It is requested that Brentwood borough council clarify how the proposed settlement hierarchy is supported by the appropriate evidence base. Brentwood borough council should include appropriate reference to the evidence base on this matter in the supporting text

It is requested that Brentwood borough council clarify how the proposed settlement hierarchy is supported by the appropriate evidence base. Settlement Hierarchy - Paragraph 2.8 to 2.10; Figures 2.2 & 2.3

1.0 Introduction
1.1 These representations have been prepared by Bidwells on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's (hereafter referred to as "BBC") public consultation on the Regulation 19 Pre-Submission Local Plan ("the emerging Plan") in respect of land at Nags Head Lane, Brentwood ("the Site").
1.2 Crest Nicholson Eastern controls the entirety of the Site which is the subject of a proposed allocation in the emerging Plan under Policy R06 for the development of around 125 dwellings. Primarily, the consultation seeks responses regarding the soundness of the emerging Plan as set out in the National Planning Policy Framework (NPPF).
1.3 Our comments on the emerging Plan are made having regard to the NPPF, which at paragraph 35 states "Plans are considered sound if they are:
● Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
● Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
● Effective - deliverable over the plan period, and based on effective joint working on crossboundary strategic matters that have been dealt with rather than deferred, as evidenced by the
statement of common ground; and
● Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework."
1.4 Accordingly, these representations:
● Support the principle of the proposed allocation of land at Nags Head Lane, Brentwood under Policy R06 because the allocation of the site for residential development is justified and consistent with national policy; and
● Object to the allocation's indicative dwelling capacity because it would be unnecessarily restrictive of the deliverable quantum of development and is therefore ineffective. 1.5 Our response to the emerging Plan policies is provided within this report and in the enclosed completed Comments Form at Appendix 1. A discussion of the deliverability of the Site drawing upon technical evidence from the accompanying Design Development Framework prepared by Clague Architects (March 2019) is attached at Appendix 2 of these representations. 1.6 We formally request that our recommended amendment is taken into account for the Regulation 22 submission to the Secretary of State and, in accordance with Section 20(6) of the Planning and Compulsory Purchase Act 2004, hereby formally request that Crest Nicholson Eastern is invited to participate at all hearing sessions relevant to Land at Nags Head Lane, Brentwood. Written representations prepared on behalf of Crest Nicholson Easterm In respect of Policy R06: Land at Nags Head Lane, Brentwood
2.0 Support for the Spatial Policies
Chapter 2. A Borough of Villages
Settlement Hierarchy
2.1 Brentwood falls within Settlement Category 1 in the emerging Plan Settlement Hierarchy, the highest-ranking settlement type. Paragraph 2.12 identifies that Brentwood and Shenfield "offer the most scope for development in accordance with sustainable development principles. Urban extensions into the Green Belt are proposed in specific locations with clear physical boundaries and accessible to local services and transport links."
2.2 Description of Category 1 sites appropriately aligns with the characteristics of Brentwood, in that it provides a wide range of services and employment opportunities, is highly accessible and well served by public transport. We consider Brentwood's placement at the top of the Settlement Hierarchy as appropriate.
2.3 Figure 2.3 (Settlement Hierarchy) states that development opportunities in Category 1 settlements including Brentwood "should focus on making the best use of land, with a higher density". We agree with this approach because it would ensure that the development potential of such suitable sites, including Land at Nags Head Lane, is maximised.
Chapter 3. Spatial Strategy - Vision and Strategic
Objectives
Housing Need
2.4 Housing need is discussed at paragraphs 3.7 - 3.9. In planning for residential growth, the emerging Plan states its commitment to planning positively to increase the supply of new homes. The emerging Plan states it will allocate land to exceed the identified local housing need to provide flexibility in the supply and delivery of sites.
2.5 We support the approach to significantly boost the supply of new housing because it demonstrates that the Plan is positively prepared. This should mean that at the site-specific level, allocations for development, including the Land at Nags Head Lane, should seek to deliver the maximum quantum of development possible, taking account of site constraints and masterplans where applicable.
Transit-orientated Growth and the Growth Areas
2.6 Paragraphs 3.11 and 3.21-3.22 recognise the existing pattern of development and the presence of two key infrastructure corridors and that these inform the spatial approach to growth in the emerging Plan. These are the Central Brentwood Growth Corridor, comprised of the A12, the Great Eastern Main Line to London Liverpool Street and the new Elizabeth Line; and the Southern Brentwood Growth Corridor comprised of the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
2.7 Allocating development in these transit corridors ensures that new homes will be sustainably located, linked to existing service centres through proximity and accessibility to strategic transport infrastructure. We consider this an appropriate strategy.
2.8 Allocation of Land at Nags Head Lane fits appropriately with this approach because it falls within the Central Brentwood Growth Corridor. The Bull bus stop is less than 100m from the Site, with routes into Brentwood town centre and Romford. The Site is less than 2 miles from Brentwood town centre and is within 500m of local shops, pubs and a health club. The site is easily accessible from the A12 and M25 and avoids directing vehicular traffic via the town centre of Brentwood. It is therefore a highly suitable site, sustainably located, with accessibility to a wide range of services, facilities and sources of employment reflected in its location within Settlement Category 1 in the emerging Plan Settlement Hierarchy.
