting sites for development. It is accepted that this approach is intended to maximise brownfield redevelopment opportunities and support growth within compatible locations.
The Council acknowledges that Brentwood Borough Council has now published much of its previously missing evidence as set out in previous Regulation 18 representations. The Council is not satisfied that the Plan has been adequately informed by its evidence, and it questions whether the Spatial Strategy reached is therefore justified and consistent with national policy.
The Council has noted the two Growth Corridors. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia), which helps to put this investment into use through the growth locations. The South Brentwood Growth Corridor, whilst at its far west includes the M25, the remainder of the corridor consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c). It is not considered they offer comparable choices in terms of the capacity of these transport connections and the Central Brentwood Growth Corridor, by the presence of nationally and regionally maintained infrastructure.
In reviewing the appropriateness of the Spatial Strategy, an important element of the Plan's Sustainability Appraisal involves appraising 'reasonable alternatives' to inform development of the Plan. Four reasonable site alternatives in the Central Brentwood Corridor have been disregarded (AECOM Sustainability Apprial - Table 5.2), despite having few constraints and being able to tap into the potential for movement capacity offered by this superior corridor. This is considered to be in conflict with sustainable development when sites which have significant constraints to development or delivery have been included within the Plan, at the expense of sites which have fewer constraints. This raises fundamental concerns about the Plan's spatial distribution of growth and whether it has made the most of the capacity in this alternative corridor, before embarking on a new standalone settlement at DHGV in the Southern Brentwood Growth Corridor. The Council has noted that four sites on Table 5.2 of the Sustainability Appraisal have the potential to deliver 2,200 homes through extensions to villages, thereby questioning the need for a new settlement of the scale envisaged to deal with growth in the plan-period, which it considers means the Spatial Strategy is unjustified. The Council therefore objects to Chapter 3, the Sustainability Appraisal and land use allocations in Chapter 6 and 7.
Modification: Using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the superior infrastructure available. This should help encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Chapter 3 should be modified as a result along with all land use allocations in Chapter 6 and Chapter 7.
Consultation Point: Sustainability Appraisal
Soundness - Justified and consistent with national policy.
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contribution to the achievement of sustainable development. The Council challenges whether the Sustainability Appraisal has informed the choices made in the Spatial Strategy as
required by national policy, given it states that there was an early intention by Brentwood Council to deliver at least one new large-scale strategic site, which could be judged as artificially limiting the exploration of other plausible and deliverable urban/ village extensions. It is considered that Brentwood Council's lack of a Housing and Economic Land Availability Assessment (HELAA) between 2011 and 2018 has negatively impacted upon previous Regulation 18 drafts, which could have evolved differently having been informed by such evidence, demonstrating that other suitable, available and deliverable site options were present. This is unjustified, not consistent with the Plan's Strategic Objective SO1 and not in accordance with the NPPF. The Council therefore objects to the Sustainability Appraisal.
Modification: The Sustainability Appraisal should be reviewed to test an alternative strategy which does not include the artificial assumption that at least one new large scale strategic site should be incorporated into the Local Plan and then it should be amended accordingly. The Plan should then be reviewed informed by the outcome.
Consultation Point: BE11 and Paragraphs 5.106
The Council has reviewed the Brentwood Borough Infrastructure Delivery Plan (IDP) accompanying the Local Plan. It is acknowledged that this is intended to be a 'live' working document, much the same as the Basildon Borough IDP.
Paragraph 5.105 acknowledges that in respects of the South Brentwood Growth Corridor "...the provision of sustainable transport in this area is poor". The Council considers that it is surprising therefore that there are no specific highway mitigation measures provided in the Plan, just a statement that "the Council will work proactively with developers, key stakeholder and service providers to implement...new measures which would seek to mitigate transport impacts of sites on the highway infrastructure...". Whilst it is acknowledged within the Plan of the joint working being undertaken by ASELA, and the A127 Task Force for the Route Management Strategies and Joint Strategic Plan, both of which are supported by Basildon Council. The Council does however consider that highway modelling should have been tested to determine impact in development locations in Brentwood Borough, so it can be clear in policy terms how negative impacts are being mitigated and therefore prove that the Plan's spatial choices are reasonable in sustainability terms. It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace as suggested in Appendix 1, becomes hindered by a lack of infrastructure capacity and outline solutions to overcome them. It is not considered that Policy BE11 is therefore effective at delivering the Plan's Strategic Objectives.
It is noted that Paragraph 5.106-5.107 acknowledges the Lower Thames Crossing and the outline concept of its preferred route and that it is not expected to have a direct impact on Brentwood Borough in terms of land safeguarding. It is however suggested that the Plan also acknowledges that following the engagement of authorities in Essex, including Basildon Borough Council, Highways England has accepted that its impact modelling was deficient in determining how driver behaviour in South Essex and further afield could alter when the scheme opens. This is particularly an issue for this Plan, as its includes land allocations in West Horndon and the DHGV along the A127 corridor, which will be within a reasonable proximity to the Lower Thames Crossing and could therefore be impacted by it. It should be recognised that Highways England are now taking steps to incorporate growth proposals set out in Local Plans in the vicinity to address this point and identify any measures needed to the scheme or nearby routes to mitigate any adverse impacts. The Council therefore objects to Policy BE11 and Paragraphs 5.106.
Modification: 1) BE11 and the land allocations should have been informed by highway modelling that tests highway mitigation solutions to mitigate impact caused by development. This work should be repeated and the Plan amended in light of its findings.
2) Paragraph 5.106 should be amended to include reference that local authorities have secured additional testing within the Lower Thames Crossing modelling being undertaken by Highways England to determine the extent of local impacts on the road network arising from Local Plan growth.
Consultation Point: R01 & HP01
Soundness - Justified
The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs and it is considered that there may be implications for the future geographical extent of both the Brentwood and South Essex Housing Market Areas as the housing markets evolve.
Furthermore, the policy requirements of the Plan are informed by data collected from Brentwood Borough, or its population; the significant majority of which is located away from this area to the north. Consequently, there is a difference in what might be delivered in DHGV compared to what could be delivered just slightly to the east in Basildon Borough; which might distort the housing markets as they adjust to the new development taking place around the boundary. The following table has been prepared using Figure 6.1 from the Plan and the South Essex Strategic Housing Market Assessment that has informed the Basildon Borough Local Plan 2014-2034 and it is considered both these SHMA's should instead be used to inform the housing mix policy for DHGV. The Council therefore objects to Policy R01 and HP01.
Modification: It is considered the stark contrast between the house size requirements for Basildon and Brentwood in DHGV, which is on a boundary location, means it needs to have taken into account the South Essex SHMA in determining the housing mix for DHGV so that it can better sit within the landscape of the strategic context of South Essex, which is not reflective of the wider Brentwood Borough HMA. Policy HP01 and R01 should be amended in light of this.
Consultation Point: R01(D)(h)
Soundness - Justified and consistent with national policy.
The Council has noted that Policy R01(D)(h) has set a target to retain 50% of the strategic allocation for green and blue infrastructure. Given the location is over 259ha, it is agreed that this helps enshrine the Garden Community values within the policies which will guide the masterplan and the site's development. However, the Council questions whether this is intended to be a permanent resource, given it also determines that a further 2,300 homes could be brought forward in the strategic location after 2033; taking its indicative total to around 4,000 homes. It is considered that if it is not explained clearly in any published evidence, as to whether any of the retained space for green and blue infrastructure would need to be used to meet this higher development scale after 2033. The Council's understanding of this, is frustrated by a lack of published evidence on DHGV, which would enable Basildon Borough to effectively understand the nature, extent and potential implications (positive or negative) of its proposals for DHGV. This would make the policy more justified and compliant with national policy. The Council therefore objects to Policy R01(D)(h).
Modification: Clarify within R01 and its supporting text whether the Green Infrastructure proposed to amount to 50% of the land area is a permanent resource or whether the projected growth in the area beyond the plan-period would need to utilise any of the green infrastructure for growth. If the latter, the percentage should be adjusted accordingly.
Consultation Point: SP02, R01 and Paragraph 8.83-8.84
Soundness - Justified
The Council welcomes the publication of the Brentwood Borough Green Belt Study 2018. It is acknowledged that this comprises two parts; Part 1 is a full Green Belt assessment parcelling up the Green Belt and Part 2 as a separate site assessment of individual sites promoted through the Housing and Economic Land Availability Assessment (HELAA). This is a similar format to the Basildon Borough Green Belt Study.
For Part 1, a scale of high - low was used to assess the contribution 70 separate parcels made to the Green Belt. The DHGV parcel (17) score "Moderate - High". It was one of 21 parcels to score "Moderate - High". 19 parcels scored "High". The remainder scored lower.
In respect of the tests, Parcel 17 was assessed as follows:
* Purpose 1 - to check unrestricted sprawl of large built up areas: Not contained i.e. development would constitute urban sprawl (red)
* Purpose 2 - to prevent neighbouring towns merging into one another: Important
countryside gap between settlements (amber)
Purpose 3 - to assist in safeguarding the countryside from encroachment: Functional countryside (red)
Purpose 4 - to preserve the setting and special character of historic towns: Limited relationship with a historic town. (green)
The Council does not consider it to be clear however, from the published methodology, as to why having scored highly in relation to the Purpose 1 and Purpose 3, as to why this parcel is assessed as making a "moderate to high" contribution to Green Belt purposes, when there are other parcels which make high contributions towards two of the purposes have been assessed as making a "high" contribution towards Green Belt purposes; and are therefore valued to a greater degree as serving towards the purpose of Green Belt.
In respects of Part 2 assessment, the DHGV allocation (Site 200) was assessed alongside other HELAA sites. A total of 92 sites were assessed. The DHGV site assessment matches the entire Parcel 17 assessed in Part 1. Five sites were assessed as making a "high" contribution towards Green Belt purposes. A further 18 sites were assessed as making a "moderate to high contribution". Site 200 - 'Entire land east of A128, south of A127' was assessed as making a "moderate to high" contribution. The remaining 69 sites were assessed as making a less significant contribution to Green Belt purposes.
The DHGV site was assessed as follows:
* Purpose 1 - to check unrestricted sprawl of large built up areas: Not contained i.e. development would constitute urban sprawl (red)
* Purpose 2 - to prevent neighbouring towns merging into one another: Would result in significant separation reduction (amber)
* Purpose 3 - to assist in safeguarding the countryside from encroachment: Functional countryside (red)
* Purpose 4 - to preserve the setting and special character of historic towns: Limited relationship with historic town (green)
The outcomes of Part 2 are considered to be consistent with Part 1. However, it is not clear from the methodology as to why given the site scored highly in relation to Purpose 1 and Purpose 3,
this parcel is then assessed as only making a "moderate to high" contribution to Green Belt purposes, when it could potentially have been assessed as making a "high" contribution for those reasons.
The Council recognise that there is now, no longer an issue with missing evidence in this regard, which it had repeatedly raised in previous Regulation 18 consultation responses. However, the Council considers that the issue now is one of how the Green Belt evidence has informed the Plan. It is not clear how the policy judgements arrived at have considered that development in this strategic gap, which helps prevent settlement coalescence can be adequately mitigated. The Council does not believe that when accounting for this evidence that the Plan has reached a justified position in respects of whether the Green Belt evidence has informed the Local Plan policies, to the degree which the proposals in the DHGV area are set out. The Council therefore objects to Policy SP02, R01 and Paragraphs 8.83-8.84.
Modification: The Plan should demonstrate in more detail, through a tool such as a Topic Paper, how its site selection choices have been informed by the Green Belt Study 2018 and should any inconsistencies occurs the Plan's land use allocations and justification should be changed.
Consultation Point: Paragraph 9.36 and R01(II)
Soundness - Justified & Effective
Brentwood Council will be aware from joint Duty to Cooperate meetings with elected members and officers that during 2017, efforts were made by both Basildon and Brentwood Councils to determine whether a West Basildon urban extension could be delivered in the Basildon Borough Local Plan, alongside DHGV, whilst maintaining a sense of visual separation between both developments. To this end, a joint Dunton Area Landscape Corridor Design Options Study was commissioned by both Councils, which I have enclosed as evidence against this representation, to consider how both Council's Green Belt and land management policies, either side of the boundary, could be coordinated in this location going forward. This was to also help determine whether it was possible for DHGV to co-exist with development in West Basildon without causing harm to heritage and environmental assets within Basildon Borough.
The Council has noted that the Plan does now includes specific references that the joint borough boundary needs a degree of landscape and Green Belt treatment to maintain a visual separation with the edge of Basildon Borough, but it does not elaborate as to how this will be achieved. The Council therefore finds its disappointing that this joint study does not form part of the referenced and published evidence base for the Plan, nor do the outcomes from this work appear to have informed Policy R01(II) as sought through the earlier Duty to Cooperate engagement. The Council therefore objects to Policy R01(II) and Paragraph 9.36.
Modification: The measures set out in the Joint Dunton Area Landscape Corridor Design Options 2017 should be acknowledged in Paragraph 9.36 and incorporated into Policy 9.36 to make it more justified and effective at mitigating the impact the development would otherwise have on the Basildon Borough. This would lead to an effective policy outcome identified as being necessary during Duty to Cooperate engagement to manage this cross-boundary issue. It is considered that as a matter of principle, this would help address the Council's previous Regulation 18 objections as to how the boundary would be treated and how the new community could exist side by side the existing smaller settlement of Dunton Wayletts in the Basildon Borough.
Consultation Point: SP04 and R01(I)
Soundness - Effectiveness, Justified & Compliance with National Policy
It is noted that the Plan assumes that all commuters will use West Horndon railway station and other areas in Brentwood Borough to access a means of travelling to other places. It fails however to investigate the possible impacts on Basildon Borough's road and rail infrastructure, as a
neighbouring authority, arising from commuters or other road users choosing to access facilities within the Basildon Borough instead.
The Transport Assessment (PBA, 2018) discusses measures to ensure more effective bus access to and from West Horndon Station - serving an area including the new DHGV, as well as other employment sites within South Brentwood Growth Corridor. It is noted however that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable.
The Brentwood Borough IDP states that a new multi-modal interchange will be created at West Horndon Station. This will serve the DHGV, Childerditch, West Horndon and Enterprise Development sites. It also mentions the possibility that this could serve any future northern Thurrock developments. The Plan states that, the proposed DHGV settlement's transport mitigation measures will include potential dedicated bus route(s) connecting the development with West Horndon station and improvements at West Horndon station for vehicular, segregated cycle and public transport access from surrounding developments, as well as cycle storage and a bus interchange facility. The Council is therefore confused that in seeking to mitigate DHGV's impacts on the surrounding areas there is no mention of any impact being evaluated as spilling over into Basildon Borough and needing its own mitigation.
Laindon railway station, with three platforms and starter trains has greater commutable capacity than West Horndon and could become an alternative choice for residents within DHGV, despite a lack of new connections hampering their ability to make that choice easily without driving, via the A127. Whilst the Plan seeks to make provision for a new interchange at West Horndon to capture these movements more locally, should commuters still seek to use alternative stations including those outside of the Brentwood Borough such as Laindon, this will lead to increase demands on those stations' facilities, particularly parking, as well as the routes to get to them. Policy SP04 does set out the approach required by Paragraph 34 of the NPPF, but it does not explicitly mention that it has accounted for the spatial context of DHGV and the existing spatial form of the Brentwood Borough, where its higher-order settlements are further to the north. It does not state that it will support the possibility of developer contributions being used to mitigate this impact outside the Brentwood Borough in higher-order settlements which are closer that Brentwood Borough's own settlements, but outside the Brentwood Borough. This is considered to disregard how new residents living in the DHGV could behave in the future in seeking to access services and how this impact will therefore be adequately mitigated.
It seems that it an effort for the new DHGV to be self-sustaining, as set out in Paragraph 9.14, it has meant the Plan remains unclear, as to how it will relate to its neighbouring areas, particularly in terms of access and connectivity. This is considered a core sustainability principle for new developments and whether in exercising that choice, its residents will use what is to be provided within Brentwood Borough remains to be seen. They could use alternative routes (namely the A127 and West Mayne into Laindon) to access different facilities already available in closer higher order settlements outside Brentwood Borough. Considering that there are existing services that are already shared between the Borough's residents, e.g. schools, it is considered essential for a more practical and pragmatic approach to be adopted should the DHGV be permitted, including the policy reality that until such a time as the critical mass for new homes is established on-site, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the neighbouring Brentwood Borough in the short-medium term.
There is no evidence presented by Brentwood Borough Council which indicates that DHGV's growth demands have been evaluated, in combination, with the projected demands arising from the Basildon Borough Local Plan. The Plan should not assume that such growth can just be absorbed by the nearby infrastructure and services in Basildon Borough and investment through developer contributions will be necessary. The infrastructure in the Basildon Borough has been evaluated for its capacity, its ability to grow and the scale of investment necessary to accommodate the growth in the Basildon Borough Local Plan to enable the Basildon growth to occur and there has not been enough information published during Regulation 18 (as set out in previous
representations) to be able to incorporate any testing of Brentwood's growth in as well. The Council therefore objects to Policy SP04 and R01(II).
Modification: The Plan should be modified to recognise that some impacts are likely to be cross-boundary and additional provisions should be incorporated into SP04 and RO1(I) that will support using S106/CIL arising from development in Brentwood Borough to be used for investment outside the Brentwood Borough, where it can be proven that there is reasonable likelihood of a direct or residual impacts otherwise being caused that need to be mitigated. This will make the Plan more effective, justified and in accordance with national policy.
Consultation Point: R01(I) and Appendix 1
Soundness - Justified & Effective
The Council notes the housing trajectory included within the Plan at Appendix 1. With regards to DHGV it is assumed that delivery will commence in 2022/23 (within the next five years) at a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. As set out in earlier representations in respects of housing supply, this seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires masterplanning and will need to go through a planning application and elements of the condition discharge process before development on site can even commence. Development commencement on-site meanwhile, will be reliant on essential utility and infrastructure provision. No evidence is provided alongside the Plan, or within the associated Housing and Economic Land Availability Assessment (HELAA), as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base, or any form of a development framework/ masterplan for the DHGV that explains how the proposed accelerated rate of delivery will be possible to achieve.
The Council considers that the speed and level of growth in this boundary location may have implications for Basildon Borough's own housing market and risks the ability for it to be able to deliver housing at the rates necessary for its own housing trajectory. Early residents of the DHGV will rely on some services and facilities outside the village to meet their initial needs, unless these facilities were all to be front-loaded and wait for the population to gradually build up to make full use of them. As an example, the DHGV will require new primary and secondary school provision. However, whilst the Brentwood IDP shows the primary provision in particular being delivered early, it is understood to not be economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality (principally within the Basildon Borough), whilst operational primary and then secondary education provision is secured and the village becomes more self-sufficient. The Council therefore objects to Policy R01(I) and Appendix 1.
Modification: The Council therefore seeks for evidence to be provided demonstrating the realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby. This will make the Plan justified and effective.
Consultation Point: R01(II)
Soundness - Effectiveness
Notwithstanding that the Council objects to many of the fundamental soundness principles of the DHGV, the Council would like to seek assurances written into Policy R01(II) that it will be invited by Brentwood Borough Council to become more involved in the detailed design and delivery of the new village. This will ensure that the strategic and cross-boundary impacts covered by the Duty to Cooperate and raised during the Council's response to the Plan at Regulation 18 and 19 stages are managed effectively during the development's implementation stages (assuming it is
considered sound), alongside the Basildon Borough Local Plan's own implementation. The Council therefore objects to Policy R01(II).
Modification: The Council would like a criterion added into Policy R01(II) under a new heading "Collaborative Approach" that will make it a requirement for neighbouring authorities to be engaged during the detailed design stages of DHGV to ensure strategic and cross boundary impacts are managed effectively during implementation.
This concludes the Council's representation.

It is considered the Brentwood Draft Local Plan and supporting evidence base will require further revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Brentwood Local Plan should be reviewed to take account of further technical evidence and potentially the outcome of other evidence including the testing of other spatial options being considered by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

It is recommended that specific additional evidence base required includes:
* An updated SHMA to take account of the Government policy requirements not to use the 2016-based household projections;
* Further evidence to have assessed the various spatial growth options;
* A more fully developed transport evidence base that includes cumulative and site specific impacts of development on the local and strategic highway network and to identify further infrastructure and /or mitigation measures required together with costing and phasing;
* An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability

Evidence: Thurrock Council has previously made representations on the Brentwood Local Plan at the draft 2016 Local Plan consultation and the 2018 Preferred Site Allocations regarding the lack of sufficient evidence base to support the policies and proposals in the emerging Local Plan.

It is acknowledged that with the publication of the Pre-Submission Brentwood Local Plan (Regulation 19) that significant progress has been made with the provision of new and updated evidence across a range of topic areas. Brentwood Council through its collaboration and support of the South Essex Joint Strategic Plan (JSP) has also been involved in the commissioning of technical evidence to support the JSP including the Strategic Growth Locations study (SGLS), Employment Land Review and Infrastructure Framework. The South Essex authorities are also intending to commission further technical evidence including Green and Blue Infrastructure, a Strategic Green Belt Review and viability work to support the JSP.

However Thurrock Council considers that there are still key elements of the current Brentwood Local Plan base evidence that provide insufficient detail, are out of date or are missing and therefore the local plan is not fully justified in its policies and proposals. Detailed comments regarding the lack of need to update evidence are made in other representations by Thurrock Council on the Pre-Submission Brentwood Local Plan (Regulation 19).

Thurrock Council considers the Brentwood Local Plan is currently unsound because of insufficient or lack of up to date evidence regarding:
* The transport modelling and mitigation measures to support the overall spatial strategy, transport policies and key development locations such as Dunton Hills Garden Village (DHGV);
* The Infrastructure Delivery Plan (IDP) has not been sufficiently developed or contain enough detail to support the growth strategy, policies and site allocations in the plan;
* The SHMA needs to be reviewed and updated to reflect the Government approach to assessing housing need;
* There is insufficient evidence across a range of evidence topics to support the Dunton Hill Garden Village (DHGV) proposal.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

A more fine-grained approach should be undertaken.

1.0 Introduction and Background
1.1 This representation for the Brentwood Pre-Submission Local Plan (PSLP) 2019 is submitted by Strutt & Parker of behalf of BPM Investments Ltd, who hold a Promotion Agreement for Salmonds Grove, Ingrave. The site has been promoted to the Council through the previous Local Plan consultations and has been assessed by the Council. The site is identified by the attached location plan (Appendix 1). Representations were submitted in March 2016 for the Draft Local Plan and the site has been considered by the Council through its Strategic Housing Land Availability Assessment (SHLAA) 2011, the Site Specific Sustainability Appraisal (SA), and the January 2018 Site Assessment Methodology, Site Ref. 067a and 067b. Representations to the Regulation 18 consultation were also submitted highlighting many of the same concerns.
1.2 The site is on land currently allocated as Green Belt in the Brentwood Replacement Local Plan (2005), but is situated immediately adjacent to the settlement boundary of Ingrave and Herongate. It is recognised that the settlement boundaries contained within the Brentwood Replacement Local Plan 2005 were predicated on the need to accommodate significantly less development than currently required, and this site is located in a sustainable position on the eastern boundary of Ingrave, in an area of residential character.
1.3 The specifics of the site, and its sustainability for allocation for residential development, has not been recognised in the PSLP. We have raised a number of concerns in respect of the proposed approach in the Brentwood Borough Council Preferred Site Allocations (PSA) Consultation, and set out that should the Council proceed in the current direction it will result in a plan that is unsound. Our concerns do not appear to have been addressed satisfactorily and it is considered that the PSLP, without modifications, is unsound for the following reasons: a. It fails to meet housing need over the entire plan period and is reliant on strategic allocations that will not deliver as promptly as set out in the PSLP Trajectory; b. The PSLP fails to meet the housing needs in full, as there is no accounting for underdelivery in neighbouring authorities; c. The PSLP provides only a very narrow margin compared to the calculation of housing need under the Standard Method, and is therefore inflexible; and d. The Spatial Strategy fails to meet the housing needs of settlements such as Ingrave.
1.4 It is considered that land at Salmonds Farm, Ingrave, should be removed from the Green Belt and allocated for residential development in order to assist with the soundness of the Plan. An illustrative development for the site, which would be sustainable and in keeping with Ingrave, is provided at Appendix 2 to assist in understanding the nature of the proposal. The site represents a modest extension to an existing residential area, within a sustainable location. It represents a deliverable site to assist in meeting the Borough's housing need in the short term with negligible impact on the Green Belt and surrounding landscape. Plan Period
1.5 The proposed plan period runs until 2033. Assuming adoption in 2019, this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (Paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption.
1.6 This deficiency in the PSLP is of particular relevance given that the Borough is predominately Green Belt, and failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt; its permanence (NPPF, Paragraph 133).
2.0 Housing Need
2.1. There is an acute housing shortage at both the national and the local level. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.2. The National Planning Policy Framework (NPPF) attaches great importance to the need for Local Plans to meet objectively assessed housing needs. It is a requirement of a sound Local Plan. Furthermore, the NPPF calls for a significant boost to the supply of land for housing, and requires Local Planning Authorities to ensure a sufficient supply of sites to provide five years worth of land for housing against housing.
2.3. At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12 it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying PPG).
2.4. However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.
2.5. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum, not 350.
2.6. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years).
2.7. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need.
2.8. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum.
2.9. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.10. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities.
2.11. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional years' worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for.
2.12. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period.
Five-year housing land supply and housing trajectory
2.13. The Council is required to demonstrate a five-year housing land supply at any point in the plan period.
2.14. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.15. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied.
2.16. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years.
2.17. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.18. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a fiveyear requirement of 2,712 dwellings.
2.19. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises just 653 dwellings. It is unclear how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply.
2.21. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward.
2.22. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.23. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.24. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to deliver housing completions from 2022/23, i.e. falling within the first five years of the plan.
2.25. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
2.26. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this is required before development has even begun.
2.27. The ability of larger sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin review (2018) and issues with their complexity have been ably set out in the Lichfield Study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematic due to a range of factors, including establishing the required infrastructure, and the timings of housing delivery associated with those requirements as well as the prolonged or protracted nature of the planning process. The Litchfield's report confirms that the planning process takes on average 2.5yrs for the planning application determination period for schemes of up to 500 units, but that this can double for sites over 1,000 units.
2.28. BPM Investments Ltd is a company owned by housing specialists Arebray Development Consultancy, DAP Architecture and Silverstone Lane and they all deliver schemes consistently within Essex. They are able to provide detailed evidence on the delivery rates of minor and major developments. Two such hypothetical scenarios are provided with this representations (Appendix 3 and 4)
2.29. Scenario 1 provides a 50 Unit Brownfield site. This has outline planning consent and is to be marketed. It contains existing buildings that will require demolition and there is limited contamination. Access can be gained directly from the highway and all mains services are available to the edge of the site without any works required outside the site boundary.
2.30. Scenario 2 is a 200 unit Greenfield site at the edge of an existing settlement. The site is to have outline planning consent and is to be marketed. It is assumed there will be no significant delays due to Archaeology and Ecological constraints but recognise this could be greater depending upon the time of year the programme starts. It is assumed that the site is available for immediate development. Time is allowed for local infrastructure upgrades and new junction arrangements to provide access into the site.
2.31. These scenarios both assume that there are no delays and therefore represent a best case situation for two current projects. We have presumed that workflows will overlap where there are no commercial risks by doing so.
2.32. The scenarios confirm that large scale development can take up to 3yrs to provide the first dwellings after outline planning permission is approved, while smaller schemes are predicted to require two years for delivery of the first units. The timeframe is compounded by the scale of development, as recognized by the other reviews into delivery rates. For the strategic allocations in Brentwood, it is noted that the masterplanning stages are likely to add significantly to these timeframes, which follow from outline planning permission.
2.33. For the above reasons it is unrealistic to project that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound.
2.34. The strategic sites are expected to deliver 1,555 dwellings within 5yrs of adoption. Given the matters set out above, this is unrealistic and it would not be justified to rely on these sites to meet short term housing delivery. This emphasises the need to review sites such as ref. 067a and 067b to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is sound.
3.0 Spatial Strategy for Growth
3.1. Ingrave is identified as a Category 3 settlement -Villages in sparse rural locations that provide day to day needs for local residents. Ingrave has an established community, with services commensurate with its population. This is highlighted in the Council's own report of November 2017, paragraph 103, which confirmed that Ingrave and other Large Villages provide opportunities for small edge of settlement release to support housing growth. It is important that the Local Plan manages the growth of the settlement to ensure the vitality of its communities is sustained or enhanced.
3.2. Notwithstanding the above, the PSLP proposes to direct no additional growth to Ingrave. This contrasts with the approach to Blackmore, but otherwise the Council's preferred approach for Category 3 and 4 villages is to direct no growth over the plan period. This approach is considered to be unsustainable for these settlements. These views were raised at previous consultation stages. The spatial strategy fails to ensure the sustainable growth of Ingrave. The proposal to direct none of the Borough's housing need to Ingrave is unjustified, and inconsistent with national policy.
3.3. To ensure the Local Plan is sound, the special strategy should be amended to direct a proportionate level of growth to Ingrave. Housing Delivery
3.4. Paragraph 41 of the PSLP states that affordability ratios in Brentwood require an upward adjustment to the housing supply to be made.
3.5. It is recognised that the Council is deficient in providing a five year supply of housing land. It is therefore important to balance the strategic allocations with smaller sites, as these will generally have fewer constraints and can be delivered quickly to assist with meeting the persistent undersupply of housing in Brentwood. Such sites include land at Salmonds Grove, which can be delivered within the first five years of the plan.
3.6. The NPPF expects LPAs to identify the scale and mix of housing the local population is likely to need over the plan period which, among other matters, meets household and population projections, taking account of migration and demographic change; caters for housing demand and the scale of housing supply necessary to meet this demand.
3.7. The proposed plan does not account for migration from London, as identified in the PBA OAN report. This is contrary to the NPPF.
Green Belt
3.8. A detailed Green Belt Appraisal was prepared in respect of the Site by The Landscape Partnership and submitted at the Regulation 18 stage consultation. A copy is provided again here, for completeness (Appendix 5).
3.9. The Green Belt Appraisal considers the contribution of the site in relation to the five purposes of including land in the Green Belt, as per paragraph 134 of the NPPF: * To check the unrestricted sprawl of large built-up areas: * To prevent neighbouring towns merging into one another; * To assist in safeguarding the countryside from encroachment; * To preserve the setting and special character of historic towns; and * To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
3.10. The Green Belt Appraisal provides a thorough review of the site in relation to these purposes, and concludes that: "The initial landscape appraisal fond that developing the site in the manner proposed, e.g. c.24 residential units, would be unlikely to result in any adverse effects on land with a landscape related designation, Conservation Area, or Ancient Woodland. Salmond's Grove Farmhouse to the south of the site is a Grade II Listed Building; however, there is intervening built form between it and the site and it is thus unlikely that development of the type proposed would have a material effect on the farmhouse's landscape setting" (paragraph 5.1.2).
3.11. The Green Belt and Visual Appraisal further concludes that the removal of the site from the Green Belt and its subsequent residential development, would have no significant adverse effect on other landscape features such as topography, hedges, etc.:
3.12. A Part 3 Green Belt Appraisal (dated 31 January 2019) has been published by the Council. This considers specific sites, albeit in limited detail.
3.13. There is no evidence that the findings of the Green Belt Appraisal that was produced in respect of the Site by the Landscape Partnership, and which considered the Site in far greater detail than the Council's Part 3 Green Belt Appraisal, have been taken into account.
3.14. We are concerned with the simplistic approach that appears to have been taken in considering the contribution sites make to the purposes of the Green Belt. Overview
3.15. The Council's own evidence base states that the site is suitable, available and achievable for development. Development of the site is supported by a wealth of technical evidence that confirms its suitability, including in relation to the lack of harm to its development to the purposes of the Green Belt.
3.16. The reasons given for the rejection of the site are spurious and based on erroneous conclusions.
3.17. The rejection of the site is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed over the plan period and the lack of support for any growth at Ingrave.
4.0 Land at Salmonds Grove, Ingrave
4.1. The site was discounted from the Site Considerations as part of the Council's Site Assessment Methodology (January 2018). Larger Villages (Category 3 Settlements) are set out in Appendix 6 of the Methodology and repeated in this representation as Appendix 4. The site was discounted on the basis of 'Green Belt Impact'.
4.2. Discounting Salmonds Grove on this basis is unjustified. The Methodology report states that sites were selected based on initial high-level assessments of the key assessment criteria, being, amongst other matters, flood risk, Green Belt, landscape, highways, historic assets, ecological designations, utilities, education and health facilities. There was, therefore, a reasonably extensive set of criteria analysed for each site (para.3.22- 23 of the Brentwood Draft Local Plan - Preferred Site Allocations Site Selection Methodology and Summary of Outcomes Working Draft). The conclusions for each assessment are summarised in the associated appendices of the Report, with Salmonds Grove in Appendix 6 (sites 067a&b).
4.3. For Salmonds Grove, the Site Assessment simply states that there would be 'Green Belt impact'. We are concerned that the assessment and the reasons for discounting an otherwise suitable, available and sustainable site, are not robust.
4.4. Salmond's Grove has been discounted at Stage 4 of the Site Assessments on the basis of an initial high-level assessment, which found that a site was (presumably) satisfactory and suitable on all criteria with the sole exception of impact on the Green Belt. If the site were unsuitable for other reasons, these would also be listed in Appendix 6 of the BBC Report.
4.5. Salmonds Grove adjoins Ingrave and is within Parcel 15 of the BBC Strategic Green Belt Assessment (SGBA). Parcel 15 is 458.4ha in extent, being a roughly square parcel extending from the east of Ingrave to the Borough Boundary. The Assessment concludes that the parcel is of high value to the purposes of the Green Belt. This is not surprising, given the extent of the parcel. However, this assessment is less helpful when assessing smaller sites that are well associated with the urban area, such as Salmonds Grove. The Assessment actually notes under Purpose 1 that the area is 'Very large parcel relative to Ingrave and Herogate'. This belies the unsatisfactory nature of the assessment when considering smaller sites and acknowledges the limitations of the Assessment for such sites. Tellingly, the Green Belt parcels with the least impact, Low-Moderate as identified through the Assessment, are mostly the smaller sites on the edges of urban areas (parcel Nos. 32; 45; 56; 07a (BBC Green Belt Study Part II: Green Belt Parcel Definition and Review; p.43).
4.6. Accordingly, in order to assist the Council in identifying suitable sites within large GB parcels, it is considered that a more fine-grain assessment of sites should be undertaken. This is particularly important, given that the Council are not able to meet the housing needs of the Borough and would meet the tests set out in Calverton Parish Council v Nottingham City Council & ors. [2015] EWHC 1078 (Admin).
4.7. As set out above, the promotor of the site has prepared a Landscape and Green Belt Assessment, providing a full analysis of how it contributes to the five purposes of including land in the Green Belt (Appendix 5).
4.8. This focused assessment concludes that the site: * would be unlikely to result in any adverse effects on land with a landscape-related designation, Conservation Area, or Ancient Woodland; * there would be no significant adverse effect on other landscape features such as topography, hedges; * the site exerts relatively little influence on the surrounding townscape and landscape beyond its immediate vicinity; * Salmond's Grove site makes a Low contribution to the Green Belt purposes, and it could be developed in the manner proposed without compromising the objectives of the wider Green Belt.
4.9. To ensure the plan is sound, it is considered that additional sites should be identified and allocated. Those sites should include those of less importance to the Green Belt, such as Salmonds Grove, Ingrave. Not to include the site in the Local Plan is unjustified.

