brentwood.gov.uk

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.