Borough Gateways
2.9 In considering spatial development principles, paragraphs 3.25 - 3.26 set out the aspiration for key allocations to deliver gateways that contribute to enhancing a positive impression of the Borough through public art and/or public realm improvements. Figure 3.3 identifies key gateway locations where developments within the local vicinity should enhance the positive impression of Brentwood upon arrival and for those passing by. We note this inclusion, also noting that Land at Nags Head Lane is located close to the east of the identified gateway at Brook Street. We acknowledge this policy intention and Crest Nicholson is prepared to make proportionate and reasonable contributions to enhancements to the Brook Street gateway as part of a planning permission for development of the site.
2.10 Paragraph 3.26 further recognises that sites in key gateway locations offer an opportunity to deliver schemes with higher densities. We support this intention because it would make efficient use of land in accordance with NPPF paragraphs 122 and 123.
Chapter 4. Managing Growth
Policy SP02: Managing Growth
2.11 This policy seeks to direct development to the site allocations set out in the Local Plan and within the highly accessible locations along transit/growth corridors. Land at Nags Head Lane would accord with both of these principles, so we support this policy.
Chapter 6. Housing Provision
Policy HP03: Residential Density
2.12 Pursuant to the above, this policy seeks to define appropriate residential development densities with the caveat that individual schemes should employ a design-led approach to determine an appropriate, site-specific density. Generally, a density of 35 dwellings per hectare or higher will be sought on sites outside of town centres, district shopping centres and local centres. We consider that adopting standards such as this is appropriate, because it would ensure that land is used as efficiently as possible, in accordance with NPPF paragraph 123 which seeks to avoid houses being built at low densities in areas where there is an existing shortage of land for meeting identified housing needs, such as Brentwood.
Chapter 8. Natural Environment
Policy NE13: Site Allocations in Green Belt
2.13 We support the release of sites from the Green Belt for development as a justified approach given the lack of alternatives in the Borough. This is consistent with national policy, namely paragraph 136 of the NPPF, which makes allowance for the alteration of Green Belt boundaries through the preparation or updating of Plans where exceptional circumstances are fully evidenced and justified.
2.14 BBC recognises that exceptional circumstances exist and warrant the release of Green Belt to accommodate the Borough's housing need. As the Borough does not have any non-Green Belt greenfield land that falls outside of existing settlement boundaries, it falls on Green Belt land to accommodate a proportion of the overall housing requirement. BBC does not have sufficient available brownfield land that could deliver the Borough's housing requirements in a manner that would accord with other policy objectives. It would not be possible to develop brownfield sites alone at such high densities in a manner that would not cause detrimental impacts to the Borough's character or compromise the ability to deliver a broad mix of housing in accordance with Strategic
Objectives including SO1 and SO3.
2.15 Land at Nags Head Lane represents an entirely logical development site as an urban extension to development on the south-west of Brentwood. Physically enclosed between Nags Head Lane, the A1023, existing business and residential units and the railway line, the Site makes a "moderate" contribution to the purposes of including land within the Green Belt according to the BBC Green Belt Study (November 2018). It should however be noted that the assessments of alternative sites range predominantly from moderate to high and the Site is therefore among the least sensitive performing Green Belt sites against the purposes of including land in the Green Belt, justifying its release for allocation. Releasing sites such as this takes pressure from other land parcels that perform a more important Green Belt function and minimises the impact on the Green Belt as far as is possible, consistent with national policy.
3.0 Comments on Policy R06: Land at Nags Head
Lane, Brentwood
In Principle Support
3.1 We fully support the principle of allocating this Site for development. Crest Nicholson Eastern is committed to the delivery of the Site in accordance with policy criteria B (Development Principles) and C (Infrastructure Requirements) as discussed in greater detail below.
The Site is strategically well-placed
3.2 The Site is located on the south-western edge of Brentwood, in the south-west of the Borough. Firmly within the Central Brentwood Growth Corridor, the Site is well connected to strategic transport infrastructure comprised of the A12, linking to Chelmsford in the north-east and Romford to the south-west, and the Great Eastern Mainline railway to London Liverpool Street. Brentwood benefits from a station on this railway line, which is approximately 1.7 miles from the Site. The new Elizabeth Line will also serve this corridor with a station in Brentwood, providing further connections across London to Reading and Heathrow to the west. The site accords with the Local Plan's strategic objectives by locating development in the growth areas and main transit corridors.
3.3 The Site is located close to the key gateway location at the junction of the A12 and the M25 as identified in Figure 3.3 of the emerging Plan. Development on the edge of Brentwood would positively contribute to the sense of arrival to the town and this Site would represent an obvious candidate to fulfil BBC's Local Plan aspiration to contribute towards enhancing a positive impression of the Borough. Crest Nicholson Eastern is committed to ensuring this will be achieved at the appropriate stage of developing the proposals.
The Site is suitable
3.4 The site is served by local shops, pubs, restaurants and a health club within a 5-minute walk. There are bus stops located opposite the site with routes into the town centre, less than 2 miles away. Land at Nags Head Lane therefore benefits from excellent sustainability credentials, reflected in BBC's decision to allocate the site for residential development.