A more fine-grain assessment of sites should be undertaken.

1.0 Introduction and Background
1.1 This representation for the Brentwood Pre-Submission Local Plan (PSLP) 2019 is submitted by Strutt & Parker of behalf of BPM Investments Ltd, who hold a Promotion Agreement for Salmonds Grove, Ingrave. The site has been promoted to the Council through the previous Local Plan consultations and has been assessed by the Council. The site is identified by the attached location plan (Appendix 1). Representations were submitted in March 2016 for the Draft Local Plan and the site has been considered by the Council through its Strategic Housing Land Availability Assessment (SHLAA) 2011, the Site Specific Sustainability Appraisal (SA), and the January 2018 Site Assessment Methodology, Site Ref. 067a and 067b. Representations to the Regulation 18 consultation were also submitted highlighting many of the same concerns.
1.2 The site is on land currently allocated as Green Belt in the Brentwood Replacement Local Plan (2005), but is situated immediately adjacent to the settlement boundary of Ingrave and Herongate. It is recognised that the settlement boundaries contained within the Brentwood Replacement Local Plan 2005 were predicated on the need to accommodate significantly less development than currently required, and this site is located in a sustainable position on the eastern boundary of Ingrave, in an area of residential character.
1.3 The specifics of the site, and its sustainability for allocation for residential development, has not been recognised in the PSLP. We have raised a number of concerns in respect of the proposed approach in the Brentwood Borough Council Preferred Site Allocations (PSA) Consultation, and set out that should the Council proceed in the current direction it will result in a plan that is unsound. Our concerns do not appear to have been addressed satisfactorily and it is considered that the PSLP, without modifications, is unsound for the following reasons: a. It fails to meet housing need over the entire plan period and is reliant on strategic allocations that will not deliver as promptly as set out in the PSLP Trajectory; b. The PSLP fails to meet the housing needs in full, as there is no accounting for underdelivery in neighbouring authorities; c. The PSLP provides only a very narrow margin compared to the calculation of housing need under the Standard Method, and is therefore inflexible; and d. The Spatial Strategy fails to meet the housing needs of settlements such as Ingrave.
1.4 It is considered that land at Salmonds Farm, Ingrave, should be removed from the Green Belt and allocated for residential development in order to assist with the soundness of the Plan. An illustrative development for the site, which would be sustainable and in keeping with Ingrave, is provided at Appendix 2 to assist in understanding the nature of the proposal. The site represents a modest extension to an existing residential area, within a sustainable location. It represents a deliverable site to assist in meeting the Borough's housing need in the short term with negligible impact on the Green Belt and surrounding landscape. Plan Period
1.5 The proposed plan period runs until 2033. Assuming adoption in 2019, this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (Paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption.
1.6 This deficiency in the PSLP is of particular relevance given that the Borough is predominately Green Belt, and failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt; its permanence (NPPF, Paragraph 133).
2.0 Housing Need
2.1. There is an acute housing shortage at both the national and the local level. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.2. The National Planning Policy Framework (NPPF) attaches great importance to the need for Local Plans to meet objectively assessed housing needs. It is a requirement of a sound Local Plan. Furthermore, the NPPF calls for a significant boost to the supply of land for housing, and requires Local Planning Authorities to ensure a sufficient supply of sites to provide five years worth of land for housing against housing.
2.3. At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12 it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying PPG).
2.4. However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.
2.5. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum, not 350.
2.6. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years).
2.7. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need.
2.8. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum.
2.9. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.10. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities.
2.11. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional years' worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for.
2.12. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period.
Five-year housing land supply and housing trajectory
2.13. The Council is required to demonstrate a five-year housing land supply at any point in the plan period.
2.14. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.15. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied.
2.16. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years.
2.17. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.18. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a fiveyear requirement of 2,712 dwellings.
2.19. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises just 653 dwellings. It is unclear how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply.
2.21. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward.
2.22. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.23. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.24. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to deliver housing completions from 2022/23, i.e. falling within the first five years of the plan.
2.25. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
2.26. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this is required before development has even begun.
2.27. The ability of larger sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin review (2018) and issues with their complexity have been ably set out in the Lichfield Study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematic due to a range of factors, including establishing the required infrastructure, and the timings of housing delivery associated with those requirements as well as the prolonged or protracted nature of the planning process. The Litchfield's report confirms that the planning process takes on average 2.5yrs for the planning application determination period for schemes of up to 500 units, but that this can double for sites over 1,000 units.
2.28. BPM Investments Ltd is a company owned by housing specialists Arebray Development Consultancy, DAP Architecture and Silverstone Lane and they all deliver schemes consistently within Essex. They are able to provide detailed evidence on the delivery rates of minor and major developments. Two such hypothetical scenarios are provided with this representations (Appendix 3 and 4)
2.29. Scenario 1 provides a 50 Unit Brownfield site. This has outline planning consent and is to be marketed. It contains existing buildings that will require demolition and there is limited contamination. Access can be gained directly from the highway and all mains services are available to the edge of the site without any works required outside the site boundary.
2.30. Scenario 2 is a 200 unit Greenfield site at the edge of an existing settlement. The site is to have outline planning consent and is to be marketed. It is assumed there will be no significant delays due to Archaeology and Ecological constraints but recognise this could be greater depending upon the time of year the programme starts. It is assumed that the site is available for immediate development. Time is allowed for local infrastructure upgrades and new junction arrangements to provide access into the site.
2.31. These scenarios both assume that there are no delays and therefore represent a best case situation for two current projects. We have presumed that workflows will overlap where there are no commercial risks by doing so.
2.32. The scenarios confirm that large scale development can take up to 3yrs to provide the first dwellings after outline planning permission is approved, while smaller schemes are predicted to require two years for delivery of the first units. The timeframe is compounded by the scale of development, as recognized by the other reviews into delivery rates. For the strategic allocations in Brentwood, it is noted that the masterplanning stages are likely to add significantly to these timeframes, which follow from outline planning permission.
2.33. For the above reasons it is unrealistic to project that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound.
2.34. The strategic sites are expected to deliver 1,555 dwellings within 5yrs of adoption. Given the matters set out above, this is unrealistic and it would not be justified to rely on these sites to meet short term housing delivery. This emphasises the need to review sites such as ref. 067a and 067b to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is sound.
3.0 Spatial Strategy for Growth
3.1. Ingrave is identified as a Category 3 settlement -Villages in sparse rural locations that provide day to day needs for local residents. Ingrave has an established community, with services commensurate with its population. This is highlighted in the Council's own report of November 2017, paragraph 103, which confirmed that Ingrave and other Large Villages provide opportunities for small edge of settlement release to support housing growth. It is important that the Local Plan manages the growth of the settlement to ensure the vitality of its communities is sustained or enhanced.
3.2. Notwithstanding the above, the PSLP proposes to direct no additional growth to Ingrave. This contrasts with the approach to Blackmore, but otherwise the Council's preferred approach for Category 3 and 4 villages is to direct no growth over the plan period. This approach is considered to be unsustainable for these settlements. These views were raised at previous consultation stages. The spatial strategy fails to ensure the sustainable growth of Ingrave. The proposal to direct none of the Borough's housing need to Ingrave is unjustified, and inconsistent with national policy.
3.3. To ensure the Local Plan is sound, the special strategy should be amended to direct a proportionate level of growth to Ingrave. Housing Delivery
3.4. Paragraph 41 of the PSLP states that affordability ratios in Brentwood require an upward adjustment to the housing supply to be made.
3.5. It is recognised that the Council is deficient in providing a five year supply of housing land. It is therefore important to balance the strategic allocations with smaller sites, as these will generally have fewer constraints and can be delivered quickly to assist with meeting the persistent undersupply of housing in Brentwood. Such sites include land at Salmonds Grove, which can be delivered within the first five years of the plan.
3.6. The NPPF expects LPAs to identify the scale and mix of housing the local population is likely to need over the plan period which, among other matters, meets household and population projections, taking account of migration and demographic change; caters for housing demand and the scale of housing supply necessary to meet this demand.
3.7. The proposed plan does not account for migration from London, as identified in the PBA OAN report. This is contrary to the NPPF.
Green Belt
3.8. A detailed Green Belt Appraisal was prepared in respect of the Site by The Landscape Partnership and submitted at the Regulation 18 stage consultation. A copy is provided again here, for completeness (Appendix 5).
3.9. The Green Belt Appraisal considers the contribution of the site in relation to the five purposes of including land in the Green Belt, as per paragraph 134 of the NPPF: * To check the unrestricted sprawl of large built-up areas: * To prevent neighbouring towns merging into one another; * To assist in safeguarding the countryside from encroachment; * To preserve the setting and special character of historic towns; and * To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
3.10. The Green Belt Appraisal provides a thorough review of the site in relation to these purposes, and concludes that: "The initial landscape appraisal fond that developing the site in the manner proposed, e.g. c.24 residential units, would be unlikely to result in any adverse effects on land with a landscape related designation, Conservation Area, or Ancient Woodland. Salmond's Grove Farmhouse to the south of the site is a Grade II Listed Building; however, there is intervening built form between it and the site and it is thus unlikely that development of the type proposed would have a material effect on the farmhouse's landscape setting" (paragraph 5.1.2).
3.11. The Green Belt and Visual Appraisal further concludes that the removal of the site from the Green Belt and its subsequent residential development, would have no significant adverse effect on other landscape features such as topography, hedges, etc.:
3.12. A Part 3 Green Belt Appraisal (dated 31 January 2019) has been published by the Council. This considers specific sites, albeit in limited detail.
3.13. There is no evidence that the findings of the Green Belt Appraisal that was produced in respect of the Site by the Landscape Partnership, and which considered the Site in far greater detail than the Council's Part 3 Green Belt Appraisal, have been taken into account.
3.14. We are concerned with the simplistic approach that appears to have been taken in considering the contribution sites make to the purposes of the Green Belt. Overview
3.15. The Council's own evidence base states that the site is suitable, available and achievable for development. Development of the site is supported by a wealth of technical evidence that confirms its suitability, including in relation to the lack of harm to its development to the purposes of the Green Belt.
3.16. The reasons given for the rejection of the site are spurious and based on erroneous conclusions.
3.17. The rejection of the site is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed over the plan period and the lack of support for any growth at Ingrave.
4.0 Land at Salmonds Grove, Ingrave
4.1. The site was discounted from the Site Considerations as part of the Council's Site Assessment Methodology (January 2018). Larger Villages (Category 3 Settlements) are set out in Appendix 6 of the Methodology and repeated in this representation as Appendix 4. The site was discounted on the basis of 'Green Belt Impact'.
4.2. Discounting Salmonds Grove on this basis is unjustified. The Methodology report states that sites were selected based on initial high-level assessments of the key assessment criteria, being, amongst other matters, flood risk, Green Belt, landscape, highways, historic assets, ecological designations, utilities, education and health facilities. There was, therefore, a reasonably extensive set of criteria analysed for each site (para.3.22- 23 of the Brentwood Draft Local Plan - Preferred Site Allocations Site Selection Methodology and Summary of Outcomes Working Draft). The conclusions for each assessment are summarised in the associated appendices of the Report, with Salmonds Grove in Appendix 6 (sites 067a&b).
4.3. For Salmonds Grove, the Site Assessment simply states that there would be 'Green Belt impact'. We are concerned that the assessment and the reasons for discounting an otherwise suitable, available and sustainable site, are not robust.
4.4. Salmond's Grove has been discounted at Stage 4 of the Site Assessments on the basis of an initial high-level assessment, which found that a site was (presumably) satisfactory and suitable on all criteria with the sole exception of impact on the Green Belt. If the site were unsuitable for other reasons, these would also be listed in Appendix 6 of the BBC Report.
4.5. Salmonds Grove adjoins Ingrave and is within Parcel 15 of the BBC Strategic Green Belt Assessment (SGBA). Parcel 15 is 458.4ha in extent, being a roughly square parcel extending from the east of Ingrave to the Borough Boundary. The Assessment concludes that the parcel is of high value to the purposes of the Green Belt. This is not surprising, given the extent of the parcel. However, this assessment is less helpful when assessing smaller sites that are well associated with the urban area, such as Salmonds Grove. The Assessment actually notes under Purpose 1 that the area is 'Very large parcel relative to Ingrave and Herogate'. This belies the unsatisfactory nature of the assessment when considering smaller sites and acknowledges the limitations of the Assessment for such sites. Tellingly, the Green Belt parcels with the least impact, Low-Moderate as identified through the Assessment, are mostly the smaller sites on the edges of urban areas (parcel Nos. 32; 45; 56; 07a (BBC Green Belt Study Part II: Green Belt Parcel Definition and Review; p.43).
4.6. Accordingly, in order to assist the Council in identifying suitable sites within large GB parcels, it is considered that a more fine-grain assessment of sites should be undertaken. This is particularly important, given that the Council are not able to meet the housing needs of the Borough and would meet the tests set out in Calverton Parish Council v Nottingham City Council & ors. [2015] EWHC 1078 (Admin).
4.7. As set out above, the promotor of the site has prepared a Landscape and Green Belt Assessment, providing a full analysis of how it contributes to the five purposes of including land in the Green Belt (Appendix 5).
4.8. This focused assessment concludes that the site: * would be unlikely to result in any adverse effects on land with a landscape-related designation, Conservation Area, or Ancient Woodland; * there would be no significant adverse effect on other landscape features such as topography, hedges; * the site exerts relatively little influence on the surrounding townscape and landscape beyond its immediate vicinity; * Salmond's Grove site makes a Low contribution to the Green Belt purposes, and it could be developed in the manner proposed without compromising the objectives of the wider Green Belt.
4.9. To ensure the plan is sound, it is considered that additional sites should be identified and allocated. Those sites should include those of less importance to the Green Belt, such as Salmonds Grove, Ingrave. Not to include the site in the Local Plan is unjustified.

The Policies Map should be published for affected parties to comment on if necessary, making the plan clear and effective.

1.0 Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of S&J Padfield and Partners (S&J Padfield). They are submitted pursuant to Brentwood Borough Council's (BBC's) Regulation 19 Pre-submission version of the Consultation Draft Local Plan.
1.2 S&J Padfield are the landowners of land at Codham Hall Farm, which is currently utilised for employment purposes. The site is within a strategic location to the north of the A127 at M25 Junction 29, benefiting from these strategic road links.
1.3 The site is proposed to be allocated under Policy E10 for 9.6ha of employment and 8.0ha of landscaping. The site currently supports approximately 350 jobs, contributing significantly to the provision of jobs to support the growth of the Borough.
1.4 Representations have previously been made on behalf of S&J Padfield throughout the plan making process, most recently to the 2018 Focused Review consultation.
1.5 The following sections set out the proposals in the context of the Regulation 19 Draft Local Plan, commenting on draft policies considered relevant to securing the delivery of the strategic employment sites, and Site E10 in particular.
1.6 Where any concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy.
1.7 S&J Padfield requests the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of Examination of the submitted Local Plan.
2.0 Comments on Regulation 19 Local Plan
Section 3 - Spatial Strategy, Visions, and Objectives
2.1 Section 3 of the plan sets out the Spatial Strategy, Visions, and Objectives of the Local Plan, and how it seeks to deliver the required development to support the needs of the Borough. Strategic Objectives are set out on page 38.
2.2 We support the wording of policies SO1 and SO3 in particular.
2.3 SO1 seeks to deliver growth in sustainable locations. In order for the Local Plan to be sound, it is essential that it ensures the Borough's growth is managed and sustainable. As per the National Planning Policy Framework (NPPF) (paragraph 8), achieving sustainable development means pursuing environmental, social and economic objectives; recognising these objectives are interdependent and mutually supportive. It is critical that these objectives are carried forward into the detailed policies and allocations of the Local Plan.
2.4 We support strategic objective SO3. In particular, we welcome its recognition of the importance of the economic climate to the borough's communities. We support the recognition of the importance of identifying opportunities for economic growth - the NPPF is clear on the need for Local Plans to look to realise opportunities for development.
2.5 Also set out in the Strategic Objectives is the reasoning behind the Various Growth areas set out in the plan. We broadly support the identified growth areas and the strategy, which seeks to deliver growth along the established transport corridors of the A127 and A12. Paragraph 3.21 part b) sets out the proposals for delivering employment growth in the M25/A127 areas.
Section 5 - Transport and Connectivity
2.6 Section 5 of the Local Plan seeks to ensure that transport infrastructure is delivered alongside the housing and economic growth.
2.7 We support the intent of Paragraph 5.105 in seeking to improve sustainable transport measures in the South Brentwood Growth Corridor. We would caution that transport improvements should be undertaken and required on a site specific basis, recognising the scale of new growth at each location. In the case of site E10 at Codham Hall, the employment uses on site are existing and therefore the allocation will provide for modest further growth, which should be recognised in considering any transport improvements required.
Policy BE13 - Sustainable means of travel
2.8 Policy BE13 refers to sustainable means of travel, setting out criteria for new development. Sites allocated for development have site specific policies within the Local Plan, which include criteria on transport and it is not currently clear whether Policy BE13 imposes additional requirements. In order to be effective in accordance with the tests of soundness, Policy BE13 should therefore be clearer that it does not impose additional requirements.
Section 7 - Prosperous Communities
2.9 Section 7 of the Local Plan sets out how the Local Plan seeks to maintain and create prosperous communities, with economic growth a key part of this. Policy PC02 sets out that provision is made for 5,000 additional jobs over the Plan period, with a total of circa 47.39 ha of new employment land allocations and continued support for existing employment sites. Such an approach is positively prepared, seeking to support employment growth within the Borough.
2.10 The allocation of Codham Hall supports the existing employment on site and plays a part in delivering such employment and jobs, potentially allowing the growth of the existing employment area over the plan period. As recognised in the Local Plan, the A127 corridor provides an opportunity for sustainable economic growth along this strategic route, with Codham Hall Farm providing such sustainable economic growth.
2.11 To understand the jobs growth in the Borough, an Economic Futures 2013-2033 report has been prepared by Lichfields to support the Local Plan. The Economic Futures report sets out a range of scenarios, forecasting a need between 20.3 ha and 8.1 ha of land to be used for Class B employment uses.
2.12 The Local Plan seeks to allocate an additional 47.4 ha of employment land, in part compensating for the loss of 21 ha of existing allocated employment land to other uses.
2.13 The Local Plan also anticipates there could be a further loss of employment land over the plan period due to structural change, changes in allocation threshold and changes of use through permitted development, forecasting a loss of 4.65 ha over the plan period.
2.14 Figure 7.5 of the Local Plan sets out that there is therefore a need for 33.76 to 45.96 ha of new employment land to be allocated. The 47.4 ha allocated is therefore over the highest anticipated requirement.
2.15 The approach of allocating more employment land than anticipated to be needed is positively prepared, providing a buffer should the loss of current employment land be greater than anticipated. Allocating further employment land could assist in providing greater flexibility should sites not come forward as intended or greater losses in employment space occur.
2.16 At 9.6 ha of employment land, the Codham Hall site is one of the largest employment sites with only 3 sites being over 6 ha and the remainder comprising numerous smaller sites. Codham Hall therefore provides a significant proportion of the employment land requirement, albeit this consists of existing businesses, and it is important that its development is supported and encouraged. Its allocation therefore assists in the Local Plan strategy relating to economic growth being positively prepared and justified.
Policy PC05 - Employment Development Criteria
2.17 Policy PC05 sets out criteria for employment development. Similar to concerns raised with Policy PC03, it is currently ambiguous whether this applies to employment development coming forward on allocated employment sites. To ensure the Local Plan is effective and to avoid inconsistencies, Policy PC05 should be clear that it does not apply to allocated employment sites.
Policy NE9 - Green Belt
2.18 Policy NE9 states that 'Green Belt within Brentwood Borough (as defined in the Brentwood Policies Map) will be preserved from inappropriate development...'. However, despite this wording no Policies Map has been published.
2.19 Appendix 4 of the Local Plan sets out that maps detailing various changes, including Green Belt boundary amendments, will be provided for Regulation 19 consultation and there will be a combined policies map.
2.20 The Policies Map is an important aspect of the Local Plan and should be published to provide clarity over the Green Belt boundaries to ensure these are clearly defined for all parties and that it can be protected from inappropriate development in accordance with Policy NE9 and the NPPF.
2.21 Once the Policies Map is published we may have further comments on behalf of our client in relation to the Green Belt boundaries and whether these are fully justified and reserve our position to be able to do so at the appropriate time.
Policy E10 - Codham Hall Farm
2.22 Policy E10 sets out that the site is allocated for employment use as shown in Appendix 2 of the Local Plan. 9.6 ha is allocated as employment land with 8 ha to provide for landscaping, amenity, access and ancillary uses to support the sustainability of the site.
2.23 We support the allocation of the site for employment purposes and removal of it from the Green Belt, being justified, effective and consistent with national policy.
2.24 The allocation of the site will recognise the long term employment use of the site, whilst supporting future applications for further economic growth. Being one of the largest employment sites in the Borough, the protection and support of this employment land is an important aspect of the Borough's economic growth over the plan period.
2.25 The Economic Futures 2013-2033 report published within the Local Plan's evidence base suggests the site can deliver an additional 100 jobs over the plan period, which we consider a conservative estimate. The site has the potential to deliver a significant number of jobs over the plan period, supported by its allocation as an employment site.
Removal of Site from the Green Belt
2.26 The NPPF is clear that authorities should seek to meet housing and economic growth within their boundaries, and that Green Belt boundaries can be altered through the preparation of a Local Plan where exceptional circumstances exist (paragraph 136).
2.27 The NPPF does not define what constitutes 'exceptional circumstances'. However, case law may assist BBC and the preparation of its Local Plan in this respect. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors. [2015] EWHC 1078 (Admin) suggests (paragraph 51 of the judgement) the following matters are relevant in the consideration of whether exceptional circumstances exist:
(i) The scale of the objectively assessed need;
(ii) Constraints on supply/availability of land with the potential to accommodate sustainable development;
(iii) Difficulties in achieving sustainable development without impinging on the Green Belt;
(iv) The nature and extent of the harm to the Green Belt; and
(v) The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
2.28 In respect of the first three points, through the plan-making process, BBC has evidenced a substantial need for development; and there are clearly severe limitations on options to meet this need without altering the Green Belt with 89% of the Borough currently falling within the Green Belt. Similarly, options to deliver sustainable development without amendments to the Green Belt boundary are very limited.
2.29 In respect of the fourth and fifth points, a Green Belt Review has been published as part of the Local Plan consultation. Within this, the site was assessed as overall making a low-moderate contribution towards the purposes of the Green Belt. Of all the 23 potential employment sites assessed, only 7 received a score of low-moderate or low, being the remaining scoring moderate or above.
2.30 It is noted the most recent Green Belt assessment only assesses the site to be allocated as employment land and not the land allocated for landscaping. This was previously assessed by BBC as part of a much wider parcel of land in an earlier version of the Green Belt assessment, which did not provide a site specific assessment. An assessment of the site as a whole was undertaken by Liz Lake Associates (as submitted with Regulation 18 representations), which found the whole site does not contribute to the purposes of the Green Belt.
2.31 It has been demonstrated that removal of the site from the Green Belt will not cause significant harm to the Green Belt as a whole, with the fourth and fifth points of the Calverton judgment being met. Exceptional circumstances in accordance with paragraph 136 of the NPPF and the Calverton judgment have been demonstrated to justify amending the Green Belt boundary to remove the site.
Allocation Boundary
2.32 The allocation boundary is set out in Appendix 2 of the Local Plan, with two boundaries given. The existing employment area and some additional land is shown as white land, with surrounding land hatched in green.
2.33 It should be noted that BBC have not published an overarching policies map alongside the Local Plan, with the only maps being those in Appendix 2 of the Local Plan. These maps do not show the revised Green Belt boundary for the Borough.
2.34 In the absence of such detail on a map, or clarity within Policy E10, it is not clear whether the whole site is removed from the Green Belt which is not consistent with national policy or effective.
2.35 Policy E10 should therefore be clear that the site as a whole is removed from the Green Belt. With the majority of the site already being utilised for employment purposes and the whole site not contributing to the Green Belt purposes, making it explicitly clear that the site as a whole is removed from the Green Belt will be positively prepared, justified, effective and consistent with national policy.
2.36 It should also be noted that Codham Hall is the only employment allocation where the whole site is not shown as white land and has green hatching. It would be clearer and more effective if the site as a whole was shown as white land to clarify that landscaping, amenity, access and ancillary uses are appropriate in this area. There is otherwise the risk that a planning application for such uses could be considered against Green Belt policies rather than as being in accordance with Policy E10.
Potential Access and Impact of Lower Thames Crossing
2.37 Land South of the A127 is allocated under Policy E11 as Brentwood Enterprise Park (BEP) to provide at least 25.85 ha of land for employment use and other ancillary development. This will therefore provide further facilities for employees at Codham Hall Farm, being within easy reach.
2.38 Policy E11 refers to infrastructure works needed, including potential access points via M25 Junction 29. There are also potential improvements to Junction 29 to provide a slip road from the A127 directly to the M25, which will have an impact upon the existing access from the M25 to BEP.
2.39 It is therefore important that the Codham Hall Farm allocation reflects the potential need for enhanced access through the site to the BEP. The plan included at Appendix A shows the potential land required to support the BEP access solution, which could affect the land currently shown as white land under Policy E10.
2.40 It is important to note that not all of the land will be required, and the plan is based on a series of access solutions that are currently being discussed with the LTC, Essex County Council and other stakeholders. Crucially, the plan shows the quantum of land that may be required from the Codham Hall allocation. It is considered that the employment land lost to support this access solution, if utilised, is sourced elsewhere on the site to ensure no overall loss.
2.41 This provides further justification to showing the whole site as white land within Policy E10, allowing the employment and ancillary uses to be located within the site as required without compromising the amount of employment floor space provided. Such flexibility in where the uses are provided will be justified and positively prepared.
Policy E10 Development Principles
2.42 Part B of Policy E10 sets out development principles for the site. Whilst the allocation on site is generally supported we do wish to raise objection to the wording in its current form.
2.43 Criteria b sets out a requirement to "protect and where appropriate enhance the adjoining Local Wildlife Site (Codham Hall Wood)". The site is outside of the allocation area and our client's control. The policy should therefore not require enhancement and this part of the requirement should be removed.
2.44 Criteria c states "preserve and where appropriate enhance the Public Right of Way through Site". Whilst the need to maintain public rights of way is recognised the current wording fails to provide for potential diversion if required. This should be allowed for in the policy wording.
2.45 Criteria d requires the "provision of improved walking and cycling connections within the site and to the wider area." This is a regulation of an existing site and new development proposals are likely to be focused on smaller scale improvements or new provision on site. These are unlikely to in themselves always justify improved walking and cycling connections and this requirement should accordingly be changed to state "potential to walking and cycling connections".
2.46 Paragraph 9.219 of the Local Plan expands upon this and seeks the submission of a workplace travel plan to promote the benefits of sustainable transport. In the case of site E10 it is important the policy recognises that this is regularisation of existing uses and that additional infrastructure improvements are unlikely to be justified.
2.47 A Framework Travel Plan will consider the implications of increased growth at the Codham Hall Farm site and opportunities for sustainable transport. There is currently no travel plan in place on the site for the existing employment uses, with the production of a travel plan for the whole site therefore being an improvement of the current situation and a benefit of allocating of the site.
3.0 Summary
3.1 Overall we support the removal of the Codham Hall Farm site from the Green Belt and its allocation for employment. BBC have identified a high rate of housing and economic growth which the Local Plan seeks to meet within the Borough, being positively prepared in this regard.
3.2 With 89% of the Borough currently identified as Green Belt, BBC have been required to review the Green Belt boundaries for both housing and economic growth. In respect of Codham Hall Farm, we support the conclusion that exceptional circumstances have been demonstrated to justify amending the Green Belt boundary in accordance with paragraph 136 of the NPPF.
3.3 Policy E10 fails to be fully effective at the current time as it contains two red line boundaries for the allocation and it is ambiguous whether the whole site is to be removed from the Green Belt. We consider that exceptional circumstances have been demonstrated to support the removal of the site as a whole from the Green Belt, with such an approach being sufficiently clear for all parties and providing support for future applications on the site. We therefore consider it necessary for an amendment to be made to Policy E10 to clarify that the whole site is removed from the Green Belt to ensure the policy is justified and effective.
3.4 Amendments to the wording of Policy E10 should be made to reflect the nature of the site and that this allocation covers existing employment uses rather than new provision.
3.5 BEP is located to the south of the site on the opposite side of the A127, with this development providing further ancillary facilities which could also be used by the employees of Codham Hall Farm.
3.6 There could be a requirement for an enhanced access link through the Codham Hall Farm site to BEP depending upon improvements to the A127 and M25 Junction 29. This provides further justification to making Policy E10 explicitly clear that the whole site is removed from the Green Belt to ensure any future application is supported by BBC.
3.7 Whilst we support the allocation of Codham Hall Farm for employment, we have raised some areas of concern with the soundness of parts of the Local Plan under paragraph 35 of the NPPF. We therefore welcome the opportunity to engage with BBC and the Inspector at the Local Plan Examination hearing sessions to explore these concerns and suggested amendments further.

1. Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of St Modwen Developments Limited ("St Modwen"). They are submitted pursuant to Brentwood Borough Council's (BBC) Pre-submission Version of the Regulation 19 Consultation Draft Local Plan ("Draft Local Plan"), and in particular, with regard to the proposed allocation of the Land south of the A127 at Junction 29 as the proposed Brentwood Enterprise Park (BEP).
1.2 This representation sets out St Modwen's position in relation to the commercial site specific allocation ("BEP Site") which is proposed by Policy E11 in the Draft Local Plan. St Modwen has an interest in the BEP Site pursuant to a development agreement dated 23 June 2015. The freehold owner of the BEP Site is Christopher Scott Padfield.
1.3 The draft allocation proposed by Policy E11 is the single largest employment allocation within the Draft Local Plan, comprising a developable area of 25.85ha of employment land. The BEP seeks to deliver approximately 2,000 jobs in a sustainable location. The BEP Site therefore plays a particularly important role in providing a significant element of BBC's employment land requirements. The BEP site will contribute significantly to the provision of jobs to support the growth of the borough.
1.4 Representations have previously been made on behalf of S&J Padfield and St. Modwen in respect of this site throughout the plan making process and most recently to the 2018 Draft Local Plan - Preferred Site Allocations Consultation.
1.5 The BEP Site is located at M25 Junction 29 to the south of the A127. It should be noted that another employment site included within the Draft Local Plan, at Policy E10 (Codham Hall Farm), is situated to the north of the A127.
1.6 This Regulation 19 representation is focussed on the soundness of the Local Plan, as per paragraph 35 of the NPPF (i.e. whether this draft Local Plan is positively prepared; justified; effective, and consistent with national policy); and legal compliance.
1.7 The Draft Local Plan represents the proposed final version of the Local Plan for the borough, and is supported by a raft of technical studies and evidence.
1.8 Due to the binary nature of consultation at this stage (which is recognised is a function of the regulations1) where changes are suggested to ensure the Local Plan is sound and / or legally compliant, these are expressed as objections. However, we wish to stress that fundamentally, and particularly in relation to the proposed allocation of new employment land at the BEP Site, we support the Draft Local Plan.
Brentwood Enterprise Park
1.9 The BEP provides in the region of 26ha of employment land as part of a successfully masterplanned proposal within a wider site of 35.5ha, to also include ancillary landscaping works. It is intended that the proposed development at the BEP Site will provide new floorspace for a range of B-use classes, supporting jobs and employment growth in a range of sectors including (but not necessarily limited to) storage & distribution, office space, and professional services.
1.10 The following sections set out the proposals in the context of the Draft Local Plan and provide commentary on the draft policies insofar as they are relevant to the delivery of new employment floorspace, and particular in respect of the BEP Site allocation at Policy E11.
1.11 Where any concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist BBC in ensuring the Local Plan is sound, in terms of being positively prepared, effective, justified and consistent with national policy.
1.12 St. Modwen requests the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the examination of the submitted Local Plan.
2. Policy E11 - Brentwood Enterprise Park
2.1 We wish to make clear that we support the principle of this policy and the vast majority of it is sound. However, we consider there are elements of this policy which are not effective and justified, and therefore require modification. As such, and given the binary nature of consultation at this stage, this response is expressed as an objection.
Policy E11 part C d)
2.2 We do not concur with part C d) of Policy E11. This part of the policy presently requires that the public right of way is preserved and enhanced. Whilst it is recognised that the right of way will need to be maintained, this may be through appropriate diversion if required. The policy wording presently is ambiguous in this regard and may imply that the right of way must be preserved in its current form. This could pose a risk to delivery and would not be a justified and effective approach in accordance with the tests of soundness set out at paragraph 35 of the NPPF. Accordingly, we request that sub-paragraph 'd.' of part C of Policy E11 be amended so that it reads as follows:
"preserve, through diversion if necessary, and where appropriate enhance the existing Public Right of Way through the site".
Policy E11 part D c), d) and e)
2.3 Furthermore, we consider that the references to infrastructure requirements in sub-paragraphs c., d. and e. of part D of Policy E11 should be amended to make clear that such provision will be required where appropriate. The wording at present is overly prescriptive and lacks flexibility would not therefore be a justified and effective approach in accordance with the tests of soundness set out at paragraph 35 of the NPPF. It may not, for example, be appropriate to provide direct walking connection towards junction 29 and the western site boundary.
2.4 With regards to public transport links we consider it important to recognise the site is one of a number of growth locations and should not be responsible for provision of new transport links alone. As identified in the transport work undertaken by Atkins on behalf of St Modwen, there is potential for accessibility to be provided through private shuttle bus services for example rather than formal public transport or buses. We consider that this part of the policy is not adequately justified, and while provision for bus access and links to external walkways and cycle ways is supported in principle, the implementation of a wider strategy for sustainable travel and public transport should be delivered by the appropriate local authorities, with relevant contributions sought from developers where the legal tests relating to planning obligations (i.e. regulation 122(2) of the Community Infrastructure Levy Regulations 2010) are met. In this regard, we are aware of the strategy put forward for public transport in this area, as outlined in Appendix G of the Transport Assessment. This is discussed later in the representation, and the wider interaction with other allocations in the Southern Growth Corridor concerning the implementation of this strategy is supported.
2.5 We consider this part of the policy should be amended to read:
c. provide well-connected internal road layouts which allow good accessibility for bus services or sustainable transport measures where appropriate
d. potential travel planning measures and connection to new public transport links with the surrounding area; and
e. provision for walking and cycling connections within the site and to the surrounding area where appropriate
Delivery of the BEP
2.6 The landowners and St. Modwen are committed to delivering the BEP scheme and continue to actively engage with the Council on a pre-application basis, and in terms of the delivery of the development proposals generally.
2.7 The reference in Appendix 2 to the BEP Site's delivery forecasting being "Years 5-15" should be amended instead to state: "Years 1 - 15" in order to reflect the intentions of the landowners and St Modwen and in particular the potential for early delivery of a phase of development using the existing access arrangements.
2.8 Importantly, as set out later in this representation, amendments to the allocation area and policies map are also required in order to provide for flexibility with regards to access options.
2.9 Other relevant policy considerations with regards to the allocation at Policy E11 and the supporting evidence base are set out below.
Green Belt
2.10 Firstly, addressing the principle of Green Belt release, this is considered justified and consistent with national policy in the case of Policy E11; as well as being necessary to ensure the Local Plan is sound.
2.11 The NPPF states that if Green Belt boundaries are to be altered then this should be done through preparation or updating of plans (see paragraph 136), and only when exceptional circumstances are fully evidenced and justified.
2.12 The NPPF does not define what constitutes 'exceptional circumstances'. However, case law does provide assistance in this regard. In particular, the judgment of the High Court in Calverton Parish Council v Nottingham City Council & Ors. [2015] EWHC 1078 (Admin) suggests (see paragraph 51 of the judgment) the following matters are relevant in the consideration of whether exceptional circumstances exist:
(i) the scale of the objectively assessed need;
(ii) constraints on supply/availability of land with the potential to accommodate sustainable development;
(iii) difficulties in achieving sustainable development without impinging on the Green Belt;
(iv) the nature and extent of the harm to the Green Belt; and
(v) the extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
2.13 In respect of the first three points, through the plan-making process, BBC has evidenced a substantial need for development; and there are clearly severe limitations on options to meet this need without altering the Green Belt. Similarly, options to deliver sustainable development - including through the realising the opportunities the Brentwood Enterprise Park presents - without amendments to the Green Belt boundary are very limited.
Landscaping
2.14 In addition, the allocation also seeks to deliver landscaping and groundworks to further improve the visual amenity between the site and the surrounding landscape. Given the Green Belt location of the site, we consider that provisions for landscaping within the site allocation policy is reasonably justified.
2.15 Furthermore, the Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options report by Crestwood on behalf of BBC is supported. We note in particular Appendix L3 of the Landscape Sensitivity and Capacity Study finds that the site is Low Landscape Sensitivity, Low Landscape Value, with a resultant High Landscape Capacity (a high capacity site being more readily able to accommodate development).
2.16 Appendix L4, the Landscape Character Assessment (LCA), states Moderate Overall Sensitivity to Change, and considers the Site within the LCA as being Low (as L3 above). Appendix L5 summarises the capacity for development as High (the highest it can be). We agree that the site should be preferentially prioritised for development when considering effects on the landscape, and consider that the site is justified for inclusion in the plan on this basis. Further, it is considered the plan has been positively prepared in the way it has considered and identified sites that have are shown to have capacity in terms of effect on the surrounding landscape.
Economic Evidence Base
2.17 The Draft Local Plan evidence base includes input on the economic forecasts for the Council, including commentary on job growth, employment land requirements and how they relate with growth in other areas. The provision of around 2,000 jobs will undoubtedly aid in achieving the social aspect of sustainability in respect of the NPPF, providing employment opportunities to facilitate the growth of the borough.
2.18 The number of jobs and job capacity is largely derived from the estimate of employment floorspace. The Economic Futures document has estimated the number of jobs to be provided on the basis that all employment allocations come forward, while also stating that the purported numbers are indicative. Paragraph 4.1 sets out the methodology for calculating job capacity, with the report going on to state that BEP will provide a total of 4,070 new jobs. We do not consider this figure to be justified, principally because it is based on an over-assumption of the amount of office space that may be provided. The number of jobs will depend on final mix of uses however estimates based on employment density guidance indicates in the region of 2,000 jobs, due mainly to the lower estimation for the amount of office space to be provided by the scheme.
2.19 The economic evidence base supporting the quantum and location of employment land is considered in more detail in Section 5 of this representation in the context of Policy PC03 - Job Growth & Employment Land.
Transport and Access
2.20 The BEP Site allocation is ideally located to provide direct access to the strategic road network for the commercial vehicles that will be generated by the proposed business uses on the site. This will avoid the adverse impacts of commercial vehicles, including HGVs, on the local road network and local residents, that would be likely to occur if these business uses were located on an alternative site or sites that did not have direct access to the strategic road network.
2.21 As further discussed within this representation, studies have shown that access to the strategic road network for BEP which is compatible with the LTC proposals for J29 is achievable, and therefore the allocation of the BEP is not compromised by the LTC, should it be delivered.
2.22 The transport assessment undertaken to assess the potential impact of the Local Plan on the road network adopts a methodology that forecasts future demand based predominantly on historic trends, in terms of trip generation and background traffic growth. It does not fully account for the likely demand suppression that will occur due to worsening traffic congestion on the road network, i.e. constrained network capacity, which is known to be taking place and driving changes in travel behaviour including:
a. Fewer and short journeys being undertaken through more working from home, combining trips, ordering of goods and services over the internet, etc.
b. Shift to using alternative modes of transport such as public transport, walking and cycling
c. Changes in the timing of journeys to avoid the most congested period
2.23 Additionally, emerging internet based services, such as ride sharing, mobility as a service and demand responsive public transport, are likely to further change the way that people choose to travel in the future, all of which are forecast to temper or lessen future traffic growth. The transport assessment undertaken in support of the Local Plan recognises that these changes in how people are travelling are already taking place and are likely to accelerate, with evidence of this now being seen in the most recent travel statistics.
2.24 Consequently, the cumulative traffic demand on the road network forecast in the Local Plan should not be interpreted as the likely outcome of the Local Plan site allocations. Instead it should be considered as an indicator of overall travel demand to inform future policy aimed at accommodating it in a more sustainable way that avoids the 'very worst case' forecast traffic growth. The traffic forecasts in the transport assessment should not, therefore, be relied upon to inform specific requirements for road network capacity enhancement schemes, since to do so would very likely result in unnecessarily excessive and expensive schemes.
2.25 It is also noted that the trip generation forecast for BEP used in the Local Plan transport assessment is based on the site having an employment capacity of approximately 3,000 jobs, which is considered to be an over estimate. Based on industry standard employment densities for the likely mix of business uses on the BEP Site which is proposed by St Modwen, the employment capacity is forecast to be approximately 2,000 jobs. Therefore, the Local Plan transport assessment overestimates the likely trip generation for BEP by as much as 50%.
2.26 The indicative plan of potential sustainable transport linkages shown in Figure 3.14 - Southern Growth Corridor: Sustainable Transport, included in the Infrastructure Delivery Plan should only be seen as an example of how the proposed development sites along the A127 could possibly be linked by a package of sustainable transport measures. It should not be seen as representing the specific measures that will be implemented. This is because further detailed evaluation is required to establish if they represent the most appropriate proposals, taking account of the wide range of sustainable transport measures that could be adopted by the different sites, and to confirm their deliverability (recent discussions with other parties involved with land along the A127 have mentioned the use of compulsory purchase powers, which can be a costly and lengthy process).
2.27 While recent engagement with David Ubaka Placemakers and other stakeholders in the Southern Growth Corridor has shed further light on the proposed sustainable transport measures, there is considered to be more work required before a detailed solution is available. It should therefore be recognised that the package of sustainable transport measures that will be implemented for the sites along the Southern Growth Corridor may ultimately be different to those presented in the Infrastructure Delivery Plan. The IDP itself is acknowledged to be a 'live' working document (see paragraph 1.2) and hence the final package of sustainable transport measures will be agreed at the planning application stage for the relevant development sites along the Southern Growth Corridor.
2.28 Fundamentally however, the allocation of sites including BEP, Childerditch Industrial Estate, West Horndon and DHGV along the A127 all make a strong business case for the implementation of a robust and efficient package of sustainable transport measures.
Lower Thames Crossing & Additional Land Required for Access
2.29 The BEP Site benefits from existing access to M25 junction 29 that can provide for a first phase of development and, in enhanced form, for access on a permanent basis should the Lower Thames Crossing not proceed.
2.30 Should the Lower Thames Crossing come forward, it is noted that latest proposals include potential slip roads at junction 29. This includes one running from the A127 westbound onto the M25 southbound at junction 29. The current proposals for the LTC would therefore conflict with both the existing and currently proposed access arrangements for the BEP.
2.31 Extensive liaison has been undertaken and will continue to be undertaken with representatives from Lower Thames Crossing, Highways England, Essex County Council, Peter Brett Associates and all other relevant parties. The Highways England LTC team have confirmed their commitment to proactively find solutions to allow BEP and the LTC to come forward in a manner which is mutually acceptable.
2.32 Key to this is an acknowledgement that certain land around junction 29 and the A127 will likely be needed for transport works should the LTC project proceed as currently envisaged. Accordingly, such land should be acknowledged in the Local Plan as being released from the Green Belt should it be required to provide works to allow for access to the BEP Site.
2.33 The plan at Appendix B shows the additional land that may be necessary to be released from the Green Belt in order for it to be developed for transport works to facilitate access to the BEP Site. Such release would only take effect if the land was needed for transport works to deliver access to the BEP Site.
2.34 At present, the options set out in Appendix B include land to facilitate access to junction 29, or to facilitate access to the BEP Site from the B186/Warley Street. This will likely include additional land to the north of the A127 to allow for potential access via junction 29 linking via an improved bridge, as well as land to the east including around the A127/B186 junction to allow for potential junction and slip road improvements. This includes land to the south along Warley Street to allow for potential realignment of the road / roundabout to provide access to the site.
2.35 Policy E11 must therefore be amended to acknowledge the above access options and to provide for the land to be released from the Green Belt for such purposes should that be required.
2.36 It is proposed that the policy wording seeks to ensure that works on this land are kept to the minimum necessary to facilitate the required access and highway improvements. It should also be noted that access infrastructure is likely to be at grade (or below) existing levels and would not add any significant volume/built structures to the land, and therefore any impact on openness would therefore be limited.
2.37 The need to maintain the possibility of achieving safe, satisfactory access arrangements to the largest employment land allocation in the borough in the context of the LTC is considered an exceptional circumstance, and therefore warrants this additional land to be removed from the Green Belt if required.
2.38 Further, Paragraph 146 of the NPPF sets out the forms of development that are not inappropriate in the Green Belt, provided the preserve openness and do not conflict with the purposes of including land within it. This includes, at point c), local transport infrastructure which can demonstrate a requirement for a Green Belt location.
2.39 This approach has been used in the nearby East Herts District, where the recently adopted East Herts District Plan 2018 found that in order to provide necessary highway capacity to meet the wider needs of existing residents and businesses, as well as for future growth, the connectivity over the River Stort requires significant improving. In accordance with the NPPF, the Council considered it appropriate for new crossings to be located across Green Belt land, and as a result of the adopted plan, East Herts District Council are working with other LPAs and Authorities to explore landownership associated with the delivery of additional transport capacity, and also reviewed the use of CPO powers if deemed necessary. Whilst this approach could also be adopted in Brentwood there is a need for the Local Plan to provide for release of land from the Green Belt for access should this be required.
2.40 It is additionally noted the Brentwood IDP indicates the potential implementation of sustainable transport measures around the site. The release and identification of such land on the proposals map is therefore an important requirement for the Local Plan.
2.41 In order to achieve the above, we request that the first paragraph of Policy E11 is amended to read as follows:
"Land south east of M25 Junction 29, as shown on Appendix 2, is allocated to provide high quality employment development and a significant number of jobs.
In addition, the areas of land (shown on the plan at Appendix 2) shall be released from the Green Belt for works to provide access to the site should this be necessary. The final extent of the land that is released for such works shall be identified in a planning application and shall be kept to the minimum necessary to provide an appropriate and safe access to the Brentwood Enterprise Park Site along with any associated highway and infrastructure works.
Development proposals for the Brentwood Enterprise Park site should consider the following:"
2.42 The plan at Appendix 2 to the Draft Local Plan will need to be updated to be in line with the plan attached at Appendix B of these representations.
3. Section 3 Spatial Strategy, Vision and Strategic Objectives
SO1: Manage Growth Sustainably
3.1 We support strategic objective SO1. In order for the Local Plan to be sound, it is essential that it ensures the borough's growth is managed, and in a sustainable manner. As per the NPPF (paragraph 8), achieving sustainable development means pursuing environmental, social and economic objectives; recognising these objectives are interdependent and mutually supportive. It is critical that these objectives are carried forward into the detailed policies and allocations of the Local Plan.
SO3: Deliver Sustainable Communities with Diverse Economic & Social-cultural Opportunities for All
3.2 We support strategic objective SO3. In particular, we welcome its recognition of the importance of the economic climate to the borough's communities. We support the recognition of the importance of identifying opportunities for economic growth - the NPPF is clear on the need for Local Plans to look to realise opportunities for development.
3.3 Also set out in the Strategic Objectives section is the reasoning behind the identified key growth areas. We broadly support the identified key growth areas and the strategy, which seeks to deliver growth along the established transport corridors of the A127 and A12. Paragraph 3.21 part b) sets out the proposals for delivering employment growth in the M25/A127 areas.
Growth Areas
3.4 We support the identification of the opportunity to provide a strategic employment allocation at the BEP Site. Such an approach accords with the Draft Local Plan's strategic objectives pertaining to the identification of economic growth opportunities, and thereby assists in ensuring this objective is effective. The BEP would deliver significant economic, social and environmental benefits, allowing it to come forward as a sustainable growth location to support the growth of the borough.
3.5 Fundamentally, the provision of employment land provides job opportunities and space to deliver economic growth not just in Brentwood, but throughout the region. The well-connected highway network and provisions for sustainable transport links will ensure that the BEP Site provides employment space that will make best use of its location, set within easy reach of London, DP World, the Dartford Crossing and other notable businesses and employment centres. It is recognised in the plan that other proposed infrastructure projects, such as the Lower Thames Crossing, are most beneficial to distributors and companies that are of a certain scale, who will require larger spaces and facilities from which to run their businesses. As such, employment proposals such as BEP are required not just to provide economic growth and opportunity in their own right, but also to harness the opportunities granted by future infrastructure.
3.6 The provision of jobs and employment to support the borough's population is key and the social benefits of the BEP development would principally derive from the number of jobs provided by the development, enabling future and existing residents of the borough to live and work within the locality. It is intended that a planning application will be progressed immediately and delivery on site can come forward over the next 1-15-year period, potentially providing several years' worth of construction jobs and contracts in the construction sector alone.
3.7 Currently, St. Modwen's strategy continues to be for a planning application to be prepared for submission alongside the examination in 2019, targeting determination following receipt of the Inspector's Report and adoption of the Local Plan. This pro-active approach, if reflected in an amendment to the BEP Site's delivery forecast, will lead to an effective plan that can allow for the site to come forward expediently to address the borough's employment land needs.
3.8 The site is a sustainable location for development for employment uses owing to its location adjacent to the strategic highway network. Supporting large-scale employment growth here negates the need for the delivery of further employment uses in less sustainable and less suitable locations.
Figure 3.1 - Key Diagram
3.9 The identification of an employment-led development in the south-west of the borough is supported. Such a location is well-connected to the strategic highway network, which as set out above, facilitates connections to other key employment centres. As such, the proposed approach in this regard is justified. The allocation of the BEP Site for new employment development is clearly very much consistent with national policy; and will make a significant contribution to ensuring the Local Plan is positively prepared. Indeed, if the Key Diagram were not to identify and promote realisation of such an opportunity, we consider that such an approach could not be consistent with national policy or justified.
4. Section 5 - Transport and Connectivity
4.1 Successful delivery of the allocated development within the growth areas requires a grounded appreciation of the transport issues along the various corridors. Section 5 of the Draft Local Plan covers how the Plan seeks to develop a resilient built environment. Page 92 sets out the Transport and Connectivity related policies.
4.2 We support part C of Policy BE11: Strategic Transport Infrastructure, which sets out how the Council will continue to liaise with Highways Authorities and other key stakeholders to ensure the necessary improvements to ensure highway infrastructure capacity is maintained. We welcome BBC's proactive approach in this respect.
4.3 We support the wording in Paragraph 5.105 relating to the South Brentwood Growth Corridor, particularly the intent for BBC to work proactively with developers and stakeholders along the A127. We recognise the need to work collaboratively to address any transport impacts the BEP development may have on the highway network.
4.4 We concur with paragraph 5.107, which raises doubt on the scale and timelines associated with the impacts of the proposed Lower Thames Crossing. Having liaised extensively with the LTC teams, we are aware of the proposals and their relationship with the Brentwood Enterprise Park. We can confirm that the LTC teams and ourselves are committed to the realisation of both projects in a mutually acceptable manner and discussions are on-going in this regard.
4.5 Policy BE13 should acknowledge that site specific policies provide details of how sustainable travel opportunities will be achieved in respect of each site. Accordingly, Policy BE13 should be amended so that it is made clear that it does not have the effect of imposing any requirements on the allocated sites that are in addition to those set out in the individual site allocation policies.
5. Section 7 - Prosperous Communities
5.1 The Economic Aims and Strategy priorities set out within Section 7.3 are supported. We consider these will help facilitate sustainable development, which is of course required to ensure the Local Plan is sound.
5.2 The Brentwood Enterprise Park will provide a range of employment types in a sustainable location. The proposals have been designed to reflect the need for a greater proportion of B-type use classes, supporting jobs in a range of industries that will make the most of the site's location adjacent to an established highways network, fundamentally meeting Economic Aim A1.
5.3 The scheme will provide in the region of 2,000 jobs on an area that makes up around 54% of the land identified for employment use within the Draft Local Plan. Economic Aim E2 seeks the provision of high value, diverse employment uses that will provide a significant number of high skilled and quality jobs.
PC02: Job Growth and Employment Land
5.4 The Draft Local Plan has as part of its evidence base a document entitled 'Brentwood Economic Futures 2013-2033', prepared by Lichfields, which sets out the economic evidence base in support of the Local Plan. We have reviewed the available economic evidence and also considered the conclusions drawn from that document, in particular how it determines the amount of employment land required to support the needs of the borough throughout the next plan period.
5.5 Principally, we have some reservations as to the quantum of employment land that is proposed under the various scenarios considered as part of the study. While each of the scenarios has considered relevant factors conducive to understanding the amount of employment land required, we consider that the Council should be considering the Experian based forecasts set out under Scenario A as a minimum requirement of employment land. The other scenarios do not provide an adequately robust assessment of the land required to support the necessary employment growth.
5.6 In terms of the quantum discussed within the evidence base, the Local Plan forecasts a need between 20.3 ha (Scenario A) and 8.1 ha (Scenario D) for land to be used for B-class employment uses. The Plan seeks to allocate an additional 47.4ha (with BEP accounting for around 55% of this total allocation), allowing for the compensation of the loss of 21.ha of current employment land to other uses. While it is positive that the Council has sought to address the loss of existing land, while also seeking to provide over and above the highest amount required by the Scenario A (Experian figures generated using SHMA data), we would consider the Council could be more proactive by allowing for a greater buffer beyond the requirement of land set out under Scenario A. Such a buffer would ensure flexibility, and therefore effectiveness, should any of the smaller site allocations not be delivered within the timescales envisaged.
5.7 The site's location on the outskirts of London is also considered to assist in addressing the trend for the reduction in B-class land uses within the capital. Situated adjacent to the M25 and A127, the site presents an attractive destination for London firms requiring B1c/B2 and B8 floorspace. Elsewhere in Brentwood, this ability to capitalise on the migration of such employment uses from London is not being realised, as the supply of land for industrial uses is below any of the closest competing Boroughs (Brentwood's supply of industrial land was just 205,000 sq m in 2015/16). In order to attract industrial employers and capture employment opportunities migrating from London, sites like Brentwood Enterprise Park are required to provide the required space and land uses.
5.8 Therefore, not only is BEP the foremost important asset for the Borough in terms of employment land, but especially as an option for the development of B1c, B2, and B8. The loss of the land allocation at BEP would seriously impede the borough's ability to grow in the future, and to take advantage of likely future geographical changes in location and demand for B-class employment uses.
5.9 When further considering and allocations required to deliver the number of jobs to be provided, it is critical that the Local Plan:
a) Provides for sufficient flexibility to be able to respond to rapid change (as required by paragraph 11 of the NPPF); and
b) Does so in a manner that ensures the Green Belt boundary will not need to be reviewed before the end of the plan period (paragraph 136 of the NPPF).
5.10 In respect of this, it must be recognised that the borough is predominantly Green Belt. The Council has evidenced that the current Green Belt boundaries are required to be amended by the new Local Plan (which is appropriate, as per paragraph 136 of the NPPF). In reviewing the Green Belt boundaries at this juncture, it is important that the Council is confident that the amended Green Belt will not have to be altered again in five years, when the Local Plan is required to be reviewed. As such, in considering the scale of land to be allocated to meet development needs through this Local Plan, it is important that a precautionary approach is taken so that the amount of land that is released from the Green Belt is sufficient to ensure delivery of the sites that are allocated in the Local Plan for development.
5.11 We therefore object to Policy PC02, on the basis that at the very least it should be amended such that land allocations are expressed as minimums. If Policy PC02 is amended to state that the allocation of 47.39 ha of new employment land is a minimum this will ensure that the plan is positively prepared, effective and consistent with national policy.
7.19 and 7.20 Employment Land Provision
5.12 Having regard to our comments in respect of Policy PC02 - the need to ensure flexibility; and the need to ensure the revised Green Belt boundary will be capable of enduring beyond the plan period - the Local Plan must use the higher growth forecasts and plan accordingly. In addition, it is important that the Council is satisfied the proposed allocation of employment land is sufficient in respect of the requirements outlined in our response to Policy PC02 regarding the need for both flexibility and for the Green Belt to be able to endure during the plan period.
Policy PC03: Employment Land Allocations
5.13 Policy PC03 sets out a number of considerations which are intended to relate to existing and proposed employment sites identified in Figure 7.6. Brentwood Enterprise Park is listed as one such site in Figure 7.6 of the Draft Local Plan.
5.14 The Draft Local Plan also proposes a specific site allocation policy for the BEP, (Policy E11).
5.15 Policy PC03 contains a prescriptive list of the circumstances when non B-class uses will be permitted in respect of "Redevelopment or change of use of business, office, general industry and distribution". Given that Policy E11 refers to the possibility of development for uses other than B-class uses i.e. for "any associated employment generating sui generis uses" we assume this part of Policy PC03 relates only to existing employment sites. However, in order for the policy to be effective, the policy should be amended so that the opening paragraph reads as follows:
"Within those areas allocated for general employment and office development, set out in Figure 7.6 and on the Brentwood Policies Map, the Council will seek to achieve and retain a wide range of employment opportunities. Further details in this regard are set out in the individual site allocation policies.
In relation to existing employment sites redevelopment for non B-class uses will only be permitted where:"
Paragraph 7.23 - b) part i)
5.16 The reference to BEP within the context of opportunities for growth within the South Brentwood Growth Corridor is welcomed and supported. However, in our view the reference to "redeveloping brownfield land" in sub-paragraph (b)(i) is unnecessary given that the BEP Site has been assessed by the Council and considered to be suitable for strategic employment development. Accordingly, for purposes of clarity we request that sub-paragraph b. i. is reworded to read as follows: "developing land at Brentwood Enterprise Park (see Policy E11)". This would also correct the typographical error of "Site E01" which should instead refer to E11.
Paragraph 7.25
5.17 The NPPF calls for Local Plans to make use of development opportunities. The recognition that the Lower Thames Crossing represents an opportunity which Brentwood Enterprise Park will realise is supported, as this is consistent with relevant national planning policy.
PC05 - Replicates Site Specific policies
5.18 As currently worded, the Draft Local Plan is ambiguous as to whether this policy is intended to apply to proposed as well as existing employment land. If it is intended to apply to new allocations, then similar concerns to those that we expressed in relation to policy PC03 also apply here. To ensure the Local Plan is effective, to avoid inconsistency, and so that it is clear how a decision maker should react to development proposes, Policy PC05 should be amended to make clear it does not apply to the new employment site allocations because these policies have (as applicable) clear 'Development Principles' and 'Infrastructure Requirements'.
6. Section 8 - Natural Environment
NE08 - Lighting Restrictions
6.1 We support what we have inferred is the intended objective of this policy: to ensure lighting schemes are appropriate for the use to which they are associated, and potential harm arising from lighting schemes is minimised. In respect of policy BE08 A a) we suggest that, order to provide greater clarity as to how a decision maker should react to development proposals, it is acknowledged that employment land may well require the provision of lighting for security and operational purposes.
Policy NE9: Green Belt
6.2 It is considered necessary (in respect of the effectiveness of the Local Plan and compliance with the NPPF, in relation to the need to ensure policies are not ambiguous) that the Local Plan makes clear where land is being removed from the Green Belt (such as in respect of the allocation contained in Policy E11). It is suggested that text is added to this policy to clarify that the Local Plan is altering the Green Belt boundaries.
Policy NE13: Site Allocations in the Green Belt
6.3 The policy should be amended to provide clarity that sites are being removed to enable employment needs to be met, in addition to housing. It should be recognised that the development of employment uses has intrinsic community benefits, with resultant social and economic gains.
Potential additional land required for access to Brentwood Enterprise Park
6.4 As covered in elsewhere in our representation, owing to factors arising from the proposals for the Lower Thames Crossing (LTC), it is considered that additional land may need to be released from the Green Belt in order to ensure appropriate access to the BEP Site can be provided.
7. Strategic Environmental Assessment / Sustainability Appraisal
7.1 The Draft Local Plan is accompanied by a Sustainability Appraisal that has been prepared by AECOM, which assesses all sites put forward against a number of criteria in order to ascertain an overview of the sustainability credentials of a site or location. The SA concludes that the BEP Site is suitable for the intended proposals when considered on its own merits and when considered against other options within the borough.
7.2 Turning to the more specific aspects of the proposed allocation, the SA finds that the site scores moderately well when considered against other options for growth put forward at the various stages of plan preparation. While we agree with the allocation, and consider that the SA supports the sustainability of the site location, we consider that a number of the assessed criteria could be more accurately represented.
7.3 The SA broadly supports the inclusion of the Brentwood Enterprise Park within the plan, stating all sites will have good or excellent access onto the strategic highway network, and Brentwood Enterprise Park will provide an opportunity for high-end modern premises, along with appropriate ancillary uses, e.g. a hotel.
7.4 Table C from the Sustainability Appraisal is included above, showing how the BEP site (ref 101Aii) has been assessed against the criteria set out within the plan. It is noted that the site has been scored low in respect of relationship to Local Wildlife Sites, Ancient woodland and also with regard to Air Quality Management Areas (AQMAs).
7.5 It is noted that the criteria in Table B of the SA state that the thresholds have been selected on the basis that County Wildlife Sides and Ancient Semi Natural Woodlands have a relatively low sensitivity. However, the proposed allocation at Brentwood Enterprise Park is adjacent to the Hobbs Hole, and does not directly intersect with it. While a medium score would be more appropriate in this regard, it is important to note that the proposed scheme also provide opportunities for the enhancement of the Hobbs Hole site through the provision of effective landscaping schemes and ecological management.
7.6 The criteria set out in Table B stipulates that a low score is given to sites in or adjacent to an Air Quality Management Area (AQMA), and a medium score will be given if located within a kilometre of an AQMA. Despite not satisfying either of these criteria, the site has scored low in respect of its effect on Air Quality Management Areas. The Assessment justifies this, noting that growth along the A127 corridor can be expected to lead to increased traffic in the Brentwood town centre Air Quality Management Area, which is located some 5km to the north.
7.7 The SA does however follow this up by stating that "there is some uncertainty in respect of this conclusion, given the potential to deliver significant upgrades to walking/cycling and public transport infrastructure through a focus at DHGV, as well as to deliver employment and a local centre (to include a secondary school) on-site." We support this view, and concur that the growth locations identified in the southern corridor cumulatively make a strong business case for the implementation of sustainable transport linkages and necessary infrastructure that will ultimately lessen the perceived effect on the nearest AQMAs. As such, we feel that a medium score would be more appropriate in this regard.
7.8 Finally, on the SA, it is considered to be ineffective to judge the merits of a site for employment use with regard to its proximity to services such as a GP, Primary School and Secondary School. While these services may be considered key to the delivery of successful residential allocations, they are not relevant indicators of sustainability of potential employment sites. The site has been scored low in all three aspects, due to the distance it is located from these services, and we also consider that these scores should be 'NA'.
7.9 As such, the current SA may suggest the proposed BEP is less sustainable than it actually is and this references should be updated. However, it is also relevant to note that the SA is still considered this site as a merited allocation despite this.
8. Summary
8.1 This representation has considered the Brentwood Borough Council Regulation 19 Draft Local Plan against the test of soundness as set out at Paragraph 35 of the NPPF, with specific reference made to the allocation of land for the development of the Brentwood Enterprise Park scheme.
8.2 The representation sets out how the plan, whilst fundamentally sound, is not completely justified or effective with regard to ensuring the adequate delivery of sufficient employment land to support the planned growth of the borough. Furthermore, references to certain of the draft policies and supporting evidence show that the plan should be amended to be more positively prepared and consistent with National Planning Policy.
8.3 Proposed modifications to the plan to address these matters are set out including in relation to Policy E11.
8.4 We request that we be invited to attend the relevant sessions of the forthcoming examination hearings in order that we can provide the Inspector with further oral evidence and explanation in support of these representations.
Appendix A - Letter from Highways England regarding Lower Thames Crossing
Appendix B - Potential land required for access solutions (ref: 5183535-ATK-ZZ-DR-D-0001)

1. Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of St Modwen Developments Limited ("St Modwen"). They are submitted pursuant to Brentwood Borough Council's (BBC) Pre-submission Version of the Regulation 19 Consultation Draft Local Plan ("Draft Local Plan"), and in particular, with regard to the proposed allocation of the Land south of the A127 at Junction 29 as the proposed Brentwood Enterprise Park (BEP).
1.2 This representation sets out St Modwen's position in relation to the commercial site specific allocation ("BEP Site") which is proposed by Policy E11 in the Draft Local Plan. St Modwen has an interest in the BEP Site pursuant to a development agreement dated 23 June 2015. The freehold owner of the BEP Site is Christopher Scott Padfield.
1.3 The draft allocation proposed by Policy E11 is the single largest employment allocation within the Draft Local Plan, comprising a developable area of 25.85ha of employment land. The BEP seeks to deliver approximately 2,000 jobs in a sustainable location. The BEP Site therefore plays a particularly important role in providing a significant element of BBC's employment land requirements. The BEP site will contribute significantly to the provision of jobs to support the growth of the borough.
1.4 Representations have previously been made on behalf of S&J Padfield and St. Modwen in respect of this site throughout the plan making process and most recently to the 2018 Draft Local Plan - Preferred Site Allocations Consultation.
1.5 The BEP Site is located at M25 Junction 29 to the south of the A127. It should be noted that another employment site included within the Draft Local Plan, at Policy E10 (Codham Hall Farm), is situated to the north of the A127.
1.6 This Regulation 19 representation is focussed on the soundness of the Local Plan, as per paragraph 35 of the NPPF (i.e. whether this draft Local Plan is positively prepared; justified; effective, and consistent with national policy); and legal compliance.
1.7 The Draft Local Plan represents the proposed final version of the Local Plan for the borough, and is supported by a raft of technical studies and evidence.
1.8 Due to the binary nature of consultation at this stage (which is recognised is a function of the regulations1) where changes are suggested to ensure the Local Plan is sound and / or legally compliant, these are expressed as objections. However, we wish to stress that fundamentally, and particularly in relation to the proposed allocation of new employment land at the BEP Site, we support the Draft Local Plan.
Brentwood Enterprise Park
1.9 The BEP provides in the region of 26ha of employment land as part of a successfully masterplanned proposal within a wider site of 35.5ha, to also include ancillary landscaping works. It is intended that the proposed development at the BEP Site will provide new floorspace for a range of B-use classes, supporting jobs and employment growth in a range of sectors including (but not necessarily limited to) storage & distribution, office space, and professional services.
1.10 The following sections set out the proposals in the context of the Draft Local Plan and provide commentary on the draft policies insofar as they are relevant to the delivery of new employment floorspace, and particular in respect of the BEP Site allocation at Policy E11.
1.11 Where any concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist BBC in ensuring the Local Plan is sound, in terms of being positively prepared, effective, justified and consistent with national policy.
1.12 St. Modwen requests the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the examination of the submitted Local Plan.
2. Policy E11 - Brentwood Enterprise Park
2.1 We wish to make clear that we support the principle of this policy and the vast majority of it is sound. However, we consider there are elements of this policy which are not effective and justified, and therefore require modification. As such, and given the binary nature of consultation at this stage, this response is expressed as an objection.
Policy E11 part C d)
2.2 We do not concur with part C d) of Policy E11. This part of the policy presently requires that the public right of way is preserved and enhanced. Whilst it is recognised that the right of way will need to be maintained, this may be through appropriate diversion if required. The policy wording presently is ambiguous in this regard and may imply that the right of way must be preserved in its current form. This could pose a risk to delivery and would not be a justified and effective approach in accordance with the tests of soundness set out at paragraph 35 of the NPPF. Accordingly, we request that sub-paragraph 'd.' of part C of Policy E11 be amended so that it reads as follows:
"preserve, through diversion if necessary, and where appropriate enhance the existing Public Right of Way through the site".
Policy E11 part D c), d) and e)
2.3 Furthermore, we consider that the references to infrastructure requirements in sub-paragraphs c., d. and e. of part D of Policy E11 should be amended to make clear that such provision will be required where appropriate. The wording at present is overly prescriptive and lacks flexibility would not therefore be a justified and effective approach in accordance with the tests of soundness set out at paragraph 35 of the NPPF. It may not, for example, be appropriate to provide direct walking connection towards junction 29 and the western site boundary.
2.4 With regards to public transport links we consider it important to recognise the site is one of a number of growth locations and should not be responsible for provision of new transport links alone. As identified in the transport work undertaken by Atkins on behalf of St Modwen, there is potential for accessibility to be provided through private shuttle bus services for example rather than formal public transport or buses. We consider that this part of the policy is not adequately justified, and while provision for bus access and links to external walkways and cycle ways is supported in principle, the implementation of a wider strategy for sustainable travel and public transport should be delivered by the appropriate local authorities, with relevant contributions sought from developers where the legal tests relating to planning obligations (i.e. regulation 122(2) of the Community Infrastructure Levy Regulations 2010) are met. In this regard, we are aware of the strategy put forward for public transport in this area, as outlined in Appendix G of the Transport Assessment. This is discussed later in the representation, and the wider interaction with other allocations in the Southern Growth Corridor concerning the implementation of this strategy is supported.
2.5 We consider this part of the policy should be amended to read:
c. provide well-connected internal road layouts which allow good accessibility for bus services or sustainable transport measures where appropriate
d. potential travel planning measures and connection to new public transport links with the surrounding area; and
e. provision for walking and cycling connections within the site and to the surrounding area where appropriate
Delivery of the BEP
2.6 The landowners and St. Modwen are committed to delivering the BEP scheme and continue to actively engage with the Council on a pre-application basis, and in terms of the delivery of the development proposals generally.
2.7 The reference in Appendix 2 to the BEP Site's delivery forecasting being "Years 5-15" should be amended instead to state: "Years 1 - 15" in order to reflect the intentions of the landowners and St Modwen and in particular the potential for early delivery of a phase of development using the existing access arrangements.
2.8 Importantly, as set out later in this representation, amendments to the allocation area and policies map are also required in order to provide for flexibility with regards to access options.
2.9 Other relevant policy considerations with regards to the allocation at Policy E11 and the supporting evidence base are set out below.
Green Belt
2.10 Firstly, addressing the principle of Green Belt release, this is considered justified and consistent with national policy in the case of Policy E11; as well as being necessary to ensure the Local Plan is sound.
2.11 The NPPF states that if Green Belt boundaries are to be altered then this should be done through preparation or updating of plans (see paragraph 136), and only when exceptional circumstances are fully evidenced and justified.
2.12 The NPPF does not define what constitutes 'exceptional circumstances'. However, case law does provide assistance in this regard. In particular, the judgment of the High Court in Calverton Parish Council v Nottingham City Council & Ors. [2015] EWHC 1078 (Admin) suggests (see paragraph 51 of the judgment) the following matters are relevant in the consideration of whether exceptional circumstances exist:
(i) the scale of the objectively assessed need;
(ii) constraints on supply/availability of land with the potential to accommodate sustainable development;
(iii) difficulties in achieving sustainable development without impinging on the Green Belt;
(iv) the nature and extent of the harm to the Green Belt; and
(v) the extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
2.13 In respect of the first three points, through the plan-making process, BBC has evidenced a substantial need for development; and there are clearly severe limitations on options to meet this need without altering the Green Belt. Similarly, options to deliver sustainable development - including through the realising the opportunities the Brentwood Enterprise Park presents - without amendments to the Green Belt boundary are very limited.
Landscaping
2.14 In addition, the allocation also seeks to deliver landscaping and groundworks to further improve the visual amenity between the site and the surrounding landscape. Given the Green Belt location of the site, we consider that provisions for landscaping within the site allocation policy is reasonably justified.
2.15 Furthermore, the Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options report by Crestwood on behalf of BBC is supported. We note in particular Appendix L3 of the Landscape Sensitivity and Capacity Study finds that the site is Low Landscape Sensitivity, Low Landscape Value, with a resultant High Landscape Capacity (a high capacity site being more readily able to accommodate development).
2.16 Appendix L4, the Landscape Character Assessment (LCA), states Moderate Overall Sensitivity to Change, and considers the Site within the LCA as being Low (as L3 above). Appendix L5 summarises the capacity for development as High (the highest it can be). We agree that the site should be preferentially prioritised for development when considering effects on the landscape, and consider that the site is justified for inclusion in the plan on this basis. Further, it is considered the plan has been positively prepared in the way it has considered and identified sites that have are shown to have capacity in terms of effect on the surrounding landscape.
Economic Evidence Base
2.17 The Draft Local Plan evidence base includes input on the economic forecasts for the Council, including commentary on job growth, employment land requirements and how they relate with growth in other areas. The provision of around 2,000 jobs will undoubtedly aid in achieving the social aspect of sustainability in respect of the NPPF, providing employment opportunities to facilitate the growth of the borough.
2.18 The number of jobs and job capacity is largely derived from the estimate of employment floorspace. The Economic Futures document has estimated the number of jobs to be provided on the basis that all employment allocations come forward, while also stating that the purported numbers are indicative. Paragraph 4.1 sets out the methodology for calculating job capacity, with the report going on to state that BEP will provide a total of 4,070 new jobs. We do not consider this figure to be justified, principally because it is based on an over-assumption of the amount of office space that may be provided. The number of jobs will depend on final mix of uses however estimates based on employment density guidance indicates in the region of 2,000 jobs, due mainly to the lower estimation for the amount of office space to be provided by the scheme.
2.19 The economic evidence base supporting the quantum and location of employment land is considered in more detail in Section 5 of this representation in the context of Policy PC03 - Job Growth & Employment Land.
Transport and Access
2.20 The BEP Site allocation is ideally located to provide direct access to the strategic road network for the commercial vehicles that will be generated by the proposed business uses on the site. This will avoid the adverse impacts of commercial vehicles, including HGVs, on the local road network and local residents, that would be likely to occur if these business uses were located on an alternative site or sites that did not have direct access to the strategic road network.
2.21 As further discussed within this representation, studies have shown that access to the strategic road network for BEP which is compatible with the LTC proposals for J29 is achievable, and therefore the allocation of the BEP is not compromised by the LTC, should it be delivered.
2.22 The transport assessment undertaken to assess the potential impact of the Local Plan on the road network adopts a methodology that forecasts future demand based predominantly on historic trends, in terms of trip generation and background traffic growth. It does not fully account for the likely demand suppression that will occur due to worsening traffic congestion on the road network, i.e. constrained network capacity, which is known to be taking place and driving changes in travel behaviour including:
a. Fewer and short journeys being undertaken through more working from home, combining trips, ordering of goods and services over the internet, etc.
b. Shift to using alternative modes of transport such as public transport, walking and cycling
c. Changes in the timing of journeys to avoid the most congested period
2.23 Additionally, emerging internet based services, such as ride sharing, mobility as a service and demand responsive public transport, are likely to further change the way that people choose to travel in the future, all of which are forecast to temper or lessen future traffic growth. The transport assessment undertaken in support of the Local Plan recognises that these changes in how people are travelling are already taking place and are likely to accelerate, with evidence of this now being seen in the most recent travel statistics.
2.24 Consequently, the cumulative traffic demand on the road network forecast in the Local Plan should not be interpreted as the likely outcome of the Local Plan site allocations. Instead it should be considered as an indicator of overall travel demand to inform future policy aimed at accommodating it in a more sustainable way that avoids the 'very worst case' forecast traffic growth. The traffic forecasts in the transport assessment should not, therefore, be relied upon to inform specific requirements for road network capacity enhancement schemes, since to do so would very likely result in unnecessarily excessive and expensive schemes.
2.25 It is also noted that the trip generation forecast for BEP used in the Local Plan transport assessment is based on the site having an employment capacity of approximately 3,000 jobs, which is considered to be an over estimate. Based on industry standard employment densities for the likely mix of business uses on the BEP Site which is proposed by St Modwen, the employment capacity is forecast to be approximately 2,000 jobs. Therefore, the Local Plan transport assessment overestimates the likely trip generation for BEP by as much as 50%.
2.26 The indicative plan of potential sustainable transport linkages shown in Figure 3.14 - Southern Growth Corridor: Sustainable Transport, included in the Infrastructure Delivery Plan should only be seen as an example of how the proposed development sites along the A127 could possibly be linked by a package of sustainable transport measures. It should not be seen as representing the specific measures that will be implemented. This is because further detailed evaluation is required to establish if they represent the most appropriate proposals, taking account of the wide range of sustainable transport measures that could be adopted by the different sites, and to confirm their deliverability (recent discussions with other parties involved with land along the A127 have mentioned the use of compulsory purchase powers, which can be a costly and lengthy process).
2.27 While recent engagement with David Ubaka Placemakers and other stakeholders in the Southern Growth Corridor has shed further light on the proposed sustainable transport measures, there is considered to be more work required before a detailed solution is available. It should therefore be recognised that the package of sustainable transport measures that will be implemented for the sites along the Southern Growth Corridor may ultimately be different to those presented in the Infrastructure Delivery Plan. The IDP itself is acknowledged to be a 'live' working document (see paragraph 1.2) and hence the final package of sustainable transport measures will be agreed at the planning application stage for the relevant development sites along the Southern Growth Corridor.
2.28 Fundamentally however, the allocation of sites including BEP, Childerditch Industrial Estate, West Horndon and DHGV along the A127 all make a strong business case for the implementation of a robust and efficient package of sustainable transport measures.
Lower Thames Crossing & Additional Land Required for Access
2.29 The BEP Site benefits from existing access to M25 junction 29 that can provide for a first phase of development and, in enhanced form, for access on a permanent basis should the Lower Thames Crossing not proceed.
2.30 Should the Lower Thames Crossing come forward, it is noted that latest proposals include potential slip roads at junction 29. This includes one running from the A127 westbound onto the M25 southbound at junction 29. The current proposals for the LTC would therefore conflict with both the existing and currently proposed access arrangements for the BEP.
2.31 Extensive liaison has been undertaken and will continue to be undertaken with representatives from Lower Thames Crossing, Highways England, Essex County Council, Peter Brett Associates and all other relevant parties. The Highways England LTC team have confirmed their commitment to proactively find solutions to allow BEP and the LTC to come forward in a manner which is mutually acceptable.
2.32 Key to this is an acknowledgement that certain land around junction 29 and the A127 will likely be needed for transport works should the LTC project proceed as currently envisaged. Accordingly, such land should be acknowledged in the Local Plan as being released from the Green Belt should it be required to provide works to allow for access to the BEP Site.
2.33 The plan at Appendix B shows the additional land that may be necessary to be released from the Green Belt in order for it to be developed for transport works to facilitate access to the BEP Site. Such release would only take effect if the land was needed for transport works to deliver access to the BEP Site.
2.34 At present, the options set out in Appendix B include land to facilitate access to junction 29, or to facilitate access to the BEP Site from the B186/Warley Street. This will likely include additional land to the north of the A127 to allow for potential access via junction 29 linking via an improved bridge, as well as land to the east including around the A127/B186 junction to allow for potential junction and slip road improvements. This includes land to the south along Warley Street to allow for potential realignment of the road / roundabout to provide access to the site.
2.35 Policy E11 must therefore be amended to acknowledge the above access options and to provide for the land to be released from the Green Belt for such purposes should that be required.
2.36 It is proposed that the policy wording seeks to ensure that works on this land are kept to the minimum necessary to facilitate the required access and highway improvements. It should also be noted that access infrastructure is likely to be at grade (or below) existing levels and would not add any significant volume/built structures to the land, and therefore any impact on openness would therefore be limited.
2.37 The need to maintain the possibility of achieving safe, satisfactory access arrangements to the largest employment land allocation in the borough in the context of the LTC is considered an exceptional circumstance, and therefore warrants this additional land to be removed from the Green Belt if required.
2.38 Further, Paragraph 146 of the NPPF sets out the forms of development that are not inappropriate in the Green Belt, provided the preserve openness and do not conflict with the purposes of including land within it. This includes, at point c), local transport infrastructure which can demonstrate a requirement for a Green Belt location.
2.39 This approach has been used in the nearby East Herts District, where the recently adopted East Herts District Plan 2018 found that in order to provide necessary highway capacity to meet the wider needs of existing residents and businesses, as well as for future growth, the connectivity over the River Stort requires significant improving. In accordance with the NPPF, the Council considered it appropriate for new crossings to be located across Green Belt land, and as a result of the adopted plan, East Herts District Council are working with other LPAs and Authorities to explore landownership associated with the delivery of additional transport capacity, and also reviewed the use of CPO powers if deemed necessary. Whilst this approach could also be adopted in Brentwood there is a need for the Local Plan to provide for release of land from the Green Belt for access should this be required.
2.40 It is additionally noted the Brentwood IDP indicates the potential implementation of sustainable transport measures around the site. The release and identification of such land on the proposals map is therefore an important requirement for the Local Plan.
2.41 In order to achieve the above, we request that the first paragraph of Policy E11 is amended to read as follows:
"Land south east of M25 Junction 29, as shown on Appendix 2, is allocated to provide high quality employment development and a significant number of jobs.
In addition, the areas of land (shown on the plan at Appendix 2) shall be released from the Green Belt for works to provide access to the site should this be necessary. The final extent of the land that is released for such works shall be identified in a planning application and shall be kept to the minimum necessary to provide an appropriate and safe access to the Brentwood Enterprise Park Site along with any associated highway and infrastructure works.
Development proposals for the Brentwood Enterprise Park site should consider the following:"
2.42 The plan at Appendix 2 to the Draft Local Plan will need to be updated to be in line with the plan attached at Appendix B of these representations.
3. Section 3 Spatial Strategy, Vision and Strategic Objectives
SO1: Manage Growth Sustainably
3.1 We support strategic objective SO1. In order for the Local Plan to be sound, it is essential that it ensures the borough's growth is managed, and in a sustainable manner. As per the NPPF (paragraph 8), achieving sustainable development means pursuing environmental, social and economic objectives; recognising these objectives are interdependent and mutually supportive. It is critical that these objectives are carried forward into the detailed policies and allocations of the Local Plan.
SO3: Deliver Sustainable Communities with Diverse Economic & Social-cultural Opportunities for All
3.2 We support strategic objective SO3. In particular, we welcome its recognition of the importance of the economic climate to the borough's communities. We support the recognition of the importance of identifying opportunities for economic growth - the NPPF is clear on the need for Local Plans to look to realise opportunities for development.
3.3 Also set out in the Strategic Objectives section is the reasoning behind the identified key growth areas. We broadly support the identified key growth areas and the strategy, which seeks to deliver growth along the established transport corridors of the A127 and A12. Paragraph 3.21 part b) sets out the proposals for delivering employment growth in the M25/A127 areas.
Growth Areas
3.4 We support the identification of the opportunity to provide a strategic employment allocation at the BEP Site. Such an approach accords with the Draft Local Plan's strategic objectives pertaining to the identification of economic growth opportunities, and thereby assists in ensuring this objective is effective. The BEP would deliver significant economic, social and environmental benefits, allowing it to come forward as a sustainable growth location to support the growth of the borough.
3.5 Fundamentally, the provision of employment land provides job opportunities and space to deliver economic growth not just in Brentwood, but throughout the region. The well-connected highway network and provisions for sustainable transport links will ensure that the BEP Site provides employment space that will make best use of its location, set within easy reach of London, DP World, the Dartford Crossing and other notable businesses and employment centres. It is recognised in the plan that other proposed infrastructure projects, such as the Lower Thames Crossing, are most beneficial to distributors and companies that are of a certain scale, who will require larger spaces and facilities from which to run their businesses. As such, employment proposals such as BEP are required not just to provide economic growth and opportunity in their own right, but also to harness the opportunities granted by future infrastructure.
3.6 The provision of jobs and employment to support the borough's population is key and the social benefits of the BEP development would principally derive from the number of jobs provided by the development, enabling future and existing residents of the borough to live and work within the locality. It is intended that a planning application will be progressed immediately and delivery on site can come forward over the next 1-15-year period, potentially providing several years' worth of construction jobs and contracts in the construction sector alone.
3.7 Currently, St. Modwen's strategy continues to be for a planning application to be prepared for submission alongside the examination in 2019, targeting determination following receipt of the Inspector's Report and adoption of the Local Plan. This pro-active approach, if reflected in an amendment to the BEP Site's delivery forecast, will lead to an effective plan that can allow for the site to come forward expediently to address the borough's employment land needs.
3.8 The site is a sustainable location for development for employment uses owing to its location adjacent to the strategic highway network. Supporting large-scale employment growth here negates the need for the delivery of further employment uses in less sustainable and less suitable locations.
Figure 3.1 - Key Diagram
3.9 The identification of an employment-led development in the south-west of the borough is supported. Such a location is well-connected to the strategic highway network, which as set out above, facilitates connections to other key employment centres. As such, the proposed approach in this regard is justified. The allocation of the BEP Site for new employment development is clearly very much consistent with national policy; and will make a significant contribution to ensuring the Local Plan is positively prepared. Indeed, if the Key Diagram were not to identify and promote realisation of such an opportunity, we consider that such an approach could not be consistent with national policy or justified.
4. Section 5 - Transport and Connectivity
4.1 Successful delivery of the allocated development within the growth areas requires a grounded appreciation of the transport issues along the various corridors. Section 5 of the Draft Local Plan covers how the Plan seeks to develop a resilient built environment. Page 92 sets out the Transport and Connectivity related policies.
4.2 We support part C of Policy BE11: Strategic Transport Infrastructure, which sets out how the Council will continue to liaise with Highways Authorities and other key stakeholders to ensure the necessary improvements to ensure highway infrastructure capacity is maintained. We welcome BBC's proactive approach in this respect.
4.3 We support the wording in Paragraph 5.105 relating to the South Brentwood Growth Corridor, particularly the intent for BBC to work proactively with developers and stakeholders along the A127. We recognise the need to work collaboratively to address any transport impacts the BEP development may have on the highway network.
4.4 We concur with paragraph 5.107, which raises doubt on the scale and timelines associated with the impacts of the proposed Lower Thames Crossing. Having liaised extensively with the LTC teams, we are aware of the proposals and their relationship with the Brentwood Enterprise Park. We can confirm that the LTC teams and ourselves are committed to the realisation of both projects in a mutually acceptable manner and discussions are on-going in this regard.
4.5 Policy BE13 should acknowledge that site specific policies provide details of how sustainable travel opportunities will be achieved in respect of each site. Accordingly, Policy BE13 should be amended so that it is made clear that it does not have the effect of imposing any requirements on the allocated sites that are in addition to those set out in the individual site allocation policies.
5. Section 7 - Prosperous Communities
5.1 The Economic Aims and Strategy priorities set out within Section 7.3 are supported. We consider these will help facilitate sustainable development, which is of course required to ensure the Local Plan is sound.
5.2 The Brentwood Enterprise Park will provide a range of employment types in a sustainable location. The proposals have been designed to reflect the need for a greater proportion of B-type use classes, supporting jobs in a range of industries that will make the most of the site's location adjacent to an established highways network, fundamentally meeting Economic Aim A1.
5.3 The scheme will provide in the region of 2,000 jobs on an area that makes up around 54% of the land identified for employment use within the Draft Local Plan. Economic Aim E2 seeks the provision of high value, diverse employment uses that will provide a significant number of high skilled and quality jobs.
PC02: Job Growth and Employment Land
5.4 The Draft Local Plan has as part of its evidence base a document entitled 'Brentwood Economic Futures 2013-2033', prepared by Lichfields, which sets out the economic evidence base in support of the Local Plan. We have reviewed the available economic evidence and also considered the conclusions drawn from that document, in particular how it determines the amount of employment land required to support the needs of the borough throughout the next plan period.
5.5 Principally, we have some reservations as to the quantum of employment land that is proposed under the various scenarios considered as part of the study. While each of the scenarios has considered relevant factors conducive to understanding the amount of employment land required, we consider that the Council should be considering the Experian based forecasts set out under Scenario A as a minimum requirement of employment land. The other scenarios do not provide an adequately robust assessment of the land required to support the necessary employment growth.
5.6 In terms of the quantum discussed within the evidence base, the Local Plan forecasts a need between 20.3 ha (Scenario A) and 8.1 ha (Scenario D) for land to be used for B-class employment uses. The Plan seeks to allocate an additional 47.4ha (with BEP accounting for around 55% of this total allocation), allowing for the compensation of the loss of 21.ha of current employment land to other uses. While it is positive that the Council has sought to address the loss of existing land, while also seeking to provide over and above the highest amount required by the Scenario A (Experian figures generated using SHMA data), we would consider the Council could be more proactive by allowing for a greater buffer beyond the requirement of land set out under Scenario A. Such a buffer would ensure flexibility, and therefore effectiveness, should any of the smaller site allocations not be delivered within the timescales envisaged.
5.7 The site's location on the outskirts of London is also considered to assist in addressing the trend for the reduction in B-class land uses within the capital. Situated adjacent to the M25 and A127, the site presents an attractive destination for London firms requiring B1c/B2 and B8 floorspace. Elsewhere in Brentwood, this ability to capitalise on the migration of such employment uses from London is not being realised, as the supply of land for industrial uses is below any of the closest competing Boroughs (Brentwood's supply of industrial land was just 205,000 sq m in 2015/16). In order to attract industrial employers and capture employment opportunities migrating from London, sites like Brentwood Enterprise Park are required to provide the required space and land uses.
5.8 Therefore, not only is BEP the foremost important asset for the Borough in terms of employment land, but especially as an option for the development of B1c, B2, and B8. The loss of the land allocation at BEP would seriously impede the borough's ability to grow in the future, and to take advantage of likely future geographical changes in location and demand for B-class employment uses.
5.9 When further considering and allocations required to deliver the number of jobs to be provided, it is critical that the Local Plan:
a) Provides for sufficient flexibility to be able to respond to rapid change (as required by paragraph 11 of the NPPF); and
b) Does so in a manner that ensures the Green Belt boundary will not need to be reviewed before the end of the plan period (paragraph 136 of the NPPF).
5.10 In respect of this, it must be recognised that the borough is predominantly Green Belt. The Council has evidenced that the current Green Belt boundaries are required to be amended by the new Local Plan (which is appropriate, as per paragraph 136 of the NPPF). In reviewing the Green Belt boundaries at this juncture, it is important that the Council is confident that the amended Green Belt will not have to be altered again in five years, when the Local Plan is required to be reviewed. As such, in considering the scale of land to be allocated to meet development needs through this Local Plan, it is important that a precautionary approach is taken so that the amount of land that is released from the Green Belt is sufficient to ensure delivery of the sites that are allocated in the Local Plan for development.
5.11 We therefore object to Policy PC02, on the basis that at the very least it should be amended such that land allocations are expressed as minimums. If Policy PC02 is amended to state that the allocation of 47.39 ha of new employment land is a minimum this will ensure that the plan is positively prepared, effective and consistent with national policy.
7.19 and 7.20 Employment Land Provision
5.12 Having regard to our comments in respect of Policy PC02 - the need to ensure flexibility; and the need to ensure the revised Green Belt boundary will be capable of enduring beyond the plan period - the Local Plan must use the higher growth forecasts and plan accordingly. In addition, it is important that the Council is satisfied the proposed allocation of employment land is sufficient in respect of the requirements outlined in our response to Policy PC02 regarding the need for both flexibility and for the Green Belt to be able to endure during the plan period.
Policy PC03: Employment Land Allocations
5.13 Policy PC03 sets out a number of considerations which are intended to relate to existing and proposed employment sites identified in Figure 7.6. Brentwood Enterprise Park is listed as one such site in Figure 7.6 of the Draft Local Plan.
5.14 The Draft Local Plan also proposes a specific site allocation policy for the BEP, (Policy E11).
5.15 Policy PC03 contains a prescriptive list of the circumstances when non B-class uses will be permitted in respect of "Redevelopment or change of use of business, office, general industry and distribution". Given that Policy E11 refers to the possibility of development for uses other than B-class uses i.e. for "any associated employment generating sui generis uses" we assume this part of Policy PC03 relates only to existing employment sites. However, in order for the policy to be effective, the policy should be amended so that the opening paragraph reads as follows:
"Within those areas allocated for general employment and office development, set out in Figure 7.6 and on the Brentwood Policies Map, the Council will seek to achieve and retain a wide range of employment opportunities. Further details in this regard are set out in the individual site allocation policies.
In relation to existing employment sites redevelopment for non B-class uses will only be permitted where:"
Paragraph 7.23 - b) part i)
5.16 The reference to BEP within the context of opportunities for growth within the South Brentwood Growth Corridor is welcomed and supported. However, in our view the reference to "redeveloping brownfield land" in sub-paragraph (b)(i) is unnecessary given that the BEP Site has been assessed by the Council and considered to be suitable for strategic employment development. Accordingly, for purposes of clarity we request that sub-paragraph b. i. is reworded to read as follows: "developing land at Brentwood Enterprise Park (see Policy E11)". This would also correct the typographical error of "Site E01" which should instead refer to E11.
Paragraph 7.25
5.17 The NPPF calls for Local Plans to make use of development opportunities. The recognition that the Lower Thames Crossing represents an opportunity which Brentwood Enterprise Park will realise is supported, as this is consistent with relevant national planning policy.
PC05 - Replicates Site Specific policies
5.18 As currently worded, the Draft Local Plan is ambiguous as to whether this policy is intended to apply to proposed as well as existing employment land. If it is intended to apply to new allocations, then similar concerns to those that we expressed in relation to policy PC03 also apply here. To ensure the Local Plan is effective, to avoid inconsistency, and so that it is clear how a decision maker should react to development proposes, Policy PC05 should be amended to make clear it does not apply to the new employment site allocations because these policies have (as applicable) clear 'Development Principles' and 'Infrastructure Requirements'.
6. Section 8 - Natural Environment
NE08 - Lighting Restrictions
6.1 We support what we have inferred is the intended objective of this policy: to ensure lighting schemes are appropriate for the use to which they are associated, and potential harm arising from lighting schemes is minimised. In respect of policy BE08 A a) we suggest that, order to provide greater clarity as to how a decision maker should react to development proposals, it is acknowledged that employment land may well require the provision of lighting for security and operational purposes.
Policy NE9: Green Belt
6.2 It is considered necessary (in respect of the effectiveness of the Local Plan and compliance with the NPPF, in relation to the need to ensure policies are not ambiguous) that the Local Plan makes clear where land is being removed from the Green Belt (such as in respect of the allocation contained in Policy E11). It is suggested that text is added to this policy to clarify that the Local Plan is altering the Green Belt boundaries.
Policy NE13: Site Allocations in the Green Belt
6.3 The policy should be amended to provide clarity that sites are being removed to enable employment needs to be met, in addition to housing. It should be recognised that the development of employment uses has intrinsic community benefits, with resultant social and economic gains.
Potential additional land required for access to Brentwood Enterprise Park
6.4 As covered in elsewhere in our representation, owing to factors arising from the proposals for the Lower Thames Crossing (LTC), it is considered that additional land may need to be released from the Green Belt in order to ensure appropriate access to the BEP Site can be provided.
7. Strategic Environmental Assessment / Sustainability Appraisal
7.1 The Draft Local Plan is accompanied by a Sustainability Appraisal that has been prepared by AECOM, which assesses all sites put forward against a number of criteria in order to ascertain an overview of the sustainability credentials of a site or location. The SA concludes that the BEP Site is suitable for the intended proposals when considered on its own merits and when considered against other options within the borough.
7.2 Turning to the more specific aspects of the proposed allocation, the SA finds that the site scores moderately well when considered against other options for growth put forward at the various stages of plan preparation. While we agree with the allocation, and consider that the SA supports the sustainability of the site location, we consider that a number of the assessed criteria could be more accurately represented.
7.3 The SA broadly supports the inclusion of the Brentwood Enterprise Park within the plan, stating all sites will have good or excellent access onto the strategic highway network, and Brentwood Enterprise Park will provide an opportunity for high-end modern premises, along with appropriate ancillary uses, e.g. a hotel.
7.4 Table C from the Sustainability Appraisal is included above, showing how the BEP site (ref 101Aii) has been assessed against the criteria set out within the plan. It is noted that the site has been scored low in respect of relationship to Local Wildlife Sites, Ancient woodland and also with regard to Air Quality Management Areas (AQMAs).
7.5 It is noted that the criteria in Table B of the SA state that the thresholds have been selected on the basis that County Wildlife Sides and Ancient Semi Natural Woodlands have a relatively low sensitivity. However, the proposed allocation at Brentwood Enterprise Park is adjacent to the Hobbs Hole, and does not directly intersect with it. While a medium score would be more appropriate in this regard, it is important to note that the proposed scheme also provide opportunities for the enhancement of the Hobbs Hole site through the provision of effective landscaping schemes and ecological management.
7.6 The criteria set out in Table B stipulates that a low score is given to sites in or adjacent to an Air Quality Management Area (AQMA), and a medium score will be given if located within a kilometre of an AQMA. Despite not satisfying either of these criteria, the site has scored low in respect of its effect on Air Quality Management Areas. The Assessment justifies this, noting that growth along the A127 corridor can be expected to lead to increased traffic in the Brentwood town centre Air Quality Management Area, which is located some 5km to the north.
7.7 The SA does however follow this up by stating that "there is some uncertainty in respect of this conclusion, given the potential to deliver significant upgrades to walking/cycling and public transport infrastructure through a focus at DHGV, as well as to deliver employment and a local centre (to include a secondary school) on-site." We support this view, and concur that the growth locations identified in the southern corridor cumulatively make a strong business case for the implementation of sustainable transport linkages and necessary infrastructure that will ultimately lessen the perceived effect on the nearest AQMAs. As such, we feel that a medium score would be more appropriate in this regard.
7.8 Finally, on the SA, it is considered to be ineffective to judge the merits of a site for employment use with regard to its proximity to services such as a GP, Primary School and Secondary School. While these services may be considered key to the delivery of successful residential allocations, they are not relevant indicators of sustainability of potential employment sites. The site has been scored low in all three aspects, due to the distance it is located from these services, and we also consider that these scores should be 'NA'.
7.9 As such, the current SA may suggest the proposed BEP is less sustainable than it actually is and this references should be updated. However, it is also relevant to note that the SA is still considered this site as a merited allocation despite this.
8. Summary
8.1 This representation has considered the Brentwood Borough Council Regulation 19 Draft Local Plan against the test of soundness as set out at Paragraph 35 of the NPPF, with specific reference made to the allocation of land for the development of the Brentwood Enterprise Park scheme.
8.2 The representation sets out how the plan, whilst fundamentally sound, is not completely justified or effective with regard to ensuring the adequate delivery of sufficient employment land to support the planned growth of the borough. Furthermore, references to certain of the draft policies and supporting evidence show that the plan should be amended to be more positively prepared and consistent with National Planning Policy.
8.3 Proposed modifications to the plan to address these matters are set out including in relation to Policy E11.
8.4 We request that we be invited to attend the relevant sessions of the forthcoming examination hearings in order that we can provide the Inspector with further oral evidence and explanation in support of these representations.
Appendix A - Letter from Highways England regarding Lower Thames Crossing
Appendix B - Potential land required for access solutions (ref: 5183535-ATK-ZZ-DR-D-0001)

