brentwood.gov.uk

The Plan needs to consider safeguarding land in order to meet longer term development needs.

Hallam Land Management have made representations elsewhere as to the failure of the Plan to show a sufficient supply and mix of sites to meet the minimum number of homes required, or to address the issue of unmet needs.

In this context, the Draft Plan should be providing more land for housing and thereby releasing more land from its Green Belt in order to promote sustainable patterns of development as required by Paragraph 138 of the Framework.

It is noted from paragraph 8.84 of the Draft Plan that the Council propose to only release 1% of land from the Green Belt within the Borough. This release will not result in any discernible difference to the character and appearance of the Borough, and is indicative of the fact that the Draft Plan has not thoroughly examined the contribution it should be making towards housing needs within the wider region through the release of Green Belt land. Moreover, the Draft Plan has not therefore considered the implications of its approach for sustainable development and settlements within and beyond the Green Belt in accordance with Paragraph 138 of the Framework.

Whilst the Council has reviewed its Green Belt as part of the process of preparing its Local Plan, the Assessment appears to have been overly influenced by the draft housing requirement set within the Draft Plan, and therefore over-estimated certain sites' contributions to the five purposes of the Green Belt in order to arrive at the proposed allocations and the draft housing requirement.

It is Hallam Land Management's strong view that there is a site that warrants release from the Green Belt as its development would contribute towards sustainable development and meeting housing needs where they arise, without undermining the integrity of the Green Belt within the Borough. This site is referred to as Calcott Hall Farm, Brentwood and representations are made elsewhere which support its proposed allocation.

Safeguarded Land

Notwithstanding the need to consider whether further land should be released from the Green Belt, national planning policy requires Local Plans to be able to demonstrate that Green Belt boundaries beyond the plan period will not need to be altered (NPPF para. 139).
In the context of a Local Plan area covered predominantly by Green Belt designation, with limited windfall opportunities and the Council's recognition that additional growth is inevitable beyond 2033, the Local Plan should ensure that additional land is removed from the Green Belt and safeguarded to meet longer term development needs.
This will ensure that the Local Plan provides for new defensible boundaries for future generations in accordance with Policy NE13, criterion B.
Other recently adopted Local Plans with similar levels of Green Belt coverage and future growth pressures have amended Green Belt boundaries to identify safeguarded land, for instance see South Staffordshire Site Allocations Document or Warwick District Local Plan.