3.5 The site is very well enclosed with established permanent boundaries on all sides. It is bounded to the west by Nags Head Lane, the south by a railway cutting, the east by existing dwellings at Mascalls Gardens, and the north by commercial uses and residential plots. The site consists of private fields sub-divided by established trees and hedgerows, making only a "moderate" contribution to the purposes of including land within the Green Belt according to the BBC Green Belt Study (November 2018). It should be noted that the assessments of alternative sites range predominantly from moderate to high and the Site is therefore among the least sensitive performing Green Belt sites against the purposes of including land in the Green Belt Contribution towards the 5-year housing land supply
3.6 We note that the Housing Trajectory contained in Appendix 1 of the emerging Plan anticipates housing delivery of the allocation from the years 2021/22 to 2025/26. As the accompanying Design Development Framework demonstrates that the Site is unencumbered in all respects, we consider that development could be delivered even earlier than this but nevertheless BBC's trajectory still falls within the five-year housing supply timeframe, so we concur with its general assumption and its accordance with NPPF paragraph 73 which seeks local planning authorities to identify an adequate supply of housing in the short term.
Crest Nicholson's credentials
3.7 The Site is controlled in its entirety by Crest Nicholson Eastern and is available and deliverable now to contribute to meeting the local housing need requirements in the emerging Plan and BBC's five-year housing land supply. Crest Nicholson is based locally in Brentwood and has a 50-year heritage of delivering community focused development. Crest prides itself on its focus for high quality design which has been recognised in its awards for National Housebuilder of the Year, twice in the last three years. Other recent accolades include Planning Magazine's Best National Housing Scheme over 500 homes, Evening Standard's Best Small Development and the Sunday Times' winner of the Outstanding Housing and Landscaping category.
Compliance with the draft Policy's Development Principles
3.8 Policy R06 sets out policy criteria to be considered when developing detailed proposals for the Site. These are set out in bold text below and are fully supported, with the exception of criterion A which is not listed here because it is discussed separately from paragraph 3.16 below. Our design response is summarised beneath each criterion:
B. Development Principles
a. Vehicular access via Nags Head Lane.
The accompanying Design Development Framework demonstrates that a suitable vehicular access would be achievable via Nags Head Lane.
b. Provision for pedestrian and cycle connections.
The Design Development Framework shows that a network of pedestrian and cycle connections would be provided.
c. Provision for public open space.
The indicative masterplan shows that a network of high quality public open space ould be provided.
d. Provide for sensitive landscaping along the north and eastern boundaries adjoining existing commercial development and residential dwellings Extensive landscaping is integral to the proposals for the Site, predominantly focused on the boundaries and along strategic green infrastructure corridors within the Site linking the public open spaces. The indicative masterplan shows green buffering along the northern and eastern boundaries adjoining existing commercial and residential development.
C. Infrastructure Requirements
a. The site is located within a Critical Drainage Area. This development may have the potential to impact on the Critical Drainage Area in respect of surface water flooding. As a result of this, the site is likely to require an individually designed mitigation scheme to address this issue.
The proposed drainage strategy for the Site includes Sustainable Drainage Systems (SuDS) such as permeable paving, swales and ponds to alleviate the risk of surface water flooding associated with the Site's location within a Critical Drainage Area.
The allocation is deliverable
3.9 The accompanying indicative masterplan demonstrates that a scheme for approximately 150 new homes could be delivered on the Site. This takes account of specialist evidence in respect of landscape, access, utilities, drainage, noise and heritage as summarised in the accompanying Design Development Framework.
3.10 The masterplan proposes to retain and enhance the existing vegetation structure along the southern boundary of the Site, along Nags Head Lane to provide a robust edge to the development parcel and filter views into the Site, incorporate a sequence of open spaces and SuDS, retain the internal tree and hedgerow structure where appropriate as part of the internal network of green corridors and to plant trees along contours to filter views from the north (across the valley) and to contribute to amenity value within the Site.
3.11 In respect of access, the potential impact of development traffic on the operation of the Brook Street/Nags Head Lane/Wigley Bush Lane signal junction has been assessed. Whilst the forecast increase in traffic through the junction would be imperceptible, consideration has been given to modifications to improve the future operation of this junction. A proposed improvement scheme has been assessed, which comprises an additional short lane for ahead and left traffic on the Wigley Bush Lane approach, increased kerb radius and exit taper for the left turn into Wigley Bush Lane that allows the stop line to be moved closer to the junction, and a pedestrian crossing on the eastern arm of Brook Street. Junction capacity analysis has shown that the proposed improvements would more than mitigate the impact of development traffic, the result being an overall net benefit to junction capacity. The scheme would be compliant with policy guidance on transport and land use planning at both a national and local level and would have a positive impact in terms of junction capacity and pedestrian connectivity.
3.12 National Grid has confirmed a High Pressure (HP) Gas Main runs beneath the south west corner of the Site. The illustrative masterplan shows that a 28m corridor has been provided above the HP Main to allow for future access and maintenance and limit the risk of damage to the main. Following discussions with National Grid, the Health and Safety Executive has confirmed in writing that they would not object to the current indicative layout if submitted seeking planning permission.