This representation on the Brentwood Borough Proposed Submission Local Plan
(February 2019) (PSLP) is submitted by Strutt & Parker on behalf of Barnoaks
Management Ltd. The representation is made in relation to Land south of the B1002,
Ingatestone. The site is referenced as 078 in the Council's plan making process. A location plan showing the site is provided at Appendix A of this representation. The site has previously been submitted through the Council's Call for Sites (2011) and
the Strategic Housing Land Availability Assessment (SHLAA) (Ref: GO20). In the
SHLAA, the site was defined as a 'greenfield parcel with potential'. More recently, the site was submitted through the Housing and Economic Land Availability Assessment (HELAA) (2018) (Ref: 078). The site was defined in the HELAA as a suitable, achievable and available site for residential development, which could come forward within 1 - 5 years. Representations were also submitted to Brentwood Borough Council through the Regulation 18 Consultation (2018). The site measures at approximately 1.8ha and could support the delivery of up to 54 dwellings. The site is located adjacent to the eastern edge of the settlement boundary of Ingatestone, on land, which is currently allocated as Green Belt. Currently, the site is not proposed to be allocated for residential development. The
rejection of the site for allocation is considered unjustified. The allocation of land south of the B1002, Ingatestone, for residential development would represent a sustainable and deliverable proposal to help meet housing needs over the coming plan period. The proposed plan period runs until 2033. Assuming - optimistically - adoption in 2019, this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (Paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption. This deficiency in the PSLP is of particular relevance given that the Borough is predominately Green Belt, and failure to ensure that development needs are planned
for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt; its permanence (NPPF, Paragraph 133). At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12 it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying PPG). However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum, not 350. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years). A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional years' worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest the PSLP that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. The Council is required to demonstrate a five-year housing land supply at any point in the plan period. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five year requirement of 2,712 dwellings. In terms of supply, the HLSS includes sites without detailed planning permission and
without evidence such sites will be delivered within five years. As per the NPPF, such
sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises just 653 dwellings. It is unclear how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings). Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing. Furthermore, and in respect of the projected supply, we are concerned to note that
Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this before development has even begun. The ability of larger sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin review (2018) and issues with their complexity have been ably set out in the Lichfield Study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematic due to a range of factors, including establishing the required infrastructure, and the timings of housing delivery associated with those requirements as well as the prolonged or protracted nature of the planning process. The Litchfield's report confirms that the planning process takes on average 2.5yrs for the planning application determination period for schemes of up to 500 units, but that this can double for sites over 1,000 units. For the above reasons it is unrealistic to project that 100 homes will be completed at
Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that
Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it
does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound. The strategic sites are expected to deliver 1555 dwellings within 5yrs of adoption. Given the matters set out above, this is unrealistic and it would not be justified to rely on these sites to meet short term housing delivery. This emphasises the need to review sites such as ref. 078 to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is Sound. Ingatestone is defined as a Category 2 Settlement. The Borough defines Category 2
settlements as larger villages in a rural setting, with high levels of accessibility and public transport provision, including rail services. These settlements provide a range of services and facilities to the immediate residential areas and nearby settlements. The PSLP states that appropriate urban extension and brownfield development
opportunities will be encouraged to meet local needs. In 2011, Ingatestone had a population of 4,812 (Census; 2011). It is the Borough's largest village, with a modest level of facilities, including a secondary school. Furthermore, Ingatestone Railway Station is located within the village, and provides frequent railway services to London Liverpool Street, Stratford (London), Chelmsford, Colchester and other surrounding settlements. The PSLP confirms that although Ingatestone has relatively good facilities, a modest level of development is envisaged, due to infrastructure constraints and a lack of suitable sites. As such, only two sites have been allocated for residential development in the PSLP -R21 and R22. This results in a total of 218 dwellings for Ingatestone over the plan period. Site 078 has previously been defined in the HELAA (2018) as suitable, available and achievable site for residential development. The PSLP in this case is flawed, as it doesn't appropriately consider Site 078 as a suitable site for residential development. It is considered that the PSLP fails to support the sustainable growth of Ingatestone. The
failure to thoroughly consider Site 078 for residential development is unjustified. To ensure the Local Plan is sound, further suitable sites within Ingatestone should be
allocated to ensure the sustainable growth of Ingatestone. The site measures at approximately 1.8ha and could support the development of up to 54 dwellings. The site is located adjacent to the eastern edge of the settlement boundary, on land,
which is currently allocated as Green Belt. The site is bounded by existing residential development to the north and south and the B1002 to the west. To the eastern boundary of the site are agricultural fields. A considerable amount of technical work has been undertaken in respect of land south of the B1002 and has previously been submitted to the Council through previous stages of the plan-making process. The technical work undertaken demonstrates that the site is sustainable, suitable, available and achievable and its development would help meet the Borough's housing need. Work undertaken, and previously provided is included in this representation for completeness: * Proposed Site Plan prepared by Grafik (Appendix B); * Landscape and Visual Issues Scoping Report prepared by Nigel Cowlin (Appendix C); * Landscape Advisory Plan prepared by Nigel Cowlin (Appendix D); * Access Appraisal by Ardent Engineers (Appendix E). In previous representations submitted to the Council, we have commented specifically on the proposals for layout and landscaping, providing that the site would be allocated for residential development by the Council. A Feasibility Layout prepared by Graffik Architecture has previously been submitted to the Council and is included within this representation for completeness. The feasibility study demonstrates how 54 dwellings could be accommodated on the site. The layout illustrates how the site could provide infill development to the already existing settlement of Ingatestone, without adversely harming the landscape character of the area or the character of Ingatestone itself. The Feasibility Layout also shows the potential proposals for landscaping on site. These proposals have been formed through careful consideration of the existing landscape character of Ingatestone and in line with the Landscape and Visual Issues Scoping Report and Landscape Advisory Plan which has been prepared by Nigel Cowlin. The report and plan also accompany this representation. As set out above, a Landscape and Visual Issues Scoping Report and Landscaping Advisory Plan has been prepared by Nigel Cowlin and accompanies this representation. It is proposed that there is to be retained and enhanced landscaping on site, specifically to the eastern and southern boundaries. This landscaping proposal takes into account the Grade II Listed Building - Rays - which is located beyond the eastern boundary of the site. By proposing dense planting at this boundary, it will ensure that the development proposal has no adverse effect on the nearby listed building. The Feasibility Layout also illustrates that planting will be retained at the western boundary of the site at the High Street, where access to the site is proposed. Furthermore, it is illustrated that the existing oak tree at the western part of the site will be retained to provide a substantial area of open space on the site. The Scoping Report suggests that these simple design controls and landscape mitigation measures, such as the protection of existing field boundary hedgerows, along with retaining an open space around the mature Oak Tree at the front of the site, would help to ensure that the proposed development would be as successful as possible in landscape and visual terms. The Scoping Report found that the visual influence of the site to surrounding locations was found to be limited due to the built up nature of the surrounding area, for example the ribbon development to the north and the settlement edge of Ingatestone to the south. The report states that development of the site should be considered as a logical area for infill development along the B1002. The Environmental Assessment of Plans and Programmes Regulations (2004) requires SA/SEAs to inter alia set out the reasons for the selection of preferred alternatives, and the rejections of others, be made set out. In addition, the Planning Practice Guidance4 makes clear that the strategic
environmental assessment should outline the reasons the alternatives were selected,
the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. Sustainability Appraisal of the PSLP has been published: the Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA). Paragraph 5.5.31 of the SA confirms that Site 078 is listed as 1 of 5 omission sites in the HELAA as it is "deliverable or developable". The SA confirms that the two sites with the greatest potential for allocation are the adjacent "Parklands" Sites (Ref: 078 and Ref: 243), at the northern boundary of the village. The SA states that the accompanying Green Belt Review found that both sites contribute to the purposes of the Green Belt to a 'moderate' extent, however neither site is fully contained in the landscape. The SA concludes that the option of adding one or more omission sites was determined as "unreasonable", for the purposes of establishing reasonable spatial alternatives. No details are provided to explain in what way Site 078 is considered not to be fully contained in the landscape. Furthermore, as per Section 3 of this representation, the accompanying Landscape and Visual Issues Scoping Report confirms that further planting can be provided on site at all boundaries, thus ensuring it is a contained site. The proposed planting would be effective in appropriately screening the proposed development and ensuring the village character of Ingatestone is retained. In short, the SA does not provide a justified reason for the rejection of the site. Turning to the specifics of the SA assessment of the site, these are set out in Table C of the SA. This provides a 'traffic light' assessment of sites' sustainability. Green indicates sites perform well; amber - poorly; red- particularly poorly; against specific criteria. Our first point in relation to the approach taken is that it is very simplistic - the assessment of site appears to be based purely on physical distance to various features / facilities / designations. For example, in relation to criteria 10 (Conservation Area), our site is considered to score 'poorly'. Part of Ingatestone High Street is defined as a Conservation Area, however site 078 is not within this designation and is located at least 400m from the defined Conservation Area. As such, it is considered that the proposed development of the site would not unacceptably impact the Conservation Area. Furthermore, in relation to criteria 1 (Air Quality Management Area (AQMA)), the site is considered to score 'poorly'. The site is located approximately 1 mile from AQMA BRW6 at the A12/Fryerning Lane. It is considered that the AQMA will not be adversely impacted by the site, given the distance between the two. In relation to criteria 8 (Primary School), the site is considered to score 'poorly'. The site is located 0.5 miles from both an infant and junior school. It is considered that the primary school provisions within Ingatestone are within walking distance to the site and the site should not be scored as 'poorly' in relation to this criterion. As per the reasons above, we therefore consider the SA's assessment to be flawed. A Green Belt Study and Assessment has been undertaken by Crestwood Environmental
Ltd as part of the Regulation 19 Consultation. The Assessment looks to assess specific green belt parcels in relation to the 4 purposes of the Green Belt. These are: Purpose 1 - To check the unrestricted sprawl of large built-up areas; Purpose 2 - To prevent neighbouring towns merging in to one another; Purpose 3 - To assist in safeguarding the countryside from encroachment; Purpose 4 - To preserve the setting and special character of historic towns. Following this assessment, the parcel is given an overall assessment rating. The ratings are; Low; Low-Moderate; Moderate; Moderate - High; High. Site 078 is within Parcel 9A of the Green Belt Assessment. Parcel 9a includes land to the northeast of Ingatestone. The parcel size is 41.94ha. Purpose 1: Parcel 9a is defined by the Council as 'Partly Contained', as it abuts a large built up area. The assessment states that the 'Partly Contained' sites have weak/degraded/unclear boundaries. This is an overall assessment of the parcel and not specifically of Site 078. Site 078 has clear natural boundaries at the east and to the south. Furthermore, as detailed at Section 3, further planting is proposed at the site in order to contain the proposed development. Purpose 2: Parcel 9a has been assessed as an 'Important Countryside Gap'. The Assessment
states that the parcel forms either a large proportion of countryside gaps between towns or the development of the site would result in the physical narrowing of the gap and potential visual coalescence. As per the accompanying Landscape and Visual Issues Scoping Report, it is considered that the site would result in a coherent infill development between two existing areas of developed land. The Scoping Report also confirms that the proposed development of the site wold not result in the coalescence of Margaretting and Ingatestone. Purpose 3: Parcel 9a has been assessed as 'Functional Countryside' (FC). This again, is an overall assessment of the parcel and not specifically of Site 078. As such, we do not agree that Site 078 can be defined as Functional Countryside. The site is between existing development and can therefore be considered as an infill site. Purpose 4: The assessment states that Parcel 9A has a 'limited relationship with Historic Town'. We agree with this assessment. Overall Brentwood Borough Council have assessed Parcel 9a, as having a 'moderate' contribution to the 4 purposes of Green Belt. The above review of Parcel 9a recognises that this assessment is not necessarily reflective of the qualities of every site within the parcel. In respect of this, we wish to highlight the findings of the Inspector in the Welwyn Hatfield Local Plan Examination, which we consider helpful in the consideration of the PSLP. Following the Stage 1 and 2 hearing sessions at Welwyn Hatfield, the Inspector provided a note to the Council in December 2017 on its approach to review of the Green Belt (EX39 of the Welywn Hatfield Local Plan Examination). Within this note, the Inspector stated: "The Council has suggested that it is unable to meet its housing need because of
Green Belt restrictions among other concerns. In my concluding remarks ... I pointed
out that I did not consider the development strategy put forward in the plan to be sound, in part because there was insufficient justification for the failure to identify sufficient developable sites within the Green Belt. That is largely because the phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas." "Additionally, the phase 2 Green Belt Review, which did look at a finer grain of sites,
does not appear to have examined all of the potential development sites adjacent to
the urban areas..." "The actual development strategy finally arrived at is a matter for the Council... However, if that strategy fails to meet the FOAHN and assuming that all realistic development opportunities outside of the Green Belt have been put forward in the plan, then it is effectively saying that there are no exceptional circumstances justifying a further release of additional land from the Green Belt and that presumably means for as long as current national green belt policy and its interpretation prevails. That may be the case but unless all of the Green Belt has been forensically analysed in some detail then it is difficult to prove." Having regard to all of the above, key issues to consider include: * Whether all potential sites' impact on the Green Belt has been assessed; * Whether such assessment was undertaken at a sufficiently fine grain to properly consider individual sites' impact on the Green Belt.In respect of the PSLP, it is clear that not all potential development sites were subject to a sufficiently detailed analysis which could enable BBC to justifiably conclude it has identified a reasonable strategy to meet its housing needs, particularly where the plan is not meeting those needs in full. At the very least, there was one site that was not properly assessed: Land to the South of the B1002, Ingatestone. The Council's own evidence base states that Site 078 is suitable, available and achievable for residential development. Development of the site is supported by technical evidence that confirms its suitability, including in relation to the lack of harm to the landscape and Green Belt. The reasons given for the rejection of the Site are based on erroneous conclusions in the evidence base and should be re-examined. The rejection of Site 078 is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed in Ingatestone. The allocation of Site 078 for development will assist in curing defects in respect of the
Local Plan, enabling it to be a sound plan.

The Local Authority should finalise its Green Belt Evidence Base.

Chapter 7 Community Infrastructure Policy PC15:Education Facilities
It is recommended that there is minor changes to the wording within the Policy. Under Policy B delete the word demonstrable before need. It is also considered unnecessary to have the additional wording that relates to the ECC's Developer's Guide to Infrastructure Contributions. If the proposals are clearly associated with educations requirements which will be a matter of fact and degree then there is no need to turn to other schedules. Furthermore the link to the Essex County Council document does not provide a clear schedule of criteria to which the decision maker or applicant can turn. It is confusing and should be deleted. We would recommend that the policy should now read "Where there is a need for new educational facilities, planning permission will be granted for appropriate and well-designed proposals."
As explanation for such minor change it will generally be the education provider whether independent school, religious order or County Education Authority who will know what is needed to improve their overall education facilities either through direct education floorspace or ancillary or associated floorspace.
Comment is also made on Policy PC16: Buildings for Institution Purposes In Policy A delete demonstrable before need. The Policy now reading "A. Where there is a need for the facilities.........." Comment is also made in relation to the general text of paragraph 7.105. This is an unnecessary inclusion within the Plan. There may from time to time be need for minor loss of existing residential accommodation to facilitate a bigger objective of educational community facilities. An example given is the recent redevelopment of the Brentwood Prep School Site where the demands for new form of entry and enlarged educational facilities necessitated the loss of an existing caretakers house. The Local Plan will not be effective with respect to the policy issue raised as it creates an unnecessary hurdle by reference to using the word demonstrable and is confusing and not necessary to relate to another document such as the Essex County Council Developers Guide to Infrastructure Contributions. I have set out the modification to PC15 Education Facilities above but for ease of reference repeat here:
B. "Where there is a need for new educational facilities, planning permission will be granted for appropriate and well-designed proposals."

The provision of educational facilities is an important part of the Local Plan and subject to any response of the Local Authority the point is best made orally.

Should any part of the Brentwood Community Hospital site be declared as surplus to the operational healthcare requirement of the NHS in the future, then the site should be considered suitable and available for alternative use, and considered deliverable within the period 5-10 years. These representations identify the sites potential for future development, in accordance with the realignment of the Green Belt so that this significant area of development land is no longer included. It is evident, that the site does not make a positive contribution towards the purposes of the Green Belt set out in the NPPF. Accordingly, redevelopment of the site could provide a key contribution to Brentwood's housing need, which the Council have failed to justify, given the reliance on key strategic sites, and the lack of acknowledgement for unmet need arising from neighbouring authorities (Basildon and Havering). These representations therefore promote and identify parts of the Brentwood Community Hospital site as a suitable site to contribute towards these requirements. This site presents an excellent opportunity for a high quality residential redevelopment on previously developed Green Belt land. This could be achieved without compromising the character of the area as the development can act as an infill site to the existing residential development surrounding it, and without the need for significant infrastructure. Furthermore, the site is also available to accommodate further health related development should the CCG seek to expand their services in this location, including the possible expansion of the hospital to provide more comprehensive services for the community. However, the site's Green Belt designation would make it difficult for any planning application proposing additional built form to provide further healthcare services to be considered acceptable. The subject site is considered available, suitable and deliverable within the 5-10 year period of the plan.

These representations seek to comment specifically on Housing Requirements, Housing Allocations, and relevant evidence base documents identified and referred to in the draft Local Plan. In addition to this, these representations will also comment on specific parts of the Spatial Strategy and Strategic Objectives provided in the emerging plan. Housing Requirements This Consultation document outlines that the Council commit to delivering 7,752 new net additional dwellings over the Plan period 2016-2033 using a stepped trajectory that would see 310 dwellings per annum until 2022/2023, following by 584 dwellings per annum from 2023/24-2033. Overall, this represents an average of 456 dwellings per annum over the Plan period. The minimum housing need for Brentwood based on the standardised methodology is 452 dwellings per annum. In addition to the Council's minimum requirement, there are 3,508 dwellings that are unmet in Basildon and 5,650 dwellings that are unmet in Havering. Basildon and Havering both adjoin Brentwood, therefore the Council should consider contributing to their housing needs through outlining and planning for a higher housing target. The Council should also consider the arrival of Crossrail, which is set to unlock further demand for housing in the area. The Council's approach to a stepped trajectory is also not justified, and should look to deliver housing in the short term. Housing Allocations
The Council's Local Plan Consultation document identifies a number of residential allocations on Green Belt land located at the edge of the Brentwood Urban Area. Policy NE13 (Site Allocations in the Green Belt) states that sites allocated within the Green Belt will be expected to provide "significant community benefits", and will be de-allocated from the Green Belt to allow development to take place. This identifies that the release of Green Belt land in these areas is being pursued as part of their Spatial Strategy. Green Belt land is also proposed for release in a number of other settlements in the Borough. Of the Council's allocations, there are four Strategic Housing Allocations. The largest allocation is Dunton Hills Garden Village Strategic Allocation (Policy R01), which is allocated for a residential-led development to deliver around 2,700 homes, with a potential overall capacity of 4,000 beyond 2033. This allocation was also located within the Green Belt. The variable housing target outlined by the Council is substantially reliant on this Garden Village commencing delivery in 2023/24 (within the first five years of the Plan), and delivering at a rate of 100 homes per annum from thereon, reaching 300 homes per annum from 2026. Housing Allocation- Land off Crescent Drive: The land adjoining Brentwood Community Hospital to the east benefits from a draft allocation in the Local Plan consultation document. Although this site has similar characteristics to the Brentwood Community Hospital site, including being a previous NHS site, it is not designated as Green Belt. The allocation on site 186, Land at Crescent Drive, Shenfield, identifies that the 1.54ha site can provide for around 55 dwellings, anticipated to be delivered between 2021/2022 and 2023/2024. It will provide a mix of size and type of homes including affordable in accordance with the Council's policy requirements. This outlines the development potential of the area. Loss of Community Use Policy PC14 (Protecting and Enhancing Community Assets) states that existing community assets will be protected from inappropriate changes of use or redevelopment. Policy PC14 (e), states that development proposals that would result in a loss of community assets will be discouraged unless it can be demonstrated the following; i. There are realistic proposals for re-provision that continue to serve the needs of the neighbourhood and wider community; or ii. the loss is part of a wider public service transformation plan which requires investment in modern, fit for purpose infrastructure and facilities to meet future population needs or to sustain and improve services. To confirm, a property can only be released for disposal or alternative use by NHSPS once Commissioners have confirmed that it is no longer required for the delivery of NHS services. Furthermore, NHSPS estate code requires that any property to be disposed of is first listed on "e-PIMS", the central database of Government Central Civil Estate properties and land, which allows other public sector bodies to consider their use for it. The ability of the NHS to continually review the healthcare estate, optimise the use of land, and deliver health services from modern and fit for purpose facilities is crucial. Given that there is very careful oversight from NHS England and CCGs to ensure sufficient services are re-provided, and that the estate is fit-for-purpose, additional protection through planning policy should be unnecessary in relation to public healthcare facilities. Therefore, if all or part of the site is declared as surplus to the operational healthcare requirements of the NHS by health commissioners, this should be considered sufficient to satisfy Policy PC14 and any subsequent replacement policy. Furthermore, any marketing period (in addition to service re-provision) should not be required. Evidence Base Documents - Since the last consultation on the Brentwood Local Plan, the Council have published a suite of evidence base documents to inform the Regulation 19 Local Plan and to address the Council's main concerns. Evidence base documents of relevance consist of the following; * Green Belt Study (November 2018); and * Infrastructure Delivery Plan. Green Belt Study (2018) - The Council's Green Belt study (February 2018), identifies that around 89% of the Borough is designated as Green Belt; it then splits all the Green Belt in the district into various parcels which are assessed against a number of criteria including the NPPF's five Green Belt purposes. The land at Brentwood Community Hospital is entirely located within Parcel 55: East of Middleton Hall Lane. This Parcel spans over 26.1ha of land which is identified as being wholly / largely contained by large built up areas. In summary, the entire parcel is considered to be well-contained, but is located within a Critical
Countryside Gap (CCG), operates as Functional Countryside (FC), and has a moderate relationship with a Historic Town. The Parcel is therefore identified as performing a moderate - high contribution towards the Green Belt's purposes. The Green Belt Stage 2 Review (February 2018) sub-divided a number of sites assessed in Part 1 for further detailed assessment. Parcel 55 had not been sub-divided in Part 2 for further assessment and thus there was no further assessment of the site against the Green Belt's purposes in this round of assessment. The Council's most recent Green Belt Study (November 2018), assesses the site under Site Assessment 186. To note, only the car parks to the western extent of the site fall within the Green Belt, therefore as such, the assessment only related to 25% of the site. The site was assessed as follows; * The car parks are strongly associated with surrounding buildings, albeit protruding in to the Green Belt. The site is assessed as Partly Contained (PC); * The site is small scale and contained within the town (e.g. infilling). The site is bounded by mature dense woodland to the west. Whilst development would mass housing on the site, there would be no appreciable reduction in the gap. The site is assessed as Separation Retained (SR); * The area of the site located within the Green Belt is car parks and woodland areas so therefore is assessed as being Mixed Functions within Countryside (MFC); * The site is assessed as having a limited relationship with the historic town (LRHT). Overall, the site was assessed as having low-moderate contribution to the Green Belt. The site was considered as a "partly developed site" due to the hardstanding car parks and was associated with the settlement boundary to the east. Infrastructure Delivery Plan - The Council's Infrastructure Delivery Plan (IDP) provides a schedule of infrastructure requirements to help support new development growth planned within the Brentwood Local Plan. Paragraph 10.6 outlines that Brentwood has a slightly higher proportion of over 65s compared to Essex county as a whole, although a 17% increase is expected between 2015 and 2025 equating to 2,600 more people. Given the foregoing, there is a clear need for a higher proportion of homes which are capable of accommodating people's changing needs. Paragraph 10.19 of the IDP also states that hospitals will need to be redesigned to treat the patients of the future. The site could be suitable for housing for older people as it is located in a sustainable location close to services, facilities and to transport links. The IDP also highlights that there is an ongoing programme to improve the utilisation of Brentwood Community Hospital, to reduce the void costs associated with the building and to make better use of the opportunity for providing a range of health and care services. Strategic Objectives - This sub-section provides a review of the Spatial Strategy, and the Strategic Objectives and how they are of relevance to the subject site. Chapter 2 (Borough of Villages), Figure 2.3 sets out the borough's settlement hierarchy categories, to identify their role for delivering sustainable growth. Figure 2.3 outlines Brentwood as a "large town", alongside Shenfield with 4 urban neighbourhoods, 2 large villages, 1 garden village, 6 rural villages, and 7 rural villages in sparse settings. Paragraph 2.11 of the Consultation document outlines that Brentwood is the borough's largest settlement and offers the most scope to develop in, in accordance with sustainable development objectives as set out in the NPPF. Chapter 3 of the consultation document outlines the Borough's Spatial Strategy and Strategic Objectives. The Council have highlighted four strategic objectives and how the policies align to help deliver these policies. These are the following; * SO1: Manage Growth Sustainably; * SO2: Deliver a Healthy and Resilient Built Environment; * SO3: Deliver Sustainable Communities with Diverse Economic & Social-cultural Opportunities for All; and * SO4: Deliver Beautiful, Biodiverse, Clean and a Functional Natural Environment. The subsequent chapters outline the policies that sit within each strategic objective. These representations specifically comment on both: Managing Sustainable Growth (SO1) and Sustainable Communities (SO3). SO1: Managing Sustainable Growth - The Council aim to direct development to the most sustainable locations, ensuring that the characteristics and patterns of the settlements are protected and enhanced. The redevelopment of the site would aid the Council in delivering most of these objectives and policies. Although currently designated as Green Belt, the brownfield nature of the site and its location within the existing built up area of Brentwood means it can significantly aid in intensification. The site is also easily accessible by existing public transport modes as outlined in the 'site context' section of these representations. The site is highly sustainable and helps contribute towards delivering the Strategic Objectives including having no unacceptable effect on visual amenity; having no unacceptable impact on health; and causes no unacceptable effects on adjoining sites. The intensification of this site would also increase the critical mass of customers/users of existing services and facilities. This can help to ensure the viability of existing services and amenities in the local area. The site could also be optimised for retention in its current use with the provision of additional built form to provide additional health services or an extension to the current facilities. SO3: Sustainable Communities - The Council aim to highlight opportunities which flexibly respond to the changing economic climate and employment sector trends making citizens feel economically empowered to enjoy and benefit from the necessary community/social infrastructure that sustains inclusive, informed, vibrant, active and cohesive communities. The potential for the provision of residential development at the site would help the Council to meet their identified and growing need for housing over the plan period. The sustainable location of the site in relation to the existing built form and settlement of Brentwood means that should the site ever become surplus to the requirements of the NHS, it would be a great location for residential development. The site is adjoined to the settlement, so therefore can help contribute towards creating a cohesive community. Furthermore, as outlined above, the site is also capable of accommodating further healthcare-related development, including the possible expansion of the hospital to provide better and more comprehensive services for the local community. The site is located in a sustainable location and is easily accessible by public transport, cycling and walking and could therefore make a good location for the expansion of the existing healthcare facilities should this be required by the CCG in the near future. Chapter 3 also outlines the Council's spatial development principles, stating that development proposals in the borough will follow the following principles; 1. Urban Areas- Prioritise brownfield sites, making efficient use of land; 2. Brownfield Green Belt Land- Use of previously developed land in the Green Belt; 3. Strategic Sites- Use opportunities created by larger housing development; 4. Urban Extensions- deliver new homes in areas close to existing transport and local facilities; and 5. Windfall- an allowance for small scale development that will come forward in the future. The site is Brownfield Green Belt land (Tier 2) so therefore should be favoured for development over strategic sites and urban extensions. The Role and Extent of the Green Belt Policy NE9: Green Belt sets out that the Green Belt will continue to be preserved from inappropriate development so that "it continues to maintain its openness and serve its key functions". The redevelopment of this site would only seek for the removal of a small element of existing Green Belt land which is currently a mix of hardstanding car parking and woodland. This removal would enable efficient and maximum redevelopment of a brownfield site, without contradicting the purposes of the Green Belt. The NPPF states that Green Belt boundaries should only be amended in "exceptional circumstances". The Housing White Paper seeks to clarify this further and states that land which has been previously developed should be considered first. Accordingly, it is sites such as Brentwood Community Hospital which should be removed from the Green Belt. This is further outlined below, which highlights the sites suitability. a. Site Suitability The site is located adjoining the existing settlement and residential area of Shenfield, and a proportion of the site within the Green Belt is currently an existing hardstanding forming a car parking area. The site is located in close proximity to public transport connections which provides links to a variety of everyday services and amenities. As previously identified, the site is currently partially located (25% of the site) within the Green Belt. However, due to the existing built form within and surrounding the site, and as evidenced in the Green Belt Study, the site provides little or no contribution towards the purposes of the Green Belt. The Council undertook a Green Belt Study (November, 2018) which assessed various parcels of Green Belt land within the district. The site fell within Site Assessment 186, which concluded as having low-moderate contribution to the Green Belt. Although considered as having a low-moderate contribution to the Green Belt, a Green Belt assessment is provided below to outline the development potential of the land at Brentwood Community Hospital. The assessment is based on the Green Belt purposes identified in the NPPF. This assessment is to enable the Council to determine the importance of the site in Green Belt terms, and to demonstrate that the site does not meet the five purposes of the Green Belt, so therefore should be removed. 1. to check the unrestricted sprawl of large built-up areas - The site is bounded on three sides by the existing built form of Brentwood. The surrounding built form includes residential dwellings to the north and west, and a draft residential allocation to the east. - The built up area would not spread further than the site's boundary due to the presence of a significant area of woodland adjacent. 2. to prevent neighbouring towns merging into one another - The site falls between the settlements of Shenfield and Brentwood. Although the site falls between these two settlements, the built form of Shenfield and Brentwood already links through the existing built form on Shenfield Road and it is not this site that forms any gap rather the playing fields adjacent. - The site's built form also limits its purposes in restricting the two settlements from merging as it is clear that it is an existing built up area. 3. to assist in safeguarding the countryside from encroachment - The site is bounded to the north, east, and west by the existing built form of Brentwood. - The site is bounded to the south by existing woodland. - Due to the site not being located in the countryside, its contribution toward this aim is limited. 4. to preserve the setting and special character of historic towns - The site is not located within a historic town.5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The site is located within an existing settlement and promotes the intensification of an existing community facility which already has its own facilities, amenities, and day-to-day services, or, the site could equally be redeveloped for the provision of residential dwellings should the land become surplus to the NHS's requirements. b. Sustainability The golden thread running through the NPPF is a presumption in favour of sustainable development. This means that developments which accord with the Local Plan should be approved without delay. The three pillars of sustainability within the NPPF are identified as Social, Environmental, and Economic; the definitions of these terms and the ways the proposals at Brentwood Community Hospital conform to these pillars are identified below. Social The NPPF defines socially sustainable development as those which contribute toward supporting a strong, vibrant and healthy community by providing the supply of housing required to meet the needs of present and future generations, through a high quality built environment with accessible services and support of health, social and cultural wellbeing. The redevelopment of Brentwood Community Hospital would accord with the social pillar of sustainable development through the provision of an increased number of residential dwellings on a sustainably located site in order to help meet the Council's identified and growing need for housing. Should the Council fail to meet their identified housing target, there could be serious social instability caused including overcrowding of existing housing stock and undersupply of housing. In addition to this, the site could represent the opportunity for the delivery of affordable housing towards the Council's identified need, representing a further opportunity to deliver a socially sustainable development. Environmental The NPPF defines environmentally sustainable development as development which contributes to protecting and enhancing the natural, built and historic environment through improving biodiversity, using natural resources prudently, and minimising waste and pollution. A scheme at Brentwood Community Hospital could provide sustainably located residential dwellings within walking distance of existing services and amenities, reducing the need for future residents to travel long distances and reducing pollution and the use of finite resources. Alternatively, should the CCG seek to expand their existing facilities on site, the intensification of the existing healthcare services could help to ensure the healthcare facilities continue to be provided in a sustainable location. Economic The NPPF defines economically sustainable development as development which contributes toward building a strong, responsive, and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation. A residential scheme at Brentwood Community Hospital would accord with this pillar through the introduction of an increased number of residents into an existing urban area. These new residents will help to secure the economic viability and vitality of the existing local businesses and services through an increased customer base. The redevelopment of the site would also ensure that a higher provision of land is available for a land use which is identified as being highly demanded at this point in time ensuring that a sufficient supply of land is available in a sustainably located site.

Should any part of the Brentwood Community Hospital site be declared as surplus to the operational healthcare requirement of the NHS in the future, then the site should be considered suitable and available for alternative use, and considered deliverable within the period 5-10 years. These representations identify the sites potential for future development, in accordance with the realignment of the Green Belt so that this significant area of development land is no longer included. It is evident, that the site does not make a positive contribution towards the purposes of the Green Belt set out in the NPPF. Accordingly, redevelopment of the site could provide a key contribution to Brentwood's housing need, which the Council have failed to justify, given the reliance on key strategic sites, and the lack of acknowledgement for unmet need arising from neighbouring authorities (Basildon and Havering). These representations therefore promote and identify parts of the Brentwood Community Hospital site as a suitable site to contribute towards these requirements. This site presents an excellent opportunity for a high quality residential redevelopment on previously developed Green Belt land. This could be achieved without compromising the character of the area as the development can act as an infill site to the existing residential development surrounding it, and without the need for significant infrastructure. Furthermore, the site is also available to accommodate further health related development should the CCG seek to expand their services in this location, including the possible expansion of the hospital to provide more comprehensive services for the community. However, the site's Green Belt designation would make it difficult for any planning application proposing additional built form to provide further healthcare services to be considered acceptable. The subject site is considered available, suitable and deliverable within the 5-10 year period of the plan.

