Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.