3.13 A preliminary noise assessment has been undertaken to assess impacts arising from primary noise sources on the M25, A12, A1023, Nags Head Lane and railway noise from the adjacent Great Eastern Mainline. The preliminary assessment shows that no single noise source is dominant and that with appropriate layout and noise treatment to the most exposed properties, both internal and external ambient noise levels would be within the desirable range and would meet with applicable
standards.
3.14 The above demonstrates that Crest Nicholson has given due consideration to the deliverability of the allocation and proposes a responsive and well-designed masterplan.
3.15 Taking account of the above we fully support the principle of the Site's proposed allocation.
Objection to the amount of development
3.16 Policy criterion A. states that the site will provide "around 125 new homes of mixed size and type". We consider that this underplays the deliverable quantum of development the Site could accommodate and therefore object to this strand of the policy requirement because the Policy is
ineffective.
3.17 The Site has been proposed for allocation in the emerging Plan since the Draft Regulation 18 iteration published for consultation in 2016, but the original draft allocation was for the delivery of around 150 dwellings. Indeed, if the residential density standard of 35 dwellings per hectare from Policy HP03 is applied to the net developable area identified in the draft allocation of 4.35 hectares, the indicative dwelling yield would be 152.25 dwellings per hectare.
3.18 As emerging Policy HP03 requires (as we have discussed at para 2.12 above), a design-led approach to determining the appropriate, site-specific residential development density has been undertaken for the Site. The accompanying Design Development Framework articulates how approximately 150 dwellings could be delivered on the Site in a generously landscaped scheme incorporating a network of public open space incorporating SuDS features and a locally equipped area of play.
3.19 The BBC Sustainability Appraisal (SA) provides justification for the reduction in units onsite. At paragraph 9.7.2 it states:
"Focusing on proposed changes to the spatial strategy since 2016, points to note are -
● The proposal to reduce the number of homes delivered at Land east of Nag's Head
Lane is supported, given proximity to several listed buildings at Brook Street."
3.20 And at 9.10.2 it states:
"Finally, it is noted that a decision was taken to reduce the quantum of homes (C3) delivered at all four of the Green Belt sites proposed by the 2016 Draft Plan, namely Land off Doddinghurst Road, Land east of Nags Head Lane, Land at Honeypot Lane and Officers Meadow. The Landscape Cpacity Study finds three of these sites to have "medium" capacity, such that a decision to reduce the quantum of homes is tentatively supported; however, Land off Doddinghurst Road is identified as having "medium-high" landscape capacity."
3.21 We consider that these statements are not justified. Whilst the Nag's Head Inn is a Grade II listed building, the Built Heritage Assessment previously submitted with our Regulation 18 representations demonstrates that it once stood as a rural building surrounded by fields and outside the tiny hamlet of Brook Street, but today it is experienced as a road-side public house in the vicinity of residential and commercial development. The area to the south of the Inn, where the Site is located, is still characterised by fields subdivided by hedgerows and trees, however the visual relationship between the Inn and the fields that make up the Site is far less apparent since
topographical features, such as thick hedgerow that border Nags Head Lane, obscure the views. Furthermore, the significance of the Inn is considered to lie within its historical and architectural value. The visual relationship between the Inn and the Site is far less than the visual connectionbetween the Inn and the fields to the south-west, which are directly behind the listed building.
3.22 Accordingly, the impact of Crest Nicholson's accompanying development proposals, with mitigation incorporating retained vegetation, contouring and open green space close to the listed building, mean that the visual impact of the setting of the listed building would be minimal, resulting in only a minor level of less than substantial harm. Given the need to promote sustainable patterns of development when Green Belt boundaries are being re-drawn (NPPF para 138), we consider the arbitrary reduction in unit numbers is not properly justified and should be amended to reflect what could reasonably be achieved on the site, taking account of Crest Nicholson's masterplanned approach.
3.23 With landscape considerations at the forefront of the design process, delivery of approximately 150 dwellings on the Site is demonstrated to the fully achievable without significant harm to the landscape in the accompanying Design Development Framework. Contained within the Design Development Framework is a summary of a Landscape Visual Impact Assessment, setting out the key landscape characteristics and the principal considerations for the identification of opportunities and constraints on the Site. This LVIA concludes that the scheme can deliver approximately 150 dwellings whilst mitigating landscape impacts effectively. The detail of the design approach taken to achieve this is discussed further in the section below.
3.24 Having taken the above design-led approach and determined that a quantum of development of approximately 150 dwellings is entirely achievable, the emerging Plan allocation should reflect this in order to ensure best use of land and maximise the development potential. The policies we have commented on above demonstrate a clear intention of BBC to seek to deliver dwellings beyond the local housing need target and this is reflected in national policy, where the NPPF requires the highest density possible on sites, particularly in areas where the land supply is significantly constrained as is the case in the predominantly Green Belt Borough of Brentwood.
3.25 We are aware that since the earlier iterations of the emerging Plan, the quantum of development proposed in the Dunton Hills Garden Village strategic allocation has increased from 2,500 dwellings in the emerging Plan period to 2,700. Other allocations, including this site which is deliverable in the short-term, should similarly seek to maximise delivery in line with the residential density standards and the design-led approach in Policy HP03 as the appropriate method for assessing the deliverable dwelling yield.