These representations seek to comment specifically on Housing Requirements, Housing Allocations, and relevant evidence base documents identified and referred to in the draft Local Plan. In addition to this, these representations will also comment on specific parts of the Spatial Strategy and Strategic Objectives provided in the emerging plan. Housing Requirements This Consultation document outlines that the Council commit to delivering 7,752 new net additional dwellings over the Plan period 2016-2033 using a stepped trajectory that would see 310 dwellings per annum until 2022/2023, following by 584 dwellings per annum from 2023/24-2033. Overall, this represents an average of 456 dwellings per annum over the Plan period. The minimum housing need for Brentwood based on the standardised methodology is 452 dwellings per annum. In addition to the Council's minimum requirement, there are 3,508 dwellings that are unmet in Basildon and 5,650 dwellings that are unmet in Havering. Basildon and Havering both adjoin Brentwood, therefore the Council should consider contributing to their housing needs through outlining and planning for a higher housing target. The Council should also consider the arrival of Crossrail, which is set to unlock further demand for housing in the area. The Council's approach to a stepped trajectory is also not justified, and should look to deliver housing in the short term. Housing Allocations
The Council's Local Plan Consultation document identifies a number of residential allocations on Green Belt land located at the edge of the Brentwood Urban Area. Policy NE13 (Site Allocations in the Green Belt) states that sites allocated within the Green Belt will be expected to provide "significant community benefits", and will be de-allocated from the Green Belt to allow development to take place. This identifies that the release of Green Belt land in these areas is being pursued as part of their Spatial Strategy. Green Belt land is also proposed for release in a number of other settlements in the Borough. Of the Council's allocations, there are four Strategic Housing Allocations. The largest allocation is Dunton Hills Garden Village Strategic Allocation (Policy R01), which is allocated for a residential-led development to deliver around 2,700 homes, with a potential overall capacity of 4,000 beyond 2033. This allocation was also located within the Green Belt. The variable housing target outlined by the Council is substantially reliant on this Garden Village commencing delivery in 2023/24 (within the first five years of the Plan), and delivering at a rate of 100 homes per annum from thereon, reaching 300 homes per annum from 2026. Housing Allocation- Land off Crescent Drive: The land adjoining Brentwood Community Hospital to the east benefits from a draft allocation in the Local Plan consultation document. Although this site has similar characteristics to the Brentwood Community Hospital site, including being a previous NHS site, it is not designated as Green Belt. The allocation on site 186, Land at Crescent Drive, Shenfield, identifies that the 1.54ha site can provide for around 55 dwellings, anticipated to be delivered between 2021/2022 and 2023/2024. It will provide a mix of size and type of homes including affordable in accordance with the Council's policy requirements. This outlines the development potential of the area. Loss of Community Use Policy PC14 (Protecting and Enhancing Community Assets) states that existing community assets will be protected from inappropriate changes of use or redevelopment. Policy PC14 (e), states that development proposals that would result in a loss of community assets will be discouraged unless it can be demonstrated the following; i. There are realistic proposals for re-provision that continue to serve the needs of the neighbourhood and wider community; or ii. the loss is part of a wider public service transformation plan which requires investment in modern, fit for purpose infrastructure and facilities to meet future population needs or to sustain and improve services. To confirm, a property can only be released for disposal or alternative use by NHSPS once Commissioners have confirmed that it is no longer required for the delivery of NHS services. Furthermore, NHSPS estate code requires that any property to be disposed of is first listed on "e-PIMS", the central database of Government Central Civil Estate properties and land, which allows other public sector bodies to consider their use for it. The ability of the NHS to continually review the healthcare estate, optimise the use of land, and deliver health services from modern and fit for purpose facilities is crucial. Given that there is very careful oversight from NHS England and CCGs to ensure sufficient services are re-provided, and that the estate is fit-for-purpose, additional protection through planning policy should be unnecessary in relation to public healthcare facilities. Therefore, if all or part of the site is declared as surplus to the operational healthcare requirements of the NHS by health commissioners, this should be considered sufficient to satisfy Policy PC14 and any subsequent replacement policy. Furthermore, any marketing period (in addition to service re-provision) should not be required. Evidence Base Documents - Since the last consultation on the Brentwood Local Plan, the Council have published a suite of evidence base documents to inform the Regulation 19 Local Plan and to address the Council's main concerns. Evidence base documents of relevance consist of the following; * Green Belt Study (November 2018); and * Infrastructure Delivery Plan. Green Belt Study (2018) - The Council's Green Belt study (February 2018), identifies that around 89% of the Borough is designated as Green Belt; it then splits all the Green Belt in the district into various parcels which are assessed against a number of criteria including the NPPF's five Green Belt purposes. The land at Brentwood Community Hospital is entirely located within Parcel 55: East of Middleton Hall Lane. This Parcel spans over 26.1ha of land which is identified as being wholly / largely contained by large built up areas. In summary, the entire parcel is considered to be well-contained, but is located within a Critical
Countryside Gap (CCG), operates as Functional Countryside (FC), and has a moderate relationship with a Historic Town. The Parcel is therefore identified as performing a moderate - high contribution towards the Green Belt's purposes. The Green Belt Stage 2 Review (February 2018) sub-divided a number of sites assessed in Part 1 for further detailed assessment. Parcel 55 had not been sub-divided in Part 2 for further assessment and thus there was no further assessment of the site against the Green Belt's purposes in this round of assessment. The Council's most recent Green Belt Study (November 2018), assesses the site under Site Assessment 186. To note, only the car parks to the western extent of the site fall within the Green Belt, therefore as such, the assessment only related to 25% of the site. The site was assessed as follows; * The car parks are strongly associated with surrounding buildings, albeit protruding in to the Green Belt. The site is assessed as Partly Contained (PC); * The site is small scale and contained within the town (e.g. infilling). The site is bounded by mature dense woodland to the west. Whilst development would mass housing on the site, there would be no appreciable reduction in the gap. The site is assessed as Separation Retained (SR); * The area of the site located within the Green Belt is car parks and woodland areas so therefore is assessed as being Mixed Functions within Countryside (MFC); * The site is assessed as having a limited relationship with the historic town (LRHT). Overall, the site was assessed as having low-moderate contribution to the Green Belt. The site was considered as a "partly developed site" due to the hardstanding car parks and was associated with the settlement boundary to the east. Infrastructure Delivery Plan - The Council's Infrastructure Delivery Plan (IDP) provides a schedule of infrastructure requirements to help support new development growth planned within the Brentwood Local Plan. Paragraph 10.6 outlines that Brentwood has a slightly higher proportion of over 65s compared to Essex county as a whole, although a 17% increase is expected between 2015 and 2025 equating to 2,600 more people. Given the foregoing, there is a clear need for a higher proportion of homes which are capable of accommodating people's changing needs. Paragraph 10.19 of the IDP also states that hospitals will need to be redesigned to treat the patients of the future. The site could be suitable for housing for older people as it is located in a sustainable location close to services, facilities and to transport links. The IDP also highlights that there is an ongoing programme to improve the utilisation of Brentwood Community Hospital, to reduce the void costs associated with the building and to make better use of the opportunity for providing a range of health and care services. Strategic Objectives - This sub-section provides a review of the Spatial Strategy, and the Strategic Objectives and how they are of relevance to the subject site. Chapter 2 (Borough of Villages), Figure 2.3 sets out the borough's settlement hierarchy categories, to identify their role for delivering sustainable growth. Figure 2.3 outlines Brentwood as a "large town", alongside Shenfield with 4 urban neighbourhoods, 2 large villages, 1 garden village, 6 rural villages, and 7 rural villages in sparse settings. Paragraph 2.11 of the Consultation document outlines that Brentwood is the borough's largest settlement and offers the most scope to develop in, in accordance with sustainable development objectives as set out in the NPPF. Chapter 3 of the consultation document outlines the Borough's Spatial Strategy and Strategic Objectives. The Council have highlighted four strategic objectives and how the policies align to help deliver these policies. These are the following; * SO1: Manage Growth Sustainably; * SO2: Deliver a Healthy and Resilient Built Environment; * SO3: Deliver Sustainable Communities with Diverse Economic & Social-cultural Opportunities for All; and * SO4: Deliver Beautiful, Biodiverse, Clean and a Functional Natural Environment. The subsequent chapters outline the policies that sit within each strategic objective. These representations specifically comment on both: Managing Sustainable Growth (SO1) and Sustainable Communities (SO3). SO1: Managing Sustainable Growth - The Council aim to direct development to the most sustainable locations, ensuring that the characteristics and patterns of the settlements are protected and enhanced. The redevelopment of the site would aid the Council in delivering most of these objectives and policies. Although currently designated as Green Belt, the brownfield nature of the site and its location within the existing built up area of Brentwood means it can significantly aid in intensification. The site is also easily accessible by existing public transport modes as outlined in the 'site context' section of these representations. The site is highly sustainable and helps contribute towards delivering the Strategic Objectives including having no unacceptable effect on visual amenity; having no unacceptable impact on health; and causes no unacceptable effects on adjoining sites. The intensification of this site would also increase the critical mass of customers/users of existing services and facilities. This can help to ensure the viability of existing services and amenities in the local area. The site could also be optimised for retention in its current use with the provision of additional built form to provide additional health services or an extension to the current facilities. SO3: Sustainable Communities - The Council aim to highlight opportunities which flexibly respond to the changing economic climate and employment sector trends making citizens feel economically empowered to enjoy and benefit from the necessary community/social infrastructure that sustains inclusive, informed, vibrant, active and cohesive communities. The potential for the provision of residential development at the site would help the Council to meet their identified and growing need for housing over the plan period. The sustainable location of the site in relation to the existing built form and settlement of Brentwood means that should the site ever become surplus to the requirements of the NHS, it would be a great location for residential development. The site is adjoined to the settlement, so therefore can help contribute towards creating a cohesive community. Furthermore, as outlined above, the site is also capable of accommodating further healthcare-related development, including the possible expansion of the hospital to provide better and more comprehensive services for the local community. The site is located in a sustainable location and is easily accessible by public transport, cycling and walking and could therefore make a good location for the expansion of the existing healthcare facilities should this be required by the CCG in the near future. Chapter 3 also outlines the Council's spatial development principles, stating that development proposals in the borough will follow the following principles; 1. Urban Areas- Prioritise brownfield sites, making efficient use of land; 2. Brownfield Green Belt Land- Use of previously developed land in the Green Belt; 3. Strategic Sites- Use opportunities created by larger housing development; 4. Urban Extensions- deliver new homes in areas close to existing transport and local facilities; and 5. Windfall- an allowance for small scale development that will come forward in the future. The site is Brownfield Green Belt land (Tier 2) so therefore should be favoured for development over strategic sites and urban extensions. The Role and Extent of the Green Belt Policy NE9: Green Belt sets out that the Green Belt will continue to be preserved from inappropriate development so that "it continues to maintain its openness and serve its key functions". The redevelopment of this site would only seek for the removal of a small element of existing Green Belt land which is currently a mix of hardstanding car parking and woodland. This removal would enable efficient and maximum redevelopment of a brownfield site, without contradicting the purposes of the Green Belt. The NPPF states that Green Belt boundaries should only be amended in "exceptional circumstances". The Housing White Paper seeks to clarify this further and states that land which has been previously developed should be considered first. Accordingly, it is sites such as Brentwood Community Hospital which should be removed from the Green Belt. This is further outlined below, which highlights the sites suitability. a. Site Suitability The site is located adjoining the existing settlement and residential area of Shenfield, and a proportion of the site within the Green Belt is currently an existing hardstanding forming a car parking area. The site is located in close proximity to public transport connections which provides links to a variety of everyday services and amenities. As previously identified, the site is currently partially located (25% of the site) within the Green Belt. However, due to the existing built form within and surrounding the site, and as evidenced in the Green Belt Study, the site provides little or no contribution towards the purposes of the Green Belt. The Council undertook a Green Belt Study (November, 2018) which assessed various parcels of Green Belt land within the district. The site fell within Site Assessment 186, which concluded as having low-moderate contribution to the Green Belt. Although considered as having a low-moderate contribution to the Green Belt, a Green Belt assessment is provided below to outline the development potential of the land at Brentwood Community Hospital. The assessment is based on the Green Belt purposes identified in the NPPF. This assessment is to enable the Council to determine the importance of the site in Green Belt terms, and to demonstrate that the site does not meet the five purposes of the Green Belt, so therefore should be removed. 1. to check the unrestricted sprawl of large built-up areas - The site is bounded on three sides by the existing built form of Brentwood. The surrounding built form includes residential dwellings to the north and west, and a draft residential allocation to the east. - The built up area would not spread further than the site's boundary due to the presence of a significant area of woodland adjacent. 2. to prevent neighbouring towns merging into one another - The site falls between the settlements of Shenfield and Brentwood. Although the site falls between these two settlements, the built form of Shenfield and Brentwood already links through the existing built form on Shenfield Road and it is not this site that forms any gap rather the playing fields adjacent. - The site's built form also limits its purposes in restricting the two settlements from merging as it is clear that it is an existing built up area. 3. to assist in safeguarding the countryside from encroachment - The site is bounded to the north, east, and west by the existing built form of Brentwood. - The site is bounded to the south by existing woodland. - Due to the site not being located in the countryside, its contribution toward this aim is limited. 4. to preserve the setting and special character of historic towns - The site is not located within a historic town.5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The site is located within an existing settlement and promotes the intensification of an existing community facility which already has its own facilities, amenities, and day-to-day services, or, the site could equally be redeveloped for the provision of residential dwellings should the land become surplus to the NHS's requirements. b. Sustainability The golden thread running through the NPPF is a presumption in favour of sustainable development. This means that developments which accord with the Local Plan should be approved without delay. The three pillars of sustainability within the NPPF are identified as Social, Environmental, and Economic; the definitions of these terms and the ways the proposals at Brentwood Community Hospital conform to these pillars are identified below. Social The NPPF defines socially sustainable development as those which contribute toward supporting a strong, vibrant and healthy community by providing the supply of housing required to meet the needs of present and future generations, through a high quality built environment with accessible services and support of health, social and cultural wellbeing. The redevelopment of Brentwood Community Hospital would accord with the social pillar of sustainable development through the provision of an increased number of residential dwellings on a sustainably located site in order to help meet the Council's identified and growing need for housing. Should the Council fail to meet their identified housing target, there could be serious social instability caused including overcrowding of existing housing stock and undersupply of housing. In addition to this, the site could represent the opportunity for the delivery of affordable housing towards the Council's identified need, representing a further opportunity to deliver a socially sustainable development. Environmental The NPPF defines environmentally sustainable development as development which contributes to protecting and enhancing the natural, built and historic environment through improving biodiversity, using natural resources prudently, and minimising waste and pollution. A scheme at Brentwood Community Hospital could provide sustainably located residential dwellings within walking distance of existing services and amenities, reducing the need for future residents to travel long distances and reducing pollution and the use of finite resources. Alternatively, should the CCG seek to expand their existing facilities on site, the intensification of the existing healthcare services could help to ensure the healthcare facilities continue to be provided in a sustainable location. Economic The NPPF defines economically sustainable development as development which contributes toward building a strong, responsive, and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation. A residential scheme at Brentwood Community Hospital would accord with this pillar through the introduction of an increased number of residents into an existing urban area. These new residents will help to secure the economic viability and vitality of the existing local businesses and services through an increased customer base. The redevelopment of the site would also ensure that a higher provision of land is available for a land use which is identified as being highly demanded at this point in time ensuring that a sufficient supply of land is available in a sustainably located site.

Add land at rear of Mill House Farm to plan

1. Introduction & Background
Introduction

1.1 This Regulation 19 Local Plan representation has been prepared by Phase 2 Planning and Development Ltd on behalf of Mr Terry Haynes, on behalf of the freehold owner of the subject site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX as outlined by the Site Location Plan included at Appendix 1.

1.2 This submission is made under the Provisions of Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations (2012) and relates to the following sections of the Council's Pre-Submission Draft Local Plan:
- Section 4: Managing Growth
Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Representation summary
1.3 In summary, the landowner wishes to highlight the sustainability of the proposed site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality. Please see the remainder of this supporting statement for further consideration in support of the subject site's inclusion in this emerging Local Plan strategy.

2. Soundness & Modifications
2.1 As the attached representation form confirms the landowners representations relate specifically and solely to the soundness of the draft Submission Local Plan in respect of being positively prepared, justified, effective, and consistent with national policy in relation to the following sections of the emerging Local Plan:

- Section 4: Managing Growth

Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Soundness
Section 4: Managing Growth
Draft Policy SP02: Managing Growth
2.2 Although on the whole it is generally considered that the Council's Pre-Submission Local Plan is sound there is some concern that the Council's Housing Requirement is not fully robust.

2.3 Planning Practice Guidance (PPG) on 'Housing and economic needs assessment', which was updated on the 20th February 2019, confirms at 'Paragraph: 005 Reference ID: 2a-005-20190220' that 2014 based household projections should be used as the baseline for the 'standard method'. The reason given for this approach is to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government's objective of significantly boosting the supply of homes.

2.4 Paragraph 4.13 of the Council's Pre-Submission Draft Local Plan confirms that Council's 'housing requirement figure' to be 350 dwellings per year. With a 20% uplift, the total annual housing requirement is 456 dwellings per year.

2.5 This housing requirement has been calculated within the Strategic Housing Market Assessment, published in October 2018 (i.e. before the latest Planning Practice Guidance assessment) with this assessment confirming that the housing requirement has been calculated using the 2016 population projections as a starting point (see paragraph 8.26 of the SHMA in particular). Accordingly, the Plan cannot be considered to be fully sound on this basis.

2.6 An indicative assessment of housing need based on the Standard Method using the 2014 population projections was published in September 2017. This stated that Brentwood's housing need, based on the Standard Method, was 454 dwellings per annum. Applying the 20% uplift to this figure would result in a housing requirement of 545 homes per year, or a total of 9,262 homes during the plan period 2016-2033.

2.7 This is an increase of 1,510 dwellings from the housing requirement calculated by the SHMA calculations which uses the 2016 population projections as a starting point.

2.8 Accordingly, we consider that the Inspector should, during the Examination, request that Brentwood update its evidence base, and its housing requirement, to reflect the 2014-based population projections. This will result in the requirement to identify additional site allocations, as considered further below.

2.9 With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan-Pre-Submission Document can be considered to be robustly sound as, in accordance with paragraph 35 of NPPF3, the Plan is not fully consistent with National Policy in its use of 2016 population projections to determine its housing requirement. In this respect, the Plan has also not been positively prepared in full as it will not, as a minimum, meet its objectively assessed needs.

Section 9: Site Allocations
2.10 The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Pre-Submission draft Local Plan. Table 4.2 of the Local Plan identifies that the allocations total 6,088 dwellings, with the remaining dwellings comprising completions between 2016/17 & 2017/18 (363 dwellings); extant permissions (926 dwellings); and the windfall allowance between 2023-2033 (410 dwellings).

2.11 Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not fully sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation.
1.4 The following section of this representation provides support for land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX, to be allocated for new residential development.
1.5 Notwithstanding this, it is considered that additional sites will be required in any event to ensure the housing requirement is met. Appendix 1 of the Local Plan sets out the Council's anticipated Housing Trajectory, which we do not fully agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears ambitious.
1.6 In particular, Dunton Hills Garden Village is identified as being capable of delivering 2,700 dwellings during the plan period, with the site being capable of delivering 100 dwellings starting from 2022/23 (i.e. within 3 years), and then between 150 - 300 dwellings each year thereafter.
1.7 This level of growth from such a strategic allocation does not appear realistic and no evidence has been put forward to date to support this forecast. For example, it is unlikely that the Local Plan will be adopted until 2020 at the earliest (the Council's Local Development Scheme
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suggests that the plan would be adopted in Q3 2019, but the timescales have slipped as the Plan was due to have been submitted in Q1 2019).
1.8 For a scheme of Dunton Hills, and the level of constraints that it faces, and the vast range of application documents that would be required, including Environmental Assessment, it is realistic to assume that an outline application could take 9-12 months to be determined. Given the level of information that would be required to support the application (Consultant Reports, EA, Public/Statutory Consultation), therefore, it is realistic and reasonable to assume that it may take up to two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission.
1.9 There would then, of course, follow further applications to discharge conditions and Reserved Matters applications, none of which would be straight forward and would require similar levels of detail to an Outline Planning Application. This process could, itself, take 9-12 months, if not longer.
1.10 Accordingly, it is realistic to assume that, from adoption, it would take close to three years before planning permissions have been approved, and conditions discharged, such that development can commence on site. This would mean that, at the earliest, dwellings will not be brought forward until 2023/24, and not 2022/23 as considered by the Housing Trajectory. Such delays in the Council's Housing Trajectory will have inevitable consequences on the Local Authority being able to deliver its housing requirement during the Plan Period.
1.11 As such, it is considered that additional sites will be required during the Plan Period to ensure that a) the Local Authority is able to deliver its housing requirement during the Plan Period (notwithstanding our view that the Council has not calculated its correct requirement); and b) that additional sites will be required to allow for flexibility in allocated sites not being brought forward within the timescales identified within the Housing Trajectory.
1.12 Furthermore, it is considered that the Local Plan is not entirely sound as it does not comply fully with paragraph 68 of the National Planning Policy Framework (NPPF3) (February 2019).
1.13 Paragraph 59 of the NPPF requires Local Authorities to 'boost significantly' the supply of housing and must, "ensure choice and competition in the market for land". This involves boosting provision of housing from a variety of sources, including small sites which are suitable for smaller housebuilders.
1.14 This is reinforced by paragraph 68 of the revised NPPF, which confirms that small sites make an important contribution to meeting housing requirements and confirms that planning authorities should accommodate at least 10% of their housing requirement on sites no larger than one hectare.
1.15 The Council's housing strategy only allocates 5% on sites no larger than one hectare. The NPPF confirms that smaller sites make an important contribution to meeting housing requirement,
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in part as they are able to be developed quickly and are able to therefore contribute towards housing supply whilst Strategic Sites are being brought forward in the background.
1.16 Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX) should be identified for allocation.

1.17 We would therefore request that the Local Authority reviews its housing supply, and particularly its approach to small sites, and allocate suitable smaller sites which can be brought forward early in the plan period.

Necessary modifications to make the Pre-Submission Draft Local Plan sound
1.18 With regards to Section 2, it is considered that Brentwood Borough Council will need to revisit its evidence base to determine a housing requirement which uses the 2014 population projections as a starting point. This will result in a larger housing requirement, with our estimate based on the indicative Standard Method being approximately 545 homes per year, or a total of 9,262 homes during the plan period 2016-2033.

Chapter 9 - Site Allocations & Local Development Plan Housing Trajectory
1.19 It is considered that additional sites should be allocated to ensure that the Local Authority can meet its housing requirement to 2033. Even if the Inspector agrees with the Council's objectively assessed need, it is likely that additional sites will be required to be brought forward given the Council's overly optimistic approach to its housing trajectory, particularly with regards to Dunton Hills Garden Village.
1.20 Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3.
1.21 It is considered that land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX is an appropriate site for residential development and should be allocated for appropriate new residential development.
1.22 The site itself includes land directly east of Hook End and north of Wyatts Green which would continue the existing pattern of development in this location as well as extend north comprising a logical and well-contained urban extension to the village with existing residential development already neighbouring the site to the south and west. Despite this the subject site still remains of a greenfield nature situated within the Metropolitan Green Belt.

1.23 Although noted that Hook End/Wyatts Green are proposed to be classified as smaller villages within the Borough's Settlement Hierarchy the importance of allocating appropriate growth throughout the Borough cannot be underestimated. The subject site itself would be well-placed to assist in enhancing the vitality of these rural communities allowing these villages to grow and thrive, especially where there are groups of smaller settlements, with development
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in one village able to support services in villages nearby as advocated by para 78 of NPPF3. This is particularly relevant in this instance given Hook End/Wyatt Green's physical relationship to the nearby villages of Stondon Massey and Doddinghurst as well as the village of Blackmore which itself includes some planned growth under the current Local Plan strategy.

1.24 Importantly NPPF3 also highlights at para 84 that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. It adds at para 103 that opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making.

1.25 Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed this part of Hay Green Lane lying on the southern edge of 'Parcel 48 Wyatt's Green East. The report when assessing the parcel as a whole, confirms that it makes a 'high' overall contribution to Green Belt Purposes although it is noted that the majority of this parcel is open to the east of Wyatt's Green with the subject site adjacent to the physical extent of the village to the north and much more likely to play a less substantial role in such purposes.

1.26 The Green Belt Study Part 3 - "Assessment of Potential Housing, Employment and Mixed Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation" - was published in November 2018, and subsequently amended in January 2019. This part of the Green Belt Study assesses the potential Site Allocations against the purposes of the Green Belt.

1.27 Our own assessment against the purposes of the Green Belt is given below.

Purpose 1: to check the unrestricted sprawl of large built-up areas: The site lies within the rural area of Hook End and is well contained by existing built development and mature trees. Development would be seen as a logical extension to the physical extent of the village and would have a very limited encroachment into the countryside. Existing site boundaries would prevent any further development into the Green Belt, with these boundaries presenting a strong and definite boundary to further development.
Purpose 2: to prevent neighbouring towns merging into one another: Development on this site would not significantly reduce the countryside gap between Hook End/Wyatts Green and nearby villages. Such countryside separation would be retained.
Purpose 3: to assist in safeguarding the countryside from encroachment: The site has no specific countryside function and would utilise a well-contained parcel of land surrounded by residential development.
Purpose 4: to preserve the setting and special character of historic towns: The site has no physical relationship with any historic town.

1.28 Accordingly, it is considered that the site is suitable to be released from the Green Belt.
1.29 Furthermore, it is noted that the Borough Council's proposed allocations allocates a number of sites within the Green Belt which the Green Belt Study confirms as making a 'moderate' contribution to the Green Belt, including:

Site R23 Brizes Corner Field, Kelvedon Hatch (23 dwellings);
Site R25 Land north of Woolard Way, Blackmore (40 dwellings); and
Site R26 Land north of Orchard Piece, Blackmore (30 dwellings).
1.30 Those sites listed above are located within villages and the rural area comparable to that of the subject site.

1.31 Accordingly, we would request that the Local Plan be modified to allocate land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas.

Conclusions
1.32 Based on the information set out above, it is considered that the inclusion of the subject site within the Council's proposed housing growth strategy or as an alternative reserve site would be sustainable and fully deliverable early within the Local Plan period, improving the overall soundness of the emerging Local Plan itself.

1.33 The possible low density nature of the allocation gives scope to provide a sensitively designed scheme which can be designed to integrate within and enhance the existing landscape having appropriate regard to local features and surrounding land uses, including existing neighbouring residential development.

1.34 Subsequently, the landowner contends that the relevant sections of the emerging Local Plan referred to within would be sound but could be improved further with the inclusion of this site ensuring the emerging Plan is positively prepared, effective and justified, and would be fully consistent with national policy including 'boosting significantly' the delivery of new homes within a borough that is heavily constrained by the Metropolitan Green Belt.

Inclusion of a red line boundary map for the site in question.

