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LLLP conclude that Point A of Policy NE13 should be deleted. Paragraph 8.114 should also be deleted or re-drafted to be explicit and entirely clear that the community benefits sought from meeting housing needs on sites released from the Green Belt will only be secured in accordance with the relevant statutory tests and national planning policies.

Representations for and on LaSalle Land Limited Partnership
Policy NE13: Site Allocations in the Green Belt
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy NE13: Site Allocations in the Green
Belt.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Policy NE13 requires, at Point A, that sites allocated to meet housing needs in the
Green Belt will be:
"expected to provide significant community benefits, both for surrounding
existing communities and those moving into new homes on site".
5. LLLP object to NE13 Point A as the policy appears to be entirely aspirational and
unjustified. The benefit of releasing Green Belt land for new housing is to ensure
that the Borough effectively meets its identified Local Housing Need and maintains
a continuous supply of housing land and sites in order to do so.
6. The National Planning Policy Framework identifies the delivery of new housing as
contributing to achieving sustainable development at paragraph 8 (as both an
economic and social objective) and recognises the importance of significantly
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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boosting the supply of housing at paragraph 59. These national objectives are for
the public benefit and represent positive contributions arising.
7. Financial, land or other contributions to new or expanded community, transport or
environmental infrastructure must be made in accordance with the relevant statutory
tests including the Community Infrastructure Levy Regulations, 2010 (as amended).
8. The NPPF is clear at paragraph 55 that planning conditions should be kept to a
minimum and only imposed where they are necessary, relevant to planning and to
the development permitted, enforceable, precise and reasonable in all other
respects.
9. NPPF paragraph 56 confirms that planning obligations must only be sought where
they meet the relevant statutory tests.
10. Paragraph 57 of the NPPF requires that up-to-date policies should set out the
contributions expected of development.
11. In LLLP's view there is nothing set out in planning statute or in the NPPF that
supports the approach described in Policy NE13 (Point A) or at the reasoned
justification in paragraph 8.114, seeking benefits that are in some way additional to
or in excess of those that are wholly necessary, directly related to the development
and fairly and reasonably related in scale and kind.
Conclusions
12. LLLP object to Policy NE13 at Point A. The policy is not sound as it is not justified
in generally seeking "significant community benefits"; is not effective in terms of
specifying what the benefits sought would be or why they comply with the relevant
statutory and national policies; and the policy is not consistent with the NPPF
including at paragraphs 55 - 57.
Modifications Required
13. LLLP conclude that Point A of Policy NE13 should be deleted. Paragraph 8.114
should also be deleted or re-drafted to be explicit and entirely clear that the
community benefits sought from meeting housing needs on sites released from the
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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Green Belt will only be secured in accordance with the relevant statutory tests and
national planning policies.