3.26 We recommend that Policy R06 reinstates the Draft Local Plan allocation quantum of approximately 150 dwellings. This would ensure that the emerging Plan is positively prepared in its ambition to maximise the delivery of new homes above and beyond the local housing need target, justified in its strategy for ensuring the best use of land for development and consistent with national policy in delivering an optimum residential density, particularly in an area with a significantly constrained land supply.
Changes necessary to make the Plan sound
3.27 Taking account of the above, we recommend that Policy R06 criterion A reinstates the Draft Local Plan's proposed quantum of development for the Site. Accordingly, it should say "provision for approximately 150 new homes of mixed size and type".
4.0 Conclusion
4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in response to BBC's emerging Plan consultation in respect of the Site.
4.2 Crest Nicholson controls the land at Nags Head Lane, Brentwood, which is proposed for allocation under Policy R06.
4.3 We:
● Support the principle of the proposed allocation of Land at Nags Head Lane, Brentwood under Policy R06 because the allocation of the site for residential development is justified and consistent with national policy; and
● Object to the allocation's indicative dwelling capacity because it would be unnecessarily restrictive of the deliverable quantum of development and is therefore ineffective.
4.4 We fully support the principle of the allocation of the Site as a positively prepared and justified policy. Allocating sites to exceed the identified local housing need is consistent with national policy, whereby housing targets are viewed as a minimum and should be exceeded where possible to ensure flexibility in housing delivery. The Site is a logical and sustainable development site to contribute dwellings towards achieving the Local Plan strategy, well related to the settlement of Brentwood and within the Central Brentwood Growth Corridor with excellent links to strategic transport infrastructure.
4.5 We object to the quantum of development quoted in the Site allocation. The Site has been included as an allocation in the emerging Plan since 2016 and the original allocation planned for 150 dwellings, based on our masterplanned approach to development set out in the accompanying Development Framework Document. The reduction to 125 dwellings in the Pre-Submission Local Plan does not align with the technical evidence and design work accompanying these representations, that demonstrates that the Site can appropriately accommodate approximately 150 dwellings taking account of the site-specific constraints and opportunities. In light of emerging Plan Policy HP03, the density of development should be maximised through a design-led approach. The quoted quantum of 125 dwellings also falls short of the standard density figure of 35 dwellings per hectare stated in Policy HP03.
4.6 In order to make the Local Plan sound, we recommend that BBC reinstates the Preferred Options draft Local Plan quantum of the proposed Site allocation to approximately 150 dwellings, to make better use of the land and maximise delivery.
4.7 Subject to the above amendment, we consider the emerging Local Plan satisfies the tests for soundness set out in paragraph 35 of the NPPF.

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Partnership University NHS Foundation Trust ("EPUT") in response to Brentwood Borough Council's ("BBC") public consultation on the Regulation 19 Pre-Submission Local Plan ("the emerging Plan") in respect of land off Warley Hill, Warley ("the Site"). The land the subject of these representations is shown on the accompanying Site Location Plan at Appendix 1.
1.2 EPUT owns the Site which is the subject of a proposed allocation in the emerging Plan for the development of around 43 dwellings. Primarily, the consultation seeks responses regarding the soundness of the emerging Plan as set out in the National Planning Policy Framework (NPPF), published in February 2019.
1.3 Our comments on the emerging Plan are made having regard to the NPPF, which at paragraph 35 states "Plans are considered sound if they are:
● Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
● Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
● Effective - deliverable over the plan period, and based on effective joint working on rossboundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
● Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework."
1.4 Accordingly, these representations fully support the proposed allocation of land off Warley Hill under Policy R09 because the allocation of the site for residential development is justified, effective and consistent with national policy.
1.5 Our response to the emerging Plan's strategic policies is provided below in the following section, with our comments on the proposed site allocation at Policy R09 thereafter. These representations are supported by:
● A completed version of the Comments Form at Appendix 2 of this report; and
● Urban Design Strategy at Appendix 3 of this report.
2.0 Our Support for the Strategic Policies
Chapter 2. A Borough of Villages
Settlement Hierarchy
2.1 Warley falls within Settlement Category 1 in the emerging Plan Settlement Hierarchy, the highest anking settlement type. Paragraph 2.11 identifies that the Brentwood Urban Area, which includes Warley, and Shenfield offer the most scope for growth in accordance with sustainable development principles. Urban extensions into the Green Belt are proposed in specific locations with clear physical boundaries and accessible to local services and transport links.
2.2 Category 1 sites are described in Figure 2.3 as "providing a wide range of services and opportunities for employment, retail, education, health and leisure facilities to the immediate residential areas as well as to the wider population in the borough. They are typically highly accessible and well served by public transport provision, including rail services, and existing infrastructure."
2.3 This description appropriately aligns with the characteristics of Warley as part of the Brentwood Urban Area, in that it provides a wide range of services and employment opportunities, is highly accessible and well served by public transport - this is demonstrated by being only 800m from Brentwood mainline / Crossrail station. We consider that Brentwood Urban Area's placement at the top of the Settlement Hierarchy, including Warley, is appropriate and justified.