1. Introduction
1.1 These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Pre-Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients' land at 030A, Land at Bayley's Mead, Hutton, Brentwood. A plan showing the site is provided as Appendix A to this representation.
1.2 Countryside was founded in Essex 60 years ago by Alan Cherry and has since established a reputation for delivering high quality developments. With the ethos 'creating places people love', Countryside's achievements are exemplified through having won more Housing Design Awards than any other house builder.
1.3 Countryside is a major development and place-maker, having secured planning permission and building out developments in varying scales: from smaller 30 dwelling schemes on the edge of village's through to large urban extensions of 3,500 new homes plus associated community facilities. Countryside has a proven track record of delivery. The company is headquartered in Brentwood and has a proud legacy of local sites such as Clements Park and the Square on Hart Street.
1.4 As the Council will be aware, representations have previously been made on behalf of Countryside Properties and in respect of both sites 030A on the Preferred Options Consultation in October 2013 and the Strategic Growth Options Consultation February 2015, and the Regulation 18 Local Plan in March 2018.
1.5 Site 030A measures approximately 2.36 hectares. The Council have previously confirmed the net developable area of the site as 1.66 hectares, with the ability to provide an estimated 30 dwellings on site. The site is situated within the Green Belt.
1.6 Whilst the Plan is considered effective in meeting the minimum housing requirements through the proposed allocations, an unjustified lack of housing provision to exceed the minimum requirements, and to provide an appropriate buffer and flexibility for the future, does prevent the Plan from being considered sound as a whole.
1.7 Site 030A has been discounted as a site for residential development through the Local Plan process, for reasons which are considered in more detail later within this representation. We consider the rejection of the site to be unjustified, and to result in a PSLP which does not promote sustainable development and as such is unsound.
1.8 The allocation of the site, at Bayley's Mead, Hutton, for residential development would represent a sustainable and deliverable proposal to help meet housing need over the coming plan period and ensure the soundness of the Local Plan.
1.9 As a minimum, the site should be safeguarded for potential future release from the Green Belt to ensure that the Green Belt remains protected throughout the entire plan period, in accordance with Paragraph 139 of the NPPF.
1.10 This representation set out comments on the Regulation 19 Draft Local Plan, as well as providing detail on the sustainability and deliverability of the site with regards to technical considerations and latest assessment work.
2. Brentwood Local Plan Regulation 19 Consultation
Plan Period
2.1. The Draft Local Plan is proposed to guide development in the Borough of Brentwood until 2033. The National Planning Policy Framework (NPPF, 2019) makes clear at Paragraph 22 that strategic policies within Local Plans should look ahead over a minimum of 15 years.
2.2. At this stage it would be optimistic to assume that adoption of the Draft Plan, which forms the subject of this representation, will happen within 2019 and therefore the plan will only address development needs in the area for a maximum of 14 years.
2.3. This shortfall is particularly relevant in respect of Green Belt, whereby a failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of Green Belt being required. This review ahead of a new Local Plan would be contrary to the NPPF (paragraph 136), and also undermine one of the two essential characteristics of the Green Belt: its permanence (NPPF, Paragraph 133).
Total Housing Requirement
2.4. Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 dwellings per annum. Paragraph 4.12 confirms that this figure is calculated using the Standard Method (as per the NPPF and respective Planning Practice Guidance(PPG)). We note that the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).
2.5. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures, the result is a requirement of 452 dwellings per annum.
2.6. The NPPF requires for Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.
2.7. As mentioned previously, the Plan should also ensure that any revised Green Belt boundary should be robust enough to be maintained beyond the Plan period and therefore account for development needs beyond 2033 (or a revised later end date to the Plan period to ensure strategic policies will cover at least 15 years).
2.8. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). Councils have a duty to cooperate with one another on strategic matters, including on unmet housing needs (paragraphs 24 to 27 of the NPPF). The PSLP does not make an allowance for any unmet needs from neighbouring authorities.
2.9. Whilst the South Essex authorities are working together on a joint strategic plan, the Local Plans for each authority must still demonstrate joint working and a consideration of unmet needs where required. A number of nearby authorities have identified difficulties in meeting their own housing needs, including Castle Point, Rochford and Southend. We also not that Epping Forest District Council in particualr is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum.
2.10. Furthermore, the Borough is located within close proximity of London, with the emerging Local Plan identifying high housing delivery on outer London Boroughs and that London will fall short of meeting its housing needs by 10,000 homes over the next ten years. Unmet need from London could therefore be required to be met by nearby authorities, including Brentwood.
2.11. Whilst no authority has formally approached Brentwood in relation to unmet need, it is not inconceivable that an authority will do. Under the current PSLP there is no flexibility to meet any unmet needs from neighbouring authorities, requiring a plan review should a request to meet unmet needs be received once the plan is adopted.
2.12. Allocating additional sites would provide greater flexibility should a request to meet unmet needs be forthcoming, avoiding the need for an early plan review. This flexibility should also be provided in accordance with paragraph 11 of the NPPF and to accommodate additional need arising from extending the plan period.
2.13. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to be maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.14. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement. The plan is therefore considered ineffective in its current form and has not been positively prepared to provide an appropriate level of contingency in terms of housing delivery, or to comply with national planning policies. As such we consider the PSLP to be unsound.
2.15. As a minimum, we consider that the PSLP's housing need should be amended to at least ensure that an additional year's worth of housing need can be accommodated, and so that the relevant strategic policies of the Plan cover at 15 years from adoption. Realistically, we expect that an additional 2 years' worth of housing may be required to support a plan period up to 2035. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. The allocation of sites for housing in Hutton, including that at Bayleys Mead, would provide for additional housing delivery in a sustainable location and help to ensure that the Plan can be found sound.
Five-year Housing Land Supply and Housing Trajectory
2.16. The Council is required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).
2.17. The NPPF (Paragraph 73) confirms that a 20% buffer should be applied to the initial calculation for a five year housing land supply requirement, in the event that the results of the Housing Delivery Test show that there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. From November 2018 significant under delivery indicates that delivery was below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037-20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.18. The results of the 2018 Housing Delivery Test confirmed that Brentwood have delivered just 50% of the housing requirement over the last three years and this is therefore well below the threshold for the 20% buffer requirement.
2.19. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018)) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.20. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
2.21. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be considered deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.22. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can be delivered early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.
2.23. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.24. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.25. Furthermore, Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
2.26. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations.
2.27. As such, we question the likelihood of 100 homes being completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does demonstrate the unsuitability of relying on large strategic sites for short term housing delivery, and means that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound.
2.28. It is evident that whilst the Plan can demonstrate housing delivery appropriate to meet minimum recognised requirements, the suggested inability of the Plan to ensure a consistent five-year supply is inconsistent with national policy, which requires that local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years' worth of housing against their housing requirement set out in adopted strategic policies. The PSLP should therefore support this requirement through the allocation of smaller scale sites that can be delivered over short timescales to be found sound. Land at Bayleys Mead is a site that would cater to this need, with its deliverability discussed in greater detail later on in this representation.
Proposed Approach to Hutton
2.29. Within the PSLP, the Borough's settlement hierarchy identifies Hutton as Category 1 - an 'urban neighbourhood'. A Category 1 settlement is defined as having a wide range of services, and are typically highly accessible and well served by public transport provision. Hutton has an established local centre which benefits from a range of services, facilities, access to public transport, and employment opportunities.
2.30. The town is situated approximately 30km from Central London, 12km from Chelmsford and well-connected in respect of regional and national infrastructure. Brentwood and Shenfield are accessible along the A12 corridor.
2.31. Hutton is a highly sustainable location, and therefore well-placed to accommodate a proportion of the Borough's housing need. In addition, the Local Plan should manage growth of such settlements to sustain and enhance their vitality.
2.32. Irrespective of the above, the PSLP proposes no growth for Hutton, in contrast to the level of growth afforded to other settlements identified as Category 1 settlements, or also those below Hutton, within the Borough's settlement hierarchy. We have concerns therefore that the PSLP fails to support the sustainable growth of Hutton and that this omission is unjustified and inconsistent with national policy.
2.33. To ensure the soundness of the Local Plan, land should be allocated in Hutton to protect the future of this settlement and ensure sustainable growth.
Green Belt
2.34. A Green Belt Study (November 2018) supports the PSLP. This study provides an assessment of Green Belt parcels against the five purposes of the Green Belt, as set out within the NPPF.
2.35. The study includes an 'assessment of Housing Sites (being considered as part of the SHLAA) within the Green Belt and their relative contribution to the purposes of the Green Belt designation'.
2.36. The site has been assessed against the five purposes of the Green Belt, as part of the Green Belt Study methodology as follows:
Purpose 1: To check the unrestricted sprawl of large built up areas
Parcel 14 is defined by the Council as 'partly contained', and recognises that it abuts a large built up area. This categorisation does however advise that the boundary is 'weak/degraded/unclear'. The site 030A is contained on two out of four boundaries by built form however and on remaining boundaries by established vegetation and hedgerows that could be incorporated and enhanced as part of a landscaping scheme that would support the redevelopment of the site. We consider that the site boundaries are clearly defined and the site is therefore well-contained. A conclusion of containment should not consider built form exclusively.
Purpose 2: To prevent neighbouring towns from merging into one another
The site is adjacent the eastern limit of Hutton Mount and the Green Belt Study correctly recognises that its development would retain separation from neighbouring towns. The next settlement to the east is Billericay and this is some distance away with a large green gap between the two. Other parts of Hutton already extend closer to Billericay without posing any risk of merging.
Purpose 3: To assist in safeguarding the countryside from encroachment
The site is defined by the Council as 'Functional Countryside' (FC). The assessment defines Functional Countryside as "access land, public area (park), high number of PRoW and important routes e.g. National Trail'. The site itself is overgrown, in private ownership, covered in dense vegetation, and not suitable for public access. It is not agricultural and is therefore not functional and this assessment of the site is incorrect.
Purpose 4: To preserve the setting and special character of historic towns
Brentwood Borough Council have recognised that site 030A has no physical of visual relationship with the Historic Town. It is some distance from the town centre with no direct relationship. It is directly associated with contemporary housing developments at Bayley's Mead and surrounding roads, which present limited historic character.
Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
Brentwood Borough Council have not provided an analysis for Purpose 5.
2.37. Overall, Brentwood Borough Council have assessed the site as having a moderate overall contribution to the Green Belt, despite the favourable assessment of the site. Where the site was assessed to have an important role on the Green Belt, we have outlined above that these elements of the assessment are incorrect and not reflective of the sites true characteristics.
2.38. The development of this Green Belt site, which has limited environmental value and offers a minimal contribution to the Green Belt when assessed against its five intended purposes, would help to support housing delivery in a sustainable location in the Brentwood Borough, whilst protecting other Green Belt sites of much higher environmental value.
2.39. The weaknesses and inconsistencies recognised in the individual site assessments made demonstrate a potential flaw in the evidence base for the Local Plan and could result in the unjustified omission of Green Belt sites from consideration for allocation as part of the new Local Plan.
2.40. The above analysis of land at Bayleys Mead, Hutton demonstrates that there remains small scale opportunities for sustainable development within the Green Belt and that the Local Plan should give consideration to the allocation of such sites alongside larger scale areas of release.
Strategic Environmental Assessment/Sustainability Appraisal (SEA/SA)
2.41. The PSLP is supported by a range of technical work, including the Sustainability Appraisal (SA) January 2019. The SA presents a number of sustainability issues/objectives which have been established through SA scoping. Together, these sustainability topics and objectives provide a methodological framework for the appraisal of potential allocation sites - including site 030A.
2.42. The SA indicates that the allocation of site 030A would have positive effects in relation to the SA objectives. The SA analysis states that site 030A is in good proximity to a secondary school (less than 1.5km), but in 'red' proximity from a GP surgery and a primary school. Willowbrook Primary School is located within 1 mile of the site, which is considered to be within walking distance to the site. The nearest GP Surgery, Mount Avenue Surgery is located 1.5 miles from the site. Mount Avenue Surgery is defined in the Regulation 18 document to be 1 of 3 surgeries within the District which has an average of 0.58 GPs per 1,000 patients, which is the national average. Furthermore, Mount Avenue Surgery has a large catchment area, therefore it is considered that it would provide service to those living at the site. Furthermore, Brentwood Community Hospital is located less than 3 miles from the site.
2.43. The SA, through its analysis also states that the site at Bayley's Mead is in an area that 'performs poorly' in respect of its proximity to Ancient Woodland, Local Wildlife Site, Woodland and Green Belt. The proposed development of the site will not unacceptably impact on Ancient Woodland, Woodland or a Local Wildlife Site. This scoring is considered to be highly assumptive and rules out the potential of sites being landscaping led and providing opportunities for the enhancement such features and local biodiversity. Being within 400m of a local wildlife site does not necessarily mean that there will be direct impacts on the site.
2.44. In relation to Green Belt, the assessment is binary in it's approach - if a potential site falls within the defined Green Belt, it will be given an 'Amber' score. Whilst the methodology notes that the Green Belt is not specifically a landscape designation, and as such potential effects on the setting have not been appraised, a blanket 'amber' score on anything seems arbitrary.
2.45. A Green Belt Review of the Borough, and the contribution that each individual site makes to the Green Belt has been undertaken and this is discussed in more detail in the following section of this representation. This recognition of differing value across individual sites should have influenced scoring for this element of the SA, and replaced the non-conducive binary approach taken.
2.46. In general, we consider that the SA Report is simplistic in its approach to individual site assessment. The SA has used a predominantly spatial or 'GIS' (use of Geographical Information Systems) approach to the assessment of each criteria, using the distance between the site and various factors to judge the extent to which it either achieves or opposes certain objectives. It has had no consideration for the positive contribution that the development of sites can make to the natural environment and local facilities.
2.47. The assumption made within the Sustainability Appraisal that sites will only negatively impact the Green Belt and other landscape and natural environment designations has contributed to the unjustified omission of sites from allocation as part of the Local Plan which has subsequently resulted in the plan being unsound.
3. Site Deliverability
3.1. The site represents a deliverable, sustainable and achievable site for residential development. There have been technical reports and associated documents completed which demonstrate this. The below section provides a summary of these documents.
Access & Connectivity
3.2. The site is considered to have good access and connectivity to the surrounding area. The vehicular and pedestrian access to the site is proposed to be from Bayley's Mead. The access arrangement was considered as satisfactory through the 2013 Draft Site Assessment.
3.3. The site is approximately 1.3 miles from Shenfield Station (approximately a 25 minute walk / 8 minute cycle). Shenfield Station provides frequent services to London Liverpool Street, Chelmsford, Colchester and Ipswich and settlements between. These destinations also provide connections to the wider national transport network. Shenfield Station is also the terminus for the new Elizabeth Line which is part of Crossrail. Crossrail provides frequent services into Central London.
3.4. A public bus stop is located approximately 200m from the site. This bus stop provides frequent services to Basildon Town Centre, Brentwood High Street, Billericay and Shenfield Rail Station, amongst services to smaller neighbouring settlements.
3.5. The site is well connected to the surrounding road network. The site is located approximately 2.5 miles from the A12. The A12 provides efficient access to settlements across Essex and East Anglia such as Chelmsford, Colchester and Ipswich, as well as a direct connection to the M25.
3.6. The site is immediately adjacent St Martin's School, a large seconday school and sixth form. There are also a number of primary schools in the area, including Willowbrook Primary School and Hutton All Saints Primary School which are both less than a mile from the site.
3.7. Given the high access and connectivity levels of the site, it is evident that Site 030A is within a sustainable location and should therefore be considered as a site for residential development.
Ecology
3.8. An ecological appraisal was undertaken by Green Environmental Consultants Ltd. In September 2013.
3.9. The ecological appraisal states that the site is abandoned farmland which is being colonised by scrub and tree species from woody boundary habitats. There are mature trees, mostly on two of the boundaries which may be used by bats of nesting birds. Otherwise the potential of the site is poor.
3.10. The ecological appraisal recommends further bat survey work to be undertaken on site and for the mature boundary trees to be protected and enhanced.
3.11. The ecological appraisal concludes that there are no significant or major impacts on a significant resource to be expected through the development of the site, but recognises that loss of scrub and some trees is likely to occur. This could be easily mitigated and enhanced through a landscaping scheme to support any future development on the site.
Geo-Environmental/Engineering
3.12. A preliminary engineering appraisal was undertaken in February 2013. This appraisal includes details on foundations, highways, drainage and contamination.
3.13. The geo-environmental appraisal concludes that there are no significant physical geo-environmental constraints to development on the site.
Drainage
3.14. The preliminary engineering appraisal states that foul water from the proposed development would discharge to the existing pumping facility and thereafter to the sewer in Hanging Hill Lane.
3.15. The appraisal states that storm run-off from the developed site would discharge at the ditch.
3.16. The existing surface water catchment for the local residential area drains into a 600mm diameter pipe which discharges via a headwall into the western end of the northernmost ditch within the site. This ditch runs across the site and continues eastwards beyond. The Environment Agency map indicates that an interconnecting ditch system eventually outfalls to the River Can. The appraisal states that drainage storage is likely to be provided through the design of a sustainable urban drainage system which may include a combination of contributing elements, swales, ponds and underground cellular storage.
Contamination
3.17. The preliminary engineering appraisal states that an intrusive soil investigation will be required to confirm whether the soil on site is contaminated. The appraisal states that in view of the perceived history of the land, this is unlikely to be the case.
Highways
3.18. The preliminary engineering appraisal states that the current width of Bayley's Mead is 5.5m which could support a development of 30 dwellings.
3.19. The appraisal states that the sight line visibility from Bayley's Mead onto Hanging Hill Lane is about 2.4m x 65m to the right hand side with the 'y' distance being much greater to the left. The requirement for a 30mph road is 2.4 x 43m. Even if measured vehicle speeds in Hanging Hill Lane are greater, for example up to 37mph, then the visibility requirement for that speed (2.4 x 59m) is still achieved.
3.20. The appraisal concludes that there is no objective reason as to why the existing access road could not support the development of Site 030A.
4. Summary
4.1. Whilst the current proposed allocations and strategic policies of the PSLP appropriately address the minimum requirement of housing recognised for the Plan period, we have reason to query the appropriate length of the Plan period, and a lack of flexibility in the housing provision and such consider the Plan unsound due to its inability to comply with national planning policy, the unjustified omission of a housing supply which exceeds minimum requirements, and given that the Plan has not been positively prepared to account for potential changes to the market and housing requirements beyond those forecast.
4.2. There is evidently a case for Site 030A to be further considered as a sustainable opportunity in respect of Brentwood Borough Council needing to further increase their housing delivery over the plan period. The development of this site would not impact the function of the Green Belt in this location and is immediately adjacent to Hutton, a 'main town' with facilities and services that could support sustainable growth. Development here would also accord with the Brentwood Borough Council Spatial Strategy which directs growth towards the A12 transport corridor.
4.3. The analysis and content within the accompanying studies evidence the deliverability, achievability and suitability of the site for development and why it should therefore be allocated by Brentwood Borough Council as a site for residential development to aid the Plan in being sound. We consider there to be outstanding opportunities for the plan to identify sustainable sites that are suitable for delivering housing over short timescales to ensure that the Plan is flexible and robust, and well-prepared to meet housing needs over the entirety of the plan period.
4.4. Development of the site is supported by a wealth of technical evidence that confirms its suitability, including in relation to the lack of harm to its development to the purposes of the Green Belt. The reasons given for the rejection of the Site are therefore based on a number of assumptions and simplistic conclusions.
4.5. The exclusion of Site 030A is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton. The allocation of Site 030A for development will assist in correcting shortfalls in respect of the Local Plan, enabling it to be a sound plan.
4.6. We note the requirements set out under Paragraph 139 which confirms that when defining Green Belt boundaries and where sites may not be allocated for development at the present time, plans should "identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period".
4.7. As a minimum therefore, land at Bayleys Mead should be safeguarded for future Green Belt release as and when a need may arise given its highly sustainable location and suitability to be developed without incurring encroachment between Hutton and the main Brentwood urban area.

1. Introduction
1.1 These representations are submitted by Strutt & Parker on behalf of Marden Homes Ltd in relation to the Brentwood Borough Council Consultation Draft Local Plan (Regulation 19), and in particular with regards to our client's land adjacent to 7 Hanging Hill Lane, Hutton, Brentwood (ref. 284). A plan showing the site is provided at Appendix 1 of this representation.
1.2 Representations have previously been made on behalf of Marden Homes Ltd and in respect of Site 284 land adjacent to 7 Hanging Hill Lane on the Brentwood Borough Council Preferred Site Allocation Consultation Document (Regulation 18) in March 2018.
1.3 Site 284 lies to the south of Hutton and is adjacent to existing development. It measures approximately 0.9ha and it is proposed that the majority of the site is suitable for development. The front of the site is made up of a number of derelict sheds and structures which are single storey in height, along with dense vegetation. The majority of the site comprises grassland. The site is situated within the Green Belt.
1.4 Site 284 has been discounted as a site for residential development through the Local Plan process, for reasons which are considered in further detail later within this representation. We consider the rejection of the site to be unjustified, and to result in a Pre-Submission Local Plan (PSLP) which does not promote sustainable development.
1.5 The allocation of the site at Hanging Hill Lane, Hutton, would represent a sustainable and deliverable proposal for residential development to help meet housing need over the coming plan period. This representation sets out comments on the Regulation 19 Draft Local Plan, as well as providing detail on the sustainability and deliverability of the site with regards to technical considerations and the latest assessment work.
2. Brentwood Local Plan Regulation 19 Consultation
Plan Period
2.1. The Draft Local Plan is proposed to guide development in the Brentwood Borough until 2033. The National Planning Policy Framework (NPPF, 2019) clearly states at Paragraph 22 that strategic policies within Local Plans should look ahead over a minimum of 15 years.
2.2. At this stage it would be optimistic to assume that the adoption of the Draft Plan which forms the subject of this representation will happen within 2019 and therefore the plan will only address development needs in the area for a maximum of 14 years.
2.3. This shortfall is particularly relevant in respect of Green Belt, whereby a failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of Green Belt being required. This review ahead of a new Local Plan would be contrary to the NPPF (paragraph 136), and also undermines one of the two essential characteristics of the Green Belt: its permanence (NPPF, Paragraph 133).
Total Housing Requirement
2.4. The required housing need figures as calculated through the Borough's SHMA, follows national guidance using the Standard Method (as per the NPPF and respective Planning Practice Guidance (PPG) 2018). Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 new homes per year.
2.5. However, the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).
2.6. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum.
2.7. The NPPF requires for Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.
2.8. As mentioned previously, the Plan should also ensure that the revised Green Belt boundary should be robust enough to be maintained beyond the Plan period and therefore account for development needs beyond 2033 (or a revised later end to the Plan period to ensure strategic policies will cover at least 15 years).
2.9. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In respect of this, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of any objection to this approach from Brentwood Borough Council, but neither is there any indication that the PSLP addresses any of this unmet need.
2.10. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to be maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.11. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement. We consider that the Plan in its current form is ineffective. It has not been positively prepared to provide for the appropriate level of contingency for housing delivery, nor does it comply with national planning policies in this regard. As such we consider the PSLP to be unsound.
2.12. We therefore consider that the housing need within the PSLP should be amended to at least ensure that an additional year's worth of housing can be accommodated for, and so that the relevant strategic policies of the Plan can cover 15 years from adoption. Realistically, we consider that the Council may actually need an additional 2 years worth of housing in order to support a plan which runs to 2035. Therefore one additional year should be regarded as the minimum.
2.13. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Allocating further sites for housing, like sites at Hanging Hill Lane, would provide additional housing delivery in a sustainable location, and would therefore help to ensure that the Draft Local Plan can be found sound.
Five-year Housing Land Supply and Housing Trajectory
2.14. Councils are required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).
2.15. At paragraph 73 of the NPPF it confirms that a 20% buffer should be applied to the initial calculation for a five year housing land supply requirement, in the event that the results of the Housing Delivery Test show for delivery to have fallen below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037- 20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.16. The results of the 2018 Housing Delivery Test showed that Brentwood Borough Council delivered just 50% of its housing requirements over the last three years. This is well below the threshold of 20% as required by national guidance.
2.17. The Borough's most recent five-year housing land supply figure, as reported in their' Five Year Housing Land Supply Statement as at 31 March 2018' (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.18. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
2.19. The HLSS includes sites without detailed planning permission within their supply and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considered deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. These sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can deliver early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.
2.21. The housing trajectory provided at Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.22. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.23. Furthermore, Dunton Hills Garden Village is a proposed major strategic development that is intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure and new community and health infrastructure. The delivery of Dunston Hills will be dependent on the coordination and input of multiple landowners, developers, infrastructure providers and other relevant stakeholders.
2.24. Once allocated, the PSLP proposed that a masterplan and design guidance will be required. Following this, an outline application will need to be prepared, submitted and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations.
2.25. We therefore question how likely the 100 homes at Dunton Hills will be completed by 2022/23. Of course, Dunton Hills can still form part of a sound Local Plan, however this does demonstrate that the reliance on large strategic sites for shorter term housing delivery is not appropriate. Additional smaller sites are capable of providing homes through the early years of a plan period and should be allocated through the PSLP to ensure the Local Plan is sound.
2.26. Whilst the plan can demonstrate housing delivery appropriate to meet minimum recognised requirements, it is evident that the suggested inability of the plan to ensure a consistent five-year supply is not consistent with national policy. National Policy requires that local planning authorities should identify and update a supply of specific deliverable sites sufficient to provide a minimum of five years' worth of housing against their housing requirement set out in the adopted strategic policies, on an annual basis.
The PSLP should support this requirement through the allocation of smaller scale sites that can be delivered over a shorter time period, in order to be found sound. Land at Hanging Hill Lane, could cater to this need. Its deliverability is discussed in greater detail in subsequent sections.
Proposed Approach to Hutton
2.27. Hutton is recognised as Category 1 - 'a main town' within the PLSP's settlement hierarchy. Hutton is the second largest settlement in the Borough, with an approximate population 15,578 (according to the 2011 Census). It has an established local centre which benefits, from a range of services, facilities, access to public transport, and employment opportunities.
2.28. Hutton is well-connected in respect of regional and national infrastructure, situated approximately 30km from Central London, 12km from Chelmsford, accessible from the A12 or national rail services.
2.29. Hutton is therefore a highly sustainable location, and makes it an ideal location to accommodate a proportion of Brentwood's housing need. The Local Plan should manage growth of such settlements to sustain and enhance their vitality.
2.30. The PSLP proposes no growth for Hutton, despite its identification as a Category 1 settlement. This is in direct contrast to the level of growth afforded to other settlements which are also identified as Category 1 or are below Hutton within the Borough's settlement hierarchy. We therefore have concerns that the PSLP is failing to support the sustainable growth of Hutton and this omission is unjustified and inconsistent with national policy.
2.31. Land at Hanging Hill Lane should be allocated in Hutton to ensure the sustainable growth of the settlement, and to ensure the soundness of the Local Plan.
Green Belt
2.32. A Green Belt Study (November 2018) supports the PSLP. This study provides an assessment of Green Belt parcels against the five purposes of the Green Belt, as set ut within the NPPF.
2.33. The study includes an 'assessment of Housing Sites (being considered as part of the SHLAA) within the Green Belt and their relative contribution to the purposes of the Green Belt designation'.
2.34. The site has been assessed against the five purposes of the Green Belt, as part of the Green Belt Study methodology as follows:
Purpose 1: To check the unrestricted sprawl of large built up areas
Parcel 14 is defined by the Council as 'partly contained', and recognises that it abuts a large built up area. This categorisation does however advise that the boundary is 'weak/degraded/unclear'. Site 284 abuts a large built-up area on two out of four boundaries, the remaining boundaries are bounded by established vegetation that could be incorporated and enhanced as part of a landscaping scheme. We consider that the site boundaries are clearly defined and the site is well contained. A conclusion of containment should not consider built form exclusively.
Purpose 2: To prevent neighbouring towns from merging into one another The site is adjacent to the eastern/south-eastern limit of Hutton Mount. The Green Belt Study correctly recognises that its development will retain separation between towns. The site sits at the eastern/south-eastern limit of Hutton mount, the nearest settlement to the east of the site is Billericay which is approximately 3 miles away. The green gap etween the two settlements is considerable. The rest of the settlement at Hutton Mount extends significantly further east than Site 284 in this regard and should be considered very low risk in terms of purpose 2, especially in the context of the other sites that have been assigned the 'Separation Retained' designation.
Purpose 3: To assist in safeguarding the countryside from encroachment Site 284 is defined within the Green Belt Study as being 'Functional Countryside'. The assessment defines Functional Countryside as 'High degree or important public access'. Access is defined as 'access land, public right of ways and important routes'. The site itself, is in private ownership and does not provide access to the public. It is not used for agricultural purposes and therefore should not be considered 'functional countryside'. We therefore consider this assessment to be incorrect.
Purpose 4: To preserve the setting and special character of historic towns Brentwood Borough Council have recognised that site 284 has no physical or visual relationship with the Historic Town. The site is located some distance from the Town Centre with no direct relationship. The site is directly associated with the contemporary developments of the surrounding roads, which have limited historic character.
Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land Brentwood Borough Council have not provided an analysis for Purpose 5.
2.35. Overall, Brentwood Borough Council have assessed the site as having a moderate overall contribution to the Green Belt, despite the favourable assessment of the site.
2.36. We have outlined above that where the site was assessed to have important role in the Green belt, that certain elements of the assessment are incorrect and are not a true reflection of the site's characteristics.
2.37. The development of this Green Belt site, which has limited environmental value and offers a minimal contribution to the Green Belt when assessed against its five intended purposes, would help to support housing delivery in a sustainable location in the Brentwood Borough, whilst protecting other Green Belt sites of much higher environmental value.
2.38. The weaknesses and inconsistencies recognised in the individual site assessments made, again demonstrate a flaw in the evidence base for the Local Plan and could again result in the unjustified omission of Green Belt sites from consideration for allocation as part of the new Local Plan.
2.39. The above analysis of Hanging Hill Lane, Hutton demonstrates that there remains small scale opportunities for sustainable development within the Green Belt and that the Local Plan should give consideration to the allocation of such sites alongside larger scale areas of release.
Strategic Environmental Assessment/Sustainability Appraisal (SEA/SA)
2.40. The PSLP is supported by a range of technical work, including the Sustainability Appraisal (SA) January 2019. The SA presents a number of sustainability issues/objectives which have been established through SA scoping. Together, these sustainability topics and objectives provide a methodological framework for the appraisal of potential allocation sites - including site 284.
2.41. The SA indicates that the allocation of Site 284 would have a positive effect in relation to one of the SA objectives. The SA analysis states that Site 284 is in good proximity to a secondary school (less than 1.5km), but in 'red' proximity from a GP surgery and a primary school. Willowbrook Primary School is located within 1.3 miles of the site, whilst Hogarth Primary School is also 1.5 miles from the site, both considered to be within walking distance from site. The nearest GP Surgery, Mount Avenue Surgery is located less than 1.5 miles away. Mount Avenue is defined in the Regulation 18 document to be 1 of 3 surgeries which has an average of 0.58 GPs per 1,000 patients, which is the national average. Furthermore, Mount Avenue Surgery has a large catchment area, therefore it is considered that it would provide service to those living at the site. Brentwood Community Hospital is also located less than 3 miles away.
2.42. The SA, through its analysis also states that the site at Hanging Hill Lane is an area that 'performs poorly' in respect of its proximity to an Ancient Woodland, SSSI, Local Wildlife Site, Listed Buildings and Agricultural Land. This scoring metric is considered to be highly assumptive and does not consider the potential opportunities for biological enhancement or mitigative measures of impact through landscape led schemes. The proximity of the site near these designations as referenced above, does not necessarily mean that there will be any direct impact to them from the development of the site.
2.43. In relation to Green Belt, the assessment is binary in its approach - if a potential site falls within the defined Green Belt, it will be given an 'Amber score'. The methodology notes that Green Belt is not a specific a landscape designation, as such the effects on the setting have not been appraised. Without appraising the effects on the setting, assigning a blanket 'amber' score to Green Belt sites, seem arbitrary.
2.44. As discussed above, a Green Belt Review of the Borough, and the contribution that each individual site makes to the Green Belt has been undertaken. This recognition that each individual site has differing values should have an influence on the scoring for the Green Belt element within the SA, rather than the binary approach taken.
2.45. In general, we consider that the SA Report is simplistic in its approach to individual site assessment. The SA has used a predominantly spatial or 'GIS' (use of Geographical Information Systems) approach to the assessment of each criteria, using the distance between the site and various factors to judge the extent to which it either achieves or opposes certain objectives. It has had no consideration for the positive contribution that the development of sites can make to the natural environment and local facilities.
2.46. The assumption made within the Sustainability Appraisal that sites will only negatively impact the Green Belt and other landscape and natural environment designations leading to the unjustified omission of sites from allocation, has resulted in the Local Plan being unsound.
3. Site Deliverability
3.1. Site 284 represents a deliverable, sustainable and achievable site for residential development. The below section provides overview of its deliverability and some of the technical reports that have been undertaken which help to demonstrate this.
Access & Connectivity
3.2. The site is considered to have a good access and connectivity to the surrounding area. The vehicular and pedestrian access to the site is proposed to be taken directly from Hanging Hill Lane, as existing.
3.3. The site is approximately 1.5 miles from Shenfield Station (less than a 30 minute walk). Shenfield Station provides frequent services to London Liverpool Street, Chelmsford, Colchester and Ipswich and settlements between. These destinations also provide connections to wider national transport network.
3.4. A public bus stop is located less than 13m from the site. This bus stop provides frequent services to Brentwood High Street, Basildon Town Centre, Billericay and Shenfield Rail Station, amongst other neighbouring settlements and the wider area.
3.5. The site is well-connected to the surrounding road network, and is approximately 2.5 miles from the A12. The A12 provides efficient access to settlements across Essex and East Anglia such as Chelmsford, Colchester and Ipswich, as well as direct connection to the M25.
3.6. Given the high access and connectivity levels of the site, it is evident that land at Hanging Hill Lane is within a sustainable location and should therefore be considered as one of a number of small sites around Hutton that would be suitable for accommodating growth that would be suitable for accommodating growth that would support the recognised housing needs of Brentwood.
Ecology
3.7. A full ecological appraisal of the site would be undertaken prior to any development. It is anticipated however that the development could easily mitigate potential impacts through retention of existing landscape features and replacement planting where appropriate, whilst also presenting an opportunity for enhancement of the ecological value of the site above the existing.
3.8. Any impacts could be easily mitigated and enhanced through a landscaping scheme to support any future development on the site.
Drainage
3.9. The site is adjacent to existing built development and it is anticipated that connections could therefore be made to the existing sewerage networks.
3.10. A sustainable urban strategy would form part of any design for the site to ensure the surface water run-off rates are maintained at the existing greenfield rates.
Contamination
3.11. The perceived history of the use of the site indicated that the site is unlikely to be contaminated.
Highways
3.12. There is an existing access to the site from Hanging Hill Lane which would be maintained and used to access any new development on the site. We understand that this access has good visibility splays and that it is therefore safe for continued use.
3.13. Any development on the site would be supported by a transport statement which consider the suitability of the local highway network to accommodate increased vehicular movements to and from the site.
3.14. It is however considered that sustainably located sites such as sites at Hanging Hill Lane will help provide new homes in locations where there is a minimal reliance on the use of the private car. There are direct footpath links to local convenience shops and schools in Hutton Mount, as well as further into the centre of Hutton. Other local services and facilities, including Shenfield station are also easily accessible by bike.
3.15. There have been no reasons recognised why existing highways and access arrangements should present a risk to the suitability and deliverability of the site.
Heritage
3.16. Grade II Listed Hare Hall is immediately to the south of the site. A Heritage Statement has been prepared by Architectural Management to assess the significance of this asset in respect of the potential residential development of the site, and accompanies this representation.
3.17. The assessment recognises that Hare Hall has been altered significantly over time and that the current building does not carry the level of significance which the original Hare Hall may have done.
3.18. In considering the setting of the listed building, the report also recognises that historically the Hall enjoyed an open outlook to the east and south and that the existing buildings on the site (subject of this rep), and its established vegetation means that the north of the site of has always been more enclosed with a limited outlook.
3.19. The report includes some specific recommendations towards site layout and design that will ensure that the development of this site will have no detrimental impact on the setting of Hare Hall.
4. Summary
4.1. Whilst the current proposed allocations and strategic polices of the PSLP appropriately address the minimum requirement of housing recognised for the Plan period, we query the length of the Plan period, and a lack of flexibility in the housing provision. As such we consider the Plan to be unsound due to its inability to comply with national policy, the unjustified omission of a housing supply which exceeds minimum requirements, and failure to positively prepare for potential changes to markets and housing requirements beyond these forecasts.
4.2. There is clearly a case for Site 284 to be further considered as a sustainable opportunity in respect of Brentwood Borough Council needing to further increase their housing delivery over the plan period. The development of the site would not impact the function of the Green belt in this location as it is immediately adjacent to Hutton, a 'main town' with the facilities and services that could support sustainable growth in Brentwood Borough. Development here would also accord with the Brentwood Borough Council Spatial Strategy which directs growth towards the A12 transport
corridor.
4.3. The accompanying studies evidence the deliverability, achievability and suitability of the site. It is anticipated that any impact on historical sites and settings, landscapes, ecology and ecological designations could be mitigated through appropriate measures. We therefore consider that the site should be allocated by Brentwood Borough Council as a site for residential development. There is an opportunity to identify sustainable sites that are suitable for delivering housing over short term timescales, and to ensure that the Plan is flexible and robust, and well prepared to meeting housing needs over the entirety of the Plan period.
4.4. Development of the site is supported by technical evidence that confirms its suitability, including in relation to the lack of harm the development would have to the purposes of the Green Belt. The reasons given for the rejection of the Site are therefore based on a number of assumptions and simplistic conclusions.
4.5. The exclusion of Site 284 is unjustified, and overlooks an opportunity to correct soundness deficiencies in respect of the Local plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth at Hutton. The allocation of Site 284 for development will assist in resolving these deficiencies in respect of the Local Plan, enabling it to be found sound.

The Plan should be updated so that the housing need is calculated based on the Government's standard methodology for calculating housing need, as well as reflecting the findings of the Housing Delivery Test. This will significantly increase the housing numbers and the number of sites required. Further consultation should then take place on a revised draft Plan, before it is submitted for Examination.

RE Planning Policy Framework 1.24 - 1.25
Planning Policy Framework
Since the Local Plan Regulation 18 consultation, which took place in early 2018, the revised NPPF has been published. This Plan will therefore now be examined against the policies set out in the revised NPPF (February 2019). Paragraph 212 of the NPPF confirms this, stating that:
'Plans may ...need to be revised to reflect policy changes which this replacement Framework has made. This should be progressed as quickly as possible, either through a partial revision or by preparing a new plan.'
We question whether, in light of this fundamental change to the planning policy context, as well as changes to the introduction of the Standard Methodology for calculating housing need and the Housing Delivery Test, which will be discussed below, the Plan should progress to Examination.
In addition, we note that significant elements of the evidence base to the Plan, which were prepared under the 2012 NPPF, have not been updated.
For example, the Site Assessment Methodology and Summary of Outcomes - Working Draft provides the basis on which sites have been assessed as suitable for development and whether they should be allocated in the Plan. This document has not been amended to reflect the publication of the revised NPPF, or the Standard Methodology. The paper still refers to making provision for 'slightly above 380 dwellings per annum'; in fact, this number will need to increase significantly, for reasons set out below.
On this basis, we believe that the Plan is unsound. It is not positively prepared because it does not make provision for the Borough's objectively assessed needs and it is not justified because the evidence base on which it is based is not proportionate.
The Plan should be updated so that the housing need is calculated based on the Government's standard methodology for calculating housing need, as well as reflecting the findings of the Housing Delivery Test. This will significantly increase the housing numbers and the number of sites required. Further consultation should then take place on a revised draft Plan, before it is submitted for Examination.

