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The Sustainability Appraisal must be reviewed and updated in light of changes that need to be made to the Draft Local Plan, and in light of new evidence presented to the Council as to the positive effects of development of Calcott Hall Farm, Brentwood.

These representations contain both general and specific concerns in relation to the Sustainability Appraisal, January 2019.

Sustainability Appraisal Process

The Sustainability Appraisal (SA) is an iterative process to help inform the stages of plan making and the key choices the plan must take in light of the findings. In this particular case, the SA has not informed plan making decisions but has responded to them. This is clearly evident from the narrative within the original SA prepared in October 2018 which appraised a different Draft Local Plan to that which is currently subject to consultation. Whilst the SA has been updated to reflect decisions taken regarding the Local Plan at the Extraordinary Council meeting in November 2018, the decision was not made in light of the SA of January 2019.

Establishing Reasonable Alternatives

As noted in representations submitted by Hallam Land Management Limited (HLM) in relation to Housing Need and Requirement, the minimum local housing need (LHN) is 452 dwellings per annum (dpa), based on the standard method, and taking into account 2014 Household Projections.

The SA has only assessed alternative strategic options for the distribution of growth that as a minimum meets the LHN within the Draft Local Plan (350 dpa). Other strategic options should now therefore be appraised which appraise higher levels of growth to reflect the higher level of LHN that now needs to be planned for.

Unmet needs from Neighbouring Authorities

As noted in representations submitted by HLM in relation to the Duty to Cooperate, the identified unmet needs of neighbouring areas have not been taken into account in establishing a housing requirement for Brentwood. The SA also recognises that there are unmet needs (box 5.2 and table 5.1), and notes that higher levels of housing growth would go some way to addressing these needs. Although the SA notes that there would be further environmental consequences of addressing unmet need from elsewhere, this would be inevitable given it is a higher level of growth requiring further land. However, this does not mean that a higher level of growth could be deemed unsustainable.
Additional Strategic Growth at Brentwood

Indeed, the SA concludes:

"A headline conclusion is that a strategy involving one or more strategic allocations within the A127 corridor performs well, relative to the alternative of supporting higher growth at Brentwood, in respect of a number of objectives. It does not automatically follow that a strategy involving higher growth at the Brentwood is relatively unsustainable overall; however, it is an indication. The appraisal has highlighted limited benefits to supporting higher growth at Brentwood, and some significant draw-backs, most notably in respect of 'air quality' and 'biodiversity', with significant negative effects predicted in both respects. However, the appraisal findings do reflect the merits of the particular package of sites assumed to deliver higher growth. There will be alternative packages of sites that perform better in certain respects."

As an example of a site that can perform better in certain respects, it will be noted from representations made in respect of the Site Allocations that Land at Calcott Hall Farm, Brentwood could have a positive effect on air quality and biodiversity as a consequence of the proposals for a Community Link Road and measures to enhance biodiversity and green infrastructure on site. Higher growth at Brentwood would not therefore automatically be appraised as unsustainable in the context of this site being allocated.

Furthermore, the SA also notes that in relation to Climate Change Mitigation, development around Brentwood urban area would be more sustainable than options elsewhere in South Essex where sustainable transport options are not available:

"In conclusion, options involving a concentration of growth along the A127 corridor perform best, along with Option 7, which is higher growth options that could feasibly reduce pressure for growth at locations to the east within South Essex where commuting by train to London is less attractive as an option."

The SA should therefore re-assess its appraisal of additional growth at Brentwood in light of the evidence presented by Hallam Land Management within its representations in respect of Calcott Hall Farm. In particular, evidence in relation to air quality, biodiversity, heritage, landscape and transport all impact on how the site should be assessed with the SA. The SA should be updated to reflect this further evidence in the same way evidence prepared to inform the appraisal of Dunton Hills Garden Village has been taken into account.