Chapter 3. Spatial Strategy - Vision and Strategic
Objectives
Housing Need
2.4 Housing need is discussed at paragraphs 3.7 - 3.9 of the consultation document. In planning for residential growth, the emerging Plan states its commitment to planning positively to increase the supply of new homes. The emerging Plan states it will allocate land to exceed the identified local housing need to provide flexibility in the supply and delivery of sites. We support the approach to significantly boost the supply of new housing because it demonstrates that the Plan is positively prepared.
2.5 The flexibility benefits of allocating sites to exceed the identified local housing need can only be realised if the supply of those sites is not unduly restricted to arbitrary time periods. The Local Development Plan Housing Trajectory identifies anticipated delivery timescales for allocated sites, but this should not prejudice the early delivery of sites anticipated to be built out later in the emerging Local Plan period. In order to be considered positively prepared, allocated sites should be delivered as soon as they are available.
Transit-orientated Growth and the Growth Areas
2.6 Paragraphs 3.11 and 3.21-3.22 recognise the existing pattern of development and the presence of two key infrastructure corridors and that these inform the spatial approach to growth in the emerging Plan. These are the Central Brentwood Growth Corridor, comprised of the A12, the Great Eastern Main Line to London Liverpool Street and the new Elizabeth Line/Crossrail; and the Southern Brentwood Growth Corridor comprised of the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
2.7 Allocating development in these transit corridors ensures that new homes will be sustainably located, linked to existing service centres through proximity and accessibility to strategic transport infrastructure. We consider this an appropriate and justified strategy.
2.8 Allocation of Land off Warley Hill fits appropriately with this approach because it is located within the Central Brentwood Growth Corridor, approximately 800 metres from Brentwood mainline / Elizabeth line/Crossrail station. Warley Hill, Albert Street and Walter Boyce Centre bus stops are all less than 100m from the Site, with routes into Brentwood town centre and Romford. The Site is less than 2 miles from Brentwood town centre, which offers public transport routes to Grays, South Ockendon, Chelmsford city centre, Basildon town centre, Billericay and Shenfield among other destinations. It is within 300m of a local supermarket, petrol station, sandwich bar, GP surgery, primary school and employment opportunities. The site is easily accessible from the A12 and M25.
2.9 Land off Warley Hill is therefore a highly suitable site, sustainably located in the heart of the Central Brentwood Growth Corridor, with accessibility to a wide range of services, facilities and sources of employment reflected in its location within Settlement Category 1 in the emerging Plan Settlement Hierarchy. With such infrastructure already in place around the Site, delivery of dwellings can commence imminently, and the Site should not be held back to latter parts of the emerging Local Plan period in line with the Local Development Plan Housing Trajectory.
Chapter 4. Managing Growth
Policy SP01 Sustainable Development
2.10 This policy advocates a positive approach to considering developments that accord with the presumption in favour of sustainable development as set out in paragraph 11 of the NPPF. Clearly this is consistent with national policy and we support this approach. Paragraph C of the policy aligns with the NPPF requirement for development that accords with the emerging Local Plan to be approved without delay unless material considerations indicate otherwise. Land off Warley Hill is a proposed allocation and a planning application brought forward for the development of the site in accordance with this and should therefore be approved without delay.
Policy SP02: Managing Growth
2.11 This policy seeks to direct development to the site allocations set out in the Local Plan and within the highly accessible locations along transit/growth corridors. Land off Warley Hill would accord with both of these principles, so we support this policy.
Chapter 8. Natural Environment
Policy NE13: Site Allocations in Green Belt (8.113)
2.12 We support the release of sites from the Green Belt for development as a justified approach given the lack of alternatives in the Borough. This is consistent with national policy, namely paragraph 136 of the NPPF, which makes allowance for the alteration of Green Belt boundaries through the preparation or updating of Plans where exceptional circumstances are fully evidenced and justified.
2.13 BBC recognises that Green Belt release is necessary to meet the Borough's housing needs. BBC has insufficient available brownfield land within existing urban areas to deliver this need. It falls on Green Belt land to accommodate a proportion of the overall housing requirement. Within this context it therefore follows that the most suitable available brownfield sites within the Green Belt should be allocated for residential development.
2.14 Land off Warley Hill represents an entirely suitable development site as an urban extension to development on the south of Brentwood Urban Area. With existing residential and commercial development to the south and east, the former Warley Hospital buildings to the north-west and Pastoral Way to the north, the Site is identified as making only a "moderate" contribution to the purposes of including land within the Green Belt according to the BBC Green Belt Study (November 2018). It should be noted that the assessments of alternative sites range predominantly from moderate to high and the Site is therefore among the least sensitive performing Green Belt sites against the purposes of including land in the Green Belt, justifying its release for allocation.
Releasing sites such as this takes pressure from other land parcels that perform a more important Green Belt function and minimises the impact on the Green Belt as far as is possible, consistent with national policy.
3.0 Our Support for Policy R09: Land off Warley Hill
3.1 We fully support the allocation of this Site for residential development and EPUT is committed to the delivery of the Site in accordance with the criteria set out in policy R09. This is for the reasons elow.