RE: Policy R01 (i) Garden Village Strategic Allocation
Dunton Hills Garden Village Strategic Allocation: Policy R01 (I)
Land at Dunton Hills (east of the A128, south of the A127 and north of the C2C railway line, approximately 259.2 ha in size) is allocated for residential-led development to deliver Dunton Hills Garden Village (DHGV).
The policy states that development will deliver a mix of uses to comprise around 2,700 homes in the plan period (as part of an overall indicative capacity of around 4,000 homes to be delivered beyond 2033 - subject to further feasibility and assessment of impact). This number has increased from 2,500 homes stated in the Preferred Site Allocations Consultation document of March 2018.
We object to this policy to propose a new settlement to deliver 2,700 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged.
We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF.
It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example Braintree District, Tendring District and Colchester Borough councils in relation to the North Essex Garden Communities.
Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings.
The housing trajectory suggest that DHGV will deliver 750 dwellings by 2026. However, given the recent research, adopting the lag of seven years from a Plan adoption date before the end of 2019 (which we consider highly ambitious) would mean there would be no deliveries on site until after 2026.
Paragraph 9.33 states that of the 6,700 homes, 4,000 are to be delivered after 2033. However, this is caveated by the statement 'subject to further feasibility and assessment of impact', calling into doubt whether 4,000 can in fact be delivered on site.
The Plan places significant reliance on the timely delivery of Dunton Hills Garden Village. This is not a positive strategy for meeting housing need and does not provide the flexibility required to address changes in circumstances. The allocation should be complemented by the allocation of small sites, to improve deliverability.
We wish to participate in the Examination to set out the case that additional smaller sites should be allocated, to ensure the Plan's deliverability and to ensure a constant delivery of new homes.

RE Policy SP02 - Managing Growth
Housing Delivery
The Plan proposes that as 'the high proportion of designated Green Belt within the Borough makes it extremely difficult to achieve a five year supply' (Paragraph 4.19), a greater proportion of the required homes are forecast to be delivered in the period beyond 2023. Policy SP02 therefore sets out a stepped trajectory of delivery of 310 homes per annum to 2023, followed by a higher target of 584 per year to 2033.
We do not believe that Policy SP02 is sound because it does not provide an appropriate strategy to comply with the requirements of the NPPF, which states in paragraph 23 that:
'Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development.'
The strategy does not result in the delivery of housing throughout the Plan period. Paragraph 73 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the Plan period. Appendix 1 of the Plan sets out this housing trajectory, which demonstrates that no units will be delivered in 2019/2020 from the site allocations, and only 66 units are proposed to be delivered in 2020/2021, with 318 in 2021/2022 and 632 in 2023/2024.
We question whether this is an appropriate strategy, and believe that on this basis, Policy SP02 is unsound because it is not justified.
To set out the case that the Plan should allocate additional, smaller sites, to enable the Plan to deliver homes throughout the Plan period.

RE Local Housing Need - Paragraphs 4.11 - 4.21
Housing Need
In October 2018, the Government consulted on technical changes to its proposed Standard Methodology to calculate housing need based not on the 2016 household projections published by the Office for National Statistics, but on the 2014 household projections published by the Department for Communities and Local Government (DCLG). These revised projections result in a housing figure for the Borough of 456 dwellings per annum.
In February 2019, the Government published a summary of the responses to its October 2018 technical consultation and its view on the way forward, in which it confirmed that its proposed approach provided the most appropriate approach 'for providing stability and certainty to the planning system in the short term' and that Local Planning Authorities should not use the 2016 household projections, which resulted in lower housing numbers, as a reason to justify lower housing need.
The Plan states that the Borough's annual housing requirement is still 380 homes per annum, based on the findings of the Strategic Housing Market Assessment (2016). However, paragraph 4.16 of the Plan sets out the intention to make provision for an additional housing supply buffer, which provides a 20% uplift to the annual housing figure of 380 units, resulting in provision of 456 dwellings per annum, resulting in a requirement for 7,752 dwellings from 2016 - 2033. This is the same figure as required by the Government's Standard Methodology for Calculating Housing Need.
However, Brentwood Borough Council was recently identified in the publication of the Government's Housing Delivery Test as an authority which has delivered less than 85% of its housing requirement, and therefore has to add a 20% buffer to its housing land supply figure.
We therefore object to the housing requirement set out in the Plan on the basis that it is insufficient to meet the Borough's needs. Paragraph 59 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The Plan does not do this; it only makes provision for the OAN and does not provide for the additional 20% buffer, as required under the Housing Delivery Test.
It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.
The Plan should be updated to make provision for the Borough's objectively assessed need, to take account of the figure in the Government's Standard Methodology for Calculating Housing Need, with an additional 20% buffer to reflect the Housing Delivery Test.
If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary. To set out why the Plan is not making adequate provision for new housing.

RE Figure 2.3 - Settlement Hierarchy
Settlement hierarchy
To promote sustainable growth in rural areas, the NPPF (2019) paragraph 78 states that housing in rural areas should be located where it will enhance the vitality of rural communities, to ensure villages grow and thrive. To ensure the Local Plan responds to this, a broad Settlement Hierarchy Assessment has been undertaken to understand the role, function and relationship of Brentwood's dispersed settlements.
The Plan sets out the settlement hierarchy in the Borough. Ingrave is classed as a Category 3 settlement. Whilst we support the classification of Ingrave as a "Category 3 - Large Village", we object to the inconsistent treatment of this settlement in comparison to other settlements occupying the same level in the hierarchy.
For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave.
The moratorium of growth in these villages is contrary to the NPPF, which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. The NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 78).
As drafted, the Plan is not sound. It identifies Ingrave as a Category 3 settlement but does not allocate housing in or near the settlement. This is not an appropriate strategy and therefore the Plan is not justified in this respect.
Additional land for housing should be allocated at Ingrave to meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.
Paragraph 2.16 of the Plan notes that, in relation to Category 3 settlements;
'Brownfield redevelopment opportunities will be encouraged to meet local needs, and policies in this Plan will help to bring forward nearby redevelopment of brownfield sites in the Green Belt where appropriate.'
This emphasis on bringing forward brownfield sites 'nearby' Category 3 settlements is supported. This approach would provide a more flexible approach and would enable sites such as our client's site to come forward.
We wish to participate in the Examination to set out the case that additional sites should be allocated in and near to Ingrave, a sustainable, Category 3 settlement.

RE: Site Assessment Methodology and Summary of Outcomes - Working Draft (2018)
The spatial strategy, as set out at paragraph 3.13, focuses upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with paragraph 137 of the NPPF, which requires that:
'Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.'
However, we do not consider that the capacity of brownfield sites has been fully explored. The Stage 2 assessment process discounts sites where they are considered to be in an unsustainable location, (which included sites in the Green Belt with no connecting boundary to an existing urban area,) before considering the potential to use brownfield land. This has resulted in sites such as site 183, our client's site, being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable.
Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. Residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail.
Paragraph 103 of the NPPF acknowledges that:
"opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision taking.'
Paragraph 102 also states that:
'Transport issues should be considered from the earliest stages of plan-making and development proposals, so that c) opportunities to promote walking, cycling and public transport use are identified and pursued.'
Figure 4.2 of the Plan sets out how different types of land use will contribute to how the overall housing need will be met. The Plan's spatial strategy is unsound because it excluded all sites which do not meet the distance thresholds from existing settlements, and has not fully taken into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
In light of the higher housing numbers required, the Plan should be revised to re-assess all sites which do not meet the distance thresholds from existing settlements, and to take into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
We wish to participate in the Examination to set out the case that a further assessment of sites is required, and the opportunity should be taken to re-assess sites which were previously excluded.


RE Spatial Strategy
The draft Plan relies on the delivery of strategic sites, to meet a significant proportion of its housing requirement. Figure 4.2 of the Plan identifies that the Dunton Hills Garden Village strategic allocation will provide 35% of the total housing requirement. We note that in the Regulation 18 document, three strategic sites were proposed; this has now increased to five.
We object to the strategy relying on several large developments to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. As set out in Appendix 1, this strategy results in the delivery of no new housing in the early years of the Plan.
Paragraph 68 of the NPPF notes that:
'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare.'

The Plan should be reviewed and sites identified to meet the higher housing number of 547 dwellings per annum, through the addition of smaller site allocations. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have fewer complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver.
Allocating additional smaller sites will have multiple benefits; it will increase the flexibility of the Plan, it will contribute to the five year housing land supply, it will enable sites which do not require significant infrastructure provision to come forward quickly, and it will attract smaller house building companies who will not be present upon larger strategic sites.
To set out the case that the Plan should allocate additional, smaller sites, to improve the flexibility of the Plan, to ensure that the Plan complies with the NPPF, and to enable the Plan to deliver homes throughout the Plan period.

In light of the higher housing numbers required, the Plan should be revised to re-assess all sites which do not meet the distance thresholds from existing settlements, and to take into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.

RE Planning Policy Framework 1.24 - 1.25
Planning Policy Framework
Since the Local Plan Regulation 18 consultation, which took place in early 2018, the revised NPPF has been published. This Plan will therefore now be examined against the policies set out in the revised NPPF (February 2019). Paragraph 212 of the NPPF confirms this, stating that:
'Plans may ...need to be revised to reflect policy changes which this replacement Framework has made. This should be progressed as quickly as possible, either through a partial revision or by preparing a new plan.'
We question whether, in light of this fundamental change to the planning policy context, as well as changes to the introduction of the Standard Methodology for calculating housing need and the Housing Delivery Test, which will be discussed below, the Plan should progress to Examination.
In addition, we note that significant elements of the evidence base to the Plan, which were prepared under the 2012 NPPF, have not been updated.
For example, the Site Assessment Methodology and Summary of Outcomes - Working Draft provides the basis on which sites have been assessed as suitable for development and whether they should be allocated in the Plan. This document has not been amended to reflect the publication of the revised NPPF, or the Standard Methodology. The paper still refers to making provision for 'slightly above 380 dwellings per annum'; in fact, this number will need to increase significantly, for reasons set out below.
On this basis, we believe that the Plan is unsound. It is not positively prepared because it does not make provision for the Borough's objectively assessed needs and it is not justified because the evidence base on which it is based is not proportionate.
The Plan should be updated so that the housing need is calculated based on the Government's standard methodology for calculating housing need, as well as reflecting the findings of the Housing Delivery Test. This will significantly increase the housing numbers and the number of sites required. Further consultation should then take place on a revised draft Plan, before it is submitted for Examination.

RE: Policy R01 (i) Garden Village Strategic Allocation
Dunton Hills Garden Village Strategic Allocation: Policy R01 (I)
Land at Dunton Hills (east of the A128, south of the A127 and north of the C2C railway line, approximately 259.2 ha in size) is allocated for residential-led development to deliver Dunton Hills Garden Village (DHGV).
The policy states that development will deliver a mix of uses to comprise around 2,700 homes in the plan period (as part of an overall indicative capacity of around 4,000 homes to be delivered beyond 2033 - subject to further feasibility and assessment of impact). This number has increased from 2,500 homes stated in the Preferred Site Allocations Consultation document of March 2018.
We object to this policy to propose a new settlement to deliver 2,700 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged.
We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF.
It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example Braintree District, Tendring District and Colchester Borough councils in relation to the North Essex Garden Communities.
Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings.
The housing trajectory suggest that DHGV will deliver 750 dwellings by 2026. However, given the recent research, adopting the lag of seven years from a Plan adoption date before the end of 2019 (which we consider highly ambitious) would mean there would be no deliveries on site until after 2026.
Paragraph 9.33 states that of the 6,700 homes, 4,000 are to be delivered after 2033. However, this is caveated by the statement 'subject to further feasibility and assessment of impact', calling into doubt whether 4,000 can in fact be delivered on site.
The Plan places significant reliance on the timely delivery of Dunton Hills Garden Village. This is not a positive strategy for meeting housing need and does not provide the flexibility required to address changes in circumstances. The allocation should be complemented by the allocation of small sites, to improve deliverability.
We wish to participate in the Examination to set out the case that additional smaller sites should be allocated, to ensure the Plan's deliverability and to ensure a constant delivery of new homes.

RE Policy SP02 - Managing Growth
Housing Delivery
The Plan proposes that as 'the high proportion of designated Green Belt within the Borough makes it extremely difficult to achieve a five year supply' (Paragraph 4.19), a greater proportion of the required homes are forecast to be delivered in the period beyond 2023. Policy SP02 therefore sets out a stepped trajectory of delivery of 310 homes per annum to 2023, followed by a higher target of 584 per year to 2033.
We do not believe that Policy SP02 is sound because it does not provide an appropriate strategy to comply with the requirements of the NPPF, which states in paragraph 23 that:
'Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development.'
The strategy does not result in the delivery of housing throughout the Plan period. Paragraph 73 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the Plan period. Appendix 1 of the Plan sets out this housing trajectory, which demonstrates that no units will be delivered in 2019/2020 from the site allocations, and only 66 units are proposed to be delivered in 2020/2021, with 318 in 2021/2022 and 632 in 2023/2024.
We question whether this is an appropriate strategy, and believe that on this basis, Policy SP02 is unsound because it is not justified.
To set out the case that the Plan should allocate additional, smaller sites, to enable the Plan to deliver homes throughout the Plan period.

RE Local Housing Need - Paragraphs 4.11 - 4.21
Housing Need
In October 2018, the Government consulted on technical changes to its proposed Standard Methodology to calculate housing need based not on the 2016 household projections published by the Office for National Statistics, but on the 2014 household projections published by the Department for Communities and Local Government (DCLG). These revised projections result in a housing figure for the Borough of 456 dwellings per annum.
In February 2019, the Government published a summary of the responses to its October 2018 technical consultation and its view on the way forward, in which it confirmed that its proposed approach provided the most appropriate approach 'for providing stability and certainty to the planning system in the short term' and that Local Planning Authorities should not use the 2016 household projections, which resulted in lower housing numbers, as a reason to justify lower housing need.
The Plan states that the Borough's annual housing requirement is still 380 homes per annum, based on the findings of the Strategic Housing Market Assessment (2016). However, paragraph 4.16 of the Plan sets out the intention to make provision for an additional housing supply buffer, which provides a 20% uplift to the annual housing figure of 380 units, resulting in provision of 456 dwellings per annum, resulting in a requirement for 7,752 dwellings from 2016 - 2033. This is the same figure as required by the Government's Standard Methodology for Calculating Housing Need.
However, Brentwood Borough Council was recently identified in the publication of the Government's Housing Delivery Test as an authority which has delivered less than 85% of its housing requirement, and therefore has to add a 20% buffer to its housing land supply figure.
We therefore object to the housing requirement set out in the Plan on the basis that it is insufficient to meet the Borough's needs. Paragraph 59 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The Plan does not do this; it only makes provision for the OAN and does not provide for the additional 20% buffer, as required under the Housing Delivery Test.
It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.
The Plan should be updated to make provision for the Borough's objectively assessed need, to take account of the figure in the Government's Standard Methodology for Calculating Housing Need, with an additional 20% buffer to reflect the Housing Delivery Test.
If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary. To set out why the Plan is not making adequate provision for new housing.

RE Figure 2.3 - Settlement Hierarchy
Settlement hierarchy
To promote sustainable growth in rural areas, the NPPF (2019) paragraph 78 states that housing in rural areas should be located where it will enhance the vitality of rural communities, to ensure villages grow and thrive. To ensure the Local Plan responds to this, a broad Settlement Hierarchy Assessment has been undertaken to understand the role, function and relationship of Brentwood's dispersed settlements.
The Plan sets out the settlement hierarchy in the Borough. Ingrave is classed as a Category 3 settlement. Whilst we support the classification of Ingrave as a "Category 3 - Large Village", we object to the inconsistent treatment of this settlement in comparison to other settlements occupying the same level in the hierarchy.
For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave.
The moratorium of growth in these villages is contrary to the NPPF, which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. The NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 78).
As drafted, the Plan is not sound. It identifies Ingrave as a Category 3 settlement but does not allocate housing in or near the settlement. This is not an appropriate strategy and therefore the Plan is not justified in this respect.
Additional land for housing should be allocated at Ingrave to meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.
Paragraph 2.16 of the Plan notes that, in relation to Category 3 settlements;
'Brownfield redevelopment opportunities will be encouraged to meet local needs, and policies in this Plan will help to bring forward nearby redevelopment of brownfield sites in the Green Belt where appropriate.'
This emphasis on bringing forward brownfield sites 'nearby' Category 3 settlements is supported. This approach would provide a more flexible approach and would enable sites such as our client's site to come forward.
We wish to participate in the Examination to set out the case that additional sites should be allocated in and near to Ingrave, a sustainable, Category 3 settlement.

RE: Site Assessment Methodology and Summary of Outcomes - Working Draft (2018)
The spatial strategy, as set out at paragraph 3.13, focuses upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with paragraph 137 of the NPPF, which requires that:
'Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.'
However, we do not consider that the capacity of brownfield sites has been fully explored. The Stage 2 assessment process discounts sites where they are considered to be in an unsustainable location, (which included sites in the Green Belt with no connecting boundary to an existing urban area,) before considering the potential to use brownfield land. This has resulted in sites such as site 183, our client's site, being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable.
Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. Residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail.
Paragraph 103 of the NPPF acknowledges that:
"opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision taking.'
Paragraph 102 also states that:
'Transport issues should be considered from the earliest stages of plan-making and development proposals, so that c) opportunities to promote walking, cycling and public transport use are identified and pursued.'
Figure 4.2 of the Plan sets out how different types of land use will contribute to how the overall housing need will be met. The Plan's spatial strategy is unsound because it excluded all sites which do not meet the distance thresholds from existing settlements, and has not fully taken into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
In light of the higher housing numbers required, the Plan should be revised to re-assess all sites which do not meet the distance thresholds from existing settlements, and to take into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
We wish to participate in the Examination to set out the case that a further assessment of sites is required, and the opportunity should be taken to re-assess sites which were previously excluded.


RE Spatial Strategy
The draft Plan relies on the delivery of strategic sites, to meet a significant proportion of its housing requirement. Figure 4.2 of the Plan identifies that the Dunton Hills Garden Village strategic allocation will provide 35% of the total housing requirement. We note that in the Regulation 18 document, three strategic sites were proposed; this has now increased to five.
We object to the strategy relying on several large developments to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. As set out in Appendix 1, this strategy results in the delivery of no new housing in the early years of the Plan.
Paragraph 68 of the NPPF notes that:
'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare.'

The Plan should be reviewed and sites identified to meet the higher housing number of 547 dwellings per annum, through the addition of smaller site allocations. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have fewer complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver.
Allocating additional smaller sites will have multiple benefits; it will increase the flexibility of the Plan, it will contribute to the five year housing land supply, it will enable sites which do not require significant infrastructure provision to come forward quickly, and it will attract smaller house building companies who will not be present upon larger strategic sites.
To set out the case that the Plan should allocate additional, smaller sites, to improve the flexibility of the Plan, to ensure that the Plan complies with the NPPF, and to enable the Plan to deliver homes throughout the Plan period.

Remove DHGV from plan

Dear Sir/Madam,

Brentwood Councils Local Plan
& re Dunton Hills Garden Village

I object to DUNTON HILLS GARDEN VILLAGE (DHGV) for the following reasons: -
BRENTWOOD RESIDENTS WANT DEVELOPMENT IN NORTH OF THE BOROUGH, North Brentwood, Pilgrims Hatch and Greenfield sites North of A12 to keep families together and to provide Affordable/Social Housing.
Easy to build and have major new roads e.g. to M25 and others upgraded etc.
These areas have superb Infrastructure, Air Quality and other major benefits.

PLEASE NOTE:
The council state nothing is your problem to confirm is safe & risk free.
You will not be providing any funding for anything.
Infrastructure is always someone else's problem: NHS; Essex County Council, Bus Companies, C2C's etc.
ALSO THE COUNCILS LACK OF PROFESSIONALISM IS CERTAINLY OUTSTANDING, as no-one can trust your facts without checking.
For better information and accurate facts, rather than Brentwood Councils waffle VISIT WWW.DUNTONEXPLOITATION.CO.UK
1. THE COSTS TO ENSURE NO PROBLEMS AT DHGV alone means site UNVIABLE BUT THEN Brentwood's Political Bias & Greed takes over (see point 4).
2. Brentwood describe Dunton as: -
(A) Considered Outside of Brentwood's District
&
(B) IMPORTANTLY describe it as Fenland (Meaning low marshy area & together with their reports likely to Flood/Have Surface Water besides Soil & Water Contamination besides the Major Gas Pipe-Line but state is not Brentwood Councils problem ).
Is actually the worst site considered (which is a critical drainage area) confirming is unsuitable for development but considers is the most profitable and keeps residents out of Brentwood's main area.
3. (NEW TOWN) Currently reported 4,000 New Homes, in their January 2018 Local Plan (as advised intend to bring forward further proposed development and then increased further as understand site could double in size as far more land available to them).
4. DHGV is quoted as a self-sufficient site; however, Brentwood's Director of Strategic Planning has stated will rely on Basildon's Infrastructure.
Thereby, all income profits go to Brentwood Council and year on year maintenance costs and problems fall on Basildon Council and its Residents.
For Brentwood Council is a WIN - WIN situation: will receive over £36,000,000 from government and vast council tax with little outlay.
5. Brentwood Council is aware their Local Plan (at least in part) especially regarding DHGV is unsound.
6. Brentwood Council NOW ADVISE after over 4 years is producing an Infrastructure Delivery Plan (IDP) which will provide an overview of the infrastructure requirements associated with the Local Plan and how Brentwood intend to support the development.
However unable to supply any information to back the IDP comment!
Again proves that the Planning Department officers lied when supplying information and why unable to answer simple basic questions.
7. It appears the council deliberately want to proceed even though the facts quoted cannot be factually backed up as currently appear flawed and rigged.
8. Appears council and the Council Leader, Louise Mckinley are trying their utmost to push through DHGV, without proper scrutiny, as concerned would not be passed by Planning Inspectorate if actual facts known.
From their actions appears they do not want General Public or Residents to obtain information.
9. Brentwood Council including Planning and Louise McKinley, council leader, unable to answer relevant questions with factual information, only waffle.
10. Brentwood Council admit unable to supply Masterplan or what Infrastructure will actually be provided (and have lied about for over 4 years) as is currently only their thinking, ifs/maybes and may never be built.
11. Brentwood Council and the council leader are deliberately not responding to outstanding questions or emails (some nearly 2 months, well overdue) as appear extremely concerned that then could easily prove Reports have been Fabricated/Manipulated to misrepresent the best areas for development and in fact where the best areas are.
12. E.g. Brentwood Council dismissed building 2,300 New Homes at Pilgrims Hatch for reasons given, however, the same and worse applies to Dunton.
13. All consultations on Brentwood Councils Local Plan, have been bought into disrepute as no-one knows the real details/facts on the various proposed sites as Brentwood Council 'Keep On Moving The Goalposts', SO HOW CAN ANYONE ACCURATELY COMMENT!
What are the facts and which are fiction!
14. In the submission for the £528,000 grant, listed 10 Key Milestones to be completed by October 2018, yet the council have admitted have not carry out any, so how can Brentwood Council be trusted.
15. FACTUAL INFORMATION HAS BEEN RIGGED/AMENDED, GIVEN A DIFFERENT SLANT/REPRESENTATION by Brentwood Council.
16. There are more points but this is enough for now, without listing them all.
BRENTWOOD COUNCIL ARE LIKE THE PROVERB, 'A ROLLING STONE GATHERS NO MOSS', thereby they change details/comments at whim to whatever suits their purpose.

VISIT WWW.DUNTONEXPLOITATION.CO.UK FOR MORE ACCURATE INFORMATION
Brentwood Councils Local Plan, January 2018, shows 4,000 New Homes and advised wish built in current planning period.
(16,000 people and 8,000 vehicles besides over 30+ Travellers/Gypsy pitches).
BUT UNDERSTAND MAY WELL DOUBLE SIZE IN FUTURE!

Intend to build well over 50% of their New Homes target (appears nearly 65%), SOUTH of the A127 which they consider OUTSIDE of Brentwood Districts AREA.
It is obvious that Brentwood intends to build a New Town rather than a Village and will use every means at their disposal to build DHGV even though the Local Development Plans details after scrutiny do not stack up.
Have requested information NOW so have time to check the facts and stop this unethical development in its tracks, unless the council can supply accurate documentation which stands up to scrutiny!
Please acknowledge receipt.
I look forward to hearing from you.
Yours sincerely

Jeffrey Goodwin

We recommend the land to the south of Lodge Close, Hutton is assessed within the Council's Part 3 Green Belt assessment as a suitable, deliverable and available site. As an overarching point, we are concerned with the simplistic approach that appears to have been taken in considering the contribution sites make to the purposes of the Green Belt. We would therefore recommend that the Council provide a far more detailed and robust review of sites' contribution to the purposes of the Green Belt as part of the plan-making process. As part of any residential allocation, we would look to undertake further technical evidence to support the site's release from the Green Belt.

These representations on the Brentwood Borough Proposed Submission Local Plan (February 2019) (PSLP) are submitted by Strutt and Parker on behalf of Chelmsford Diocesan Board of Finance (CDBF) and in relation to land to the south of Lodge Close, Hutton. Land to the south of Lodge Close, Hutton ('the Site') has previously been promoted as part of the Council's plan-making process, site reference 033. The site has been actively promoted by CDBF throughout the plan-making process. Previous representations have been made at various stages of the Local Plan, including in relation to call for sites exercises and consultations on iterations of the Local Plan. CDBF as the freehold owner of the site are actively promoting the Site for residential allocation in the Council's new Local Plan. A location plan for the site is provided as Appendix A. The proposed period runs until 2033. Assuming - optimistically - adoption in 2019 this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years. This deficiency in the PSLP is of particular relevance given that the Borough is predominantly Green Belt, and failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt: its permanence (NPPF, paragraph 133). Commentary on the Total Housing Requirement: At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12, it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying Planning Practice Guidance [PPG). However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years). A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional year's worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest the PSLP that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Five-year housing land supply and housing trajectory: The Council is required to demonstrate a five-year housing land supply at any point in the plan period2. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply; 2 Paragraph: 038 Reference ID: 3-038-20180913; 3 Paragraph: 037 Reference ID: 3-037-20180913; did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings). Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this before development has even begun. As such, it is totally unrealistic to project that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound. Proposed Approach to Hutton: Hutton is the second largest settlement in the Borough. In 2011, the town had a population of 15,578 and a total of 6,564 dwellings (Census 2011). It is a large, established community and a local centre which benefits from a range of services, facilities, access to public transport, and employment opportunities. Hutton is situated approximately 30 kilometres from Central London, 12 kilometres from Chelmsford and in a position well related to regional and national infrastructure. Hutton lies in close proximity to Brentwood and Shenfield on the A12 corridor. Hutton has strong service and education provision. The settlement benefits from excellent access to Shenfield High Street on the Hutton Road which adjoins Rayleigh Road and runs centrally through the settlement on an east-west axis. The High Street provides a variety of services, shops and businesses. The PSLP sets out the Borough's settlement hierarchy. Hutton is identified as Category 1 - Main Town. It is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. In addition, as an established community, it is important that the Local Plan manages the growth of the settlement to ensure the vitality of the community is sustained or enhanced. However, notwithstanding the above, the PSLP proposes to direct no housing growth to Hutton. This contrasts sharply with the proposed approach to the other settlements identified as Category 1 - Main Towns. It is also notable that a considerable amount of growth is being directed to settlements below Hutton within the settlement hierarchy. The PSLP fails to support the sustainable growth of Hutton. The proposal to direct none of the Borough's housing need to Hutton is unjustified, and inconsistent with national policy. To ensure the Local Plan is sound, paragraph 2.10 and the associated Table should be amended to ensure that Hutton delivers a scale of growth appropriate to its position within the hierarchy as a Category 1 Settlement. At present, Hutton will deliver fewer homes than any of the Category 2 Settlements. The site, as shown on the plan provided in Appendix A measures approximately 1.3 hectare. The Council have defined the net developable area of the site at 1.18 hectare, with an indicative yield of 35 dwellings. The site principally comprises open pastoral grassland of low landscape value. The site is roughly rectangular in shape, is well contained by thick trees and hedgerow and is constrained by development to the north and west, and Hutton Village to the east and south. The site is on land currently allocated as Green Belt in the Bentwood Replacement Local Plan (2005), but is situated immediately adjacent to the settlement boundary of Hutton. Within previous submissions to the Council, we have set out the sustainability of land south of Lodge Close, Hutton for residential development, and an overview of these is provided again here, as follows. There are three dimensions to sustainable development: economic; social and environmental. In terms of economic impact, there is an inherent link between providing homes and the creation of jobs. Benefits of the site's development include additional local expenditure in and around Hutton from the additional residents. The intention for the land south of Lodge Close, Hutton is to provide homes for people working in and around the Hutton area, assisting in local economic development. Development of the site will reduce pressure to accommodate development on potentially more environmentally sensitive sites. In respect of social impacts, the land south of Lodge Close, Hutton is very well connected to local service provision with the majority of Hutton and Shenfield's services within a 2km radius of the site. In addition, the site benefits from excellent public transport links. The provision of homes to meet housing needs will have very significant social sustainability benefits. Notably, the Council's evidence base supports the view that the site is suitable and achievable for development, as confirmed through the assessment of the Site within the Brentwood Borough Council Housing and Economic Land Availability Assessment (October 2018) (HEELA). We would however disagree with the assessment of the Site's availability as a reason for the Site being discounted. The findings suggest that the Site is 'unavailable' due to a lack of active promotion from the landowner; the site has been promoted through previous consultations of the Local Plan review process at Call for Sites and Preferred Options. The site is therefore available for development. The proposals map should be modified to remove Site 033 from the Green Belt and identified for the delivery of residential development. Strategic Environment Assessment / Sustainability Appraisal (SEA/SA). The Environment Assessment of Plans and Programmes Regulations (2004) requires SA/SEA to inter alia set out the reasons of preferred alternatives, and the rejection of others, be made set out. In addition, the Planning Practice Guidance4 makes clear that the strategic environmental assessment should outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. Sustainability appraisal of the PSLP has been published: The Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA). Site 033 has been wholly discounted, failing to progress to 'shortlisted omission sites' nor the final shortlist. The SA explains that a number of sites were identified through the HELAA that were considered developable or deliverable, but are nevertheless not proposed to be allocated in the PSLP. The SA does not provide a justified reason for the rejection of the site. Paragraph: 038 Reference ID: 11-038-20150209. We seek modifications to refine the Site Appraisal Criteria contained in the SA of the Brentwood Local Plan, prepared by AECOM. The decision process for utilising the RAG scoring is unclear in regards to the weighting given to the overall scores, and how this results in a site being considered suitable for allocation or unsuitable. The criteria set out in Appendix B Table 3 must adopt a more refined approach to its scoring in order to be of use in the identification of which sites and more or less sustainable. Criteria 7, 8, 9 should take account of the capacity of existing facilities and the scale of a proposed site, as this will affect the ability to provide additional facilities, or to support existing facilities. Criteria 10, 12, 13, 15 each assume that closer proximity of a site will have a negative effect on the criteria, when this is not necessarily the case. Criteria 17 should not be included in the SA as the notes for this criteria (p.96) confirm the Agricultural Land Classification Maps are of a poor resolution. It is recommended that a more refined scoring system is required to improve the utility of the SA to the identification of sustainable sites. A more refined scoring system would more accurately reflect the sustainability of any potential allocation. Further, greater transparency is required in relation to how the individual RAG scores have been used to reach a decision to allocate or omit sites. Green Belt: A Part 3 Green Belt Appraisal (dated 31st January 2019) has been published by the Council. This considered specific sites, albeit in limited detail. Site 033 has been discounted, with the assessment explaining: 'based on the progressive findings of the HELAA and wider evidence base, a selective approach to the assessment of additional has been undertaken. Overall, Sites (located within the Green Belt) which have been discounted for other environmental or strategic reasons (i.e. too small to form a strategic allocation), were not considered for further assessment.' Whilst the assessment has justified Site 033 (and other sites) being omitted from the assessment, the study assesses the significance of each site's contribution to four of the five purposes of the Green Belt, with an understanding the fifth purpose is implemented as an integral part of the Brentwood Local Plan. As such, previous findings contained in the HEELA and environmental / strategic constraints, unless explicitly relating to the four purposes of the Green Belt, should not be used for justifying site omission. With regards to Site 033, this is especially pertinent when considering the ambiguity of weight given to various SA scores (i.e. distance to GP and interaction with the Conservation Area) and the inaccuracy of availability in the HEELA (2018). Even were it appropriate to use such criteria to discount sites from a Green Belt assessment, the criteria itself in the case of the above has proven inaccurate, overly simplistic and therefore unreliable. As such we recommend the site is assessed within the Council's Part 3 Green Belt assessment as a suitable, deliverable and available site. As an overarching point, we are concerned with the simplistic approach that appears to have been taken in considering the contribution sites make to the purposes of the Green Belt. We would therefore recommend that the Council provide a far more detailed and robust review of sites' contribution to the purposes of the Green Belt as part of the plan-making process. As part of any residential allocation, we would look to undertake further technical evidence to support the site's release from the Green Belt. Conclusion: The site is considered, suitable, available, achievable for development in accordance with the PSLP's aspirations for sustainable growth. The reasons given for the rejection of the site are spurious and based on erroneous conclusions. The rejection of site 033 is unjustified, and overlooks an opportunity to correct other soundness deficiencies of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton. The allocation of Site 033 for development will assist in curing defects of the Local Plan, enabling it to be a sound plan.