The Site is surplus to NHS requirements
3.2 The Site is sustainably located, previously developed, surplus to its former public sector requirements and is currently vacant. It contains 6 buildings with associated outbuildings and structures. These buildings were formerly used to support the provision of NHS services and was formerly part of the wider Warley Hospital site that has now been redeveloped for housing. The Site was originally developed in the 1930s and initially provided staff accommodation but more recently the existing buildings have also been used for various NHS health care-related purposes, including a drop-in service and care for people with learning difficulties. This was the case up until February 2012 when the need for the facility by the NHS ceased and the properties were vacated.
3.3 Essex Partnership University NHS Trust (EPUT) currently maintains the Site but the prolonged vacancy has increased the risk of the following issues occurring:
● Vandalism of the buildings;
● Anti-social behaviour;
● Unauthorised occupation of the buildings;
● Neighbouring amenity being jeopardised;
● Vermin nuisance to local residents; and/or
● Landscaping / trees becoming overgrown.
3.4 These are practical reasons to support the redevelopment of the Site in the short term. In addition, maintaining and securing the current buildings costs the NHS money and these finances may be better used in a positive way to support improved healthcare services. The Site's removal from the Green Belt is fully justified
3.5 We support the Site's removal from the Green Belt because this is consistent with national planning policy. BBC recognises that exceptional circumstances exist and warrant the release of Green Belt to accommodate the Borough's housing need, in accordance with NPPF paragraph 135. Furthermore, development of the site would contribute towards sustainable patterns of development because the site is located within the heart of the Central Brentwood Growth Corridor, consistent with NPPF paragraph 138, and adjacent to the existing development boundary of the Brentwood Urban Area.
3.6 Paragraph 139 of the NPPF states "when defining Green Belt boundaries, plans should...define boundaries clearly, using physical features that are readily recognisable and likely to be permanent." The B186, Warley Hill, along the Site's eastern boundary, currently forms the Green Belt boundary. The Site is bounded to the west by Clement's Wood, designated as an ancient woodland, secondary woodland habitat and a Local Wildlife Site (LoWS) as described in the Brentwood Borough Local Wildlife Site Review (2012). The woodland's designated status on the western boundary of the Site provides certainty that the redefinition of the Green Belt boundary would follow this feature would be strong, recognisable and permanent, in accordance with NPPF paragraph 139. For ease of reference, we have included an extract of the designated site.
Above: Extract from BBC's Local Wildlife Site Review: Bre61 Clement's Wood - the Site is adjacent to eastern boundary of Clement's Wood.
3.7 The Site is controlled in its entirety by EPUT and is available and deliverable now to contribute to meeting the local housing need requirements in the emerging Plan and BBC's five-year housing land supply. The deliverability of the masterplan proposals for the Site is demonstrated further in the section below.
Compliance with Policy R09's Development Principles
3.8 The extract below shows the allocation within the consultation document:
3.9 Policy R09 also sets out specific Development Principles to be considered when developing detailed proposals for the Site. These are set out and underlined below and we fully support them. Our design response is summarised beneath each criterion:
A. Amount and Type of Development
a. provision for around 43 new homes of mixed size and type:
We fully support this quantum of development and the accompanying Urban Design Strategy demonstrates the deliverability of this quantum of development on the Site.
B. Development Principles
a. vehicular access via Pastoral Way:
The accompanying masterplan in the Urban Design Strategy confirms that vehicular access would be provided via Pastoral Way, where there is a current vehicle access into the Site.
b. preserve the setting of nearby listed buildings:
The Heritage Assessment (summarised within the Urban Design Strategy) concludes that The Firs and Lyndhurst buildings are not listed and can be demolished and Shenleigh, Bramley and Beeches buildings are curtilage listed but are relatively ordinary in appearance and can be demolished. Greenwoods is similarly listed and of architectural value, so is proposed for retention within the scheme. The Tower House at Warley Hospital is also a grade II listed structure and the masterplan includes extensive tree belts and open space in its vicinity to preserve the setting.
c. provide for sensitive landscaping throughout the site and consider the need for the retention of some existing trees on site where appropriate:
The masterplan shows a generously landscaped scheme, with existing trees of value retained and the provision of open space and landscaping throughout.
C. Infrastructure Requirements
a. the site is located within a Critical Drainage Area. This development may have the potential to impact on the Critical Drainage Area in respect of surface water flooding. As a result of this, the site is likely to require an individually designed mitigation scheme to address this issue:
The inclusion of significant areas of landscaping and open space provides opportunities o deliver a bespoke drainage strategy on the Site, which would be designed in detail at he appropriate stage of the development of the proposals.
Constraints and Opportunities
3.10 The accompanying Urban Design Strategy provides an assessment of the opportunities and constraints of the Site, summarised by the following key points:
● Green Belt: The Site is currently located within the Green Belt although the emerging Local Plan proposes its removal and allocation for residential development.
● Arboriculture: There are significant existing trees on the Site with related constraints, particularly Category A and B to be retained and the presence of Tree Preservation Order TPO 10/91. Presence of Ancient Woodland within Clement's Wood.
● Heritage: Presence of heritage building 'Greenwoods' and the setting of the Listed Victorian Water Tower, both of which are considered worthy of retention.
● Biodiversity and open space: There are opportunities to enhance the biodiversity offering on the Site and potentially through the retention of existing green open space. Bats, birds and breeding mammals surveys are necessary which may determine further ecological constraints. These surveys would be undertaken at an appropriate stage of the development of the proposals.
● Cyclists and pedestrians: It is necessary to provide adequate circulation routes and provision for cyclists and pedestrians. Pedestrian connections to Warley Hill are necessary for pedestrians to access public transport bus routes.
Our Design Approach
3.11 In responding to the opportunities and constraints, the detailed design for the Site will provide highquality development in a landscape-led scheme, illustratively depicted in the accompanying Urban Design Strategy at Appendix 3 of this report and as shown below:
Above: Indicative Layout contained within the accompanying Urban Design Strategy
3.12 The indicative masterplan contains the following key features:
● Protection of the existing listed building Greenwoods;
● Creating a more appropriate and grander setting for the adjacent Listed Water Tower through the careful placement of buildings and open space;
● Protection and retention of existing trees, introduction of a new planting scheme and biodiversity measures;
● Integration of a mix of dwelling types including detached houses, town houses, and potentially live-work units;
● Creation of a more curvaceous form to the site access road and greater connectivity to the wider area.
3.13 This demonstrates that a high-quality development scheme incorporating substantial areas of landscaping and open space can be delivered alongside approximately 43 dwellings in a highly sustainable location.
Contribution towards the 5-year housing land supply
3.14 EPUT is fully committed to realising the delivery of the allocated development in the short-term and intends to engage in formal pre-application discussions with BBC imminently with the intention of progressing with an outline application as soon as is reasonably possible.
3.15 BBC's delivery assumptions are that the allocation would be completed within years 2023/4 and 2024/5. Whilst we consider this to be pessimistic, it does fall within the first five years from now so we concur with the assessment that the allocation would contribute towards the five-year supply. Securing this allocation would also ensure that BBC would maintain a strong and varied portfolio of sites that can deliver immediately following adoption of the Local Plan and underpin supply pipeline whilst the large strategic sites undergo the requisite lead-in.
3.16 We therefore fully support Policy R09.
4.0 Conclusion
4.1 These representations have been prepared on behalf of Essex Partnership University NHS Foundation Trust in response to BBC's emerging Plan consultation in respect of Land off Warley Hill. EPUT owns the Site.
4.2 We support the proposed allocation of Land off Warley Hill under Policy R09 because the allocation of the site for residential development is justified and consistent with national policy. 4.3 Allocating sites to exceed the identified local housing need is consistent with national policy, whereby housing targets are viewed as a minimum and should be exceeded where possible toensure flexibility in housing delivery. We also support the proposed policies relating to Growth Areas, the Settlement Hierarchy, Managing Growth and the general approach to directing growth to the most sustainable locations. BBC recognises that exceptional circumstances exist and warrant the release of Green Belt to accommodate the Borough's housing need.
4.4 The Land off Warley hill is located within the heart of the Central Brentwood Growth Corridor, 800m from Brentwood Crossrail station, with good accessibility to key services and facilities as well as the strategic road network, train links to London and other public transport. Several primary and secondary schools are within a reasonable distance and the characteristics of the site, with softly undulating land and an abundance of trees and hedgerows in the setting of the Water Tower heritage asset, offer a unique opportunity for high-quality, aesthetically pleasing homes.
4.5 As vacant previously developed, surplus public-sector land, the site represents an excellent opportunity to deliver homes on brownfield land in line with policy direction in the NPPF and would make best use of land currently costing the NHS money in maintenance and upkeep.
4.6 We therefore support BBC in allocating the Site for residential development.
4.7 Taking account of the above, we would seek to support BBC in its defence of Policy R09 at Examination and we therefore consider it appropriate to participate at the oral part of the Examination in Public to enable discussion of the points we have raised.

DHGV should be deleted from Settlement Category 2 and separately identified in
both Figures 2.2 and 2.3 of the Plan in order to make plain its current situation.
Paragraph 2.14 should then be modified accordingly to clearly articulate that the
Garden Village does not yet exist and remains an aspiration of the BBLP rather than
a final development scheme.

Representations for and on LaSalle Land Limited Partnership
Settlement Hierarchy - Figures 2.2 and 2.3 and Supporting Text
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 the proposed settlement categorisation and
hierarchy set out in Section 2 and Figures 2.2 and 2.3 and supporting paragraphs.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Overall Settlement Hierarchy
4. LLLP support the overall settlement hierarchy and categorisation of individual
existing towns and villages set out in Figure 2.2 of the BBLP but have concerns with
respect to the categorisation of Dunton Hills Garden Village (DHGV) as falling within
Settlement Category 2.
Settlement Category 1 - Brentwood
5. LLLP support the identification of Brentwood town as forming part of Settlement
Category 1 and agree with the description of such settlements in the Figure 2.3
(table following paragraph 2.10). It is agreed that Brentwood is correctly identified
as a 'Large Town'.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
6. LLLP are however concerned that Figure 2.3 does not provide sufficient emphasis
in the text to the effect that Settlement Category 1 towns provide the most
sustainable locations in the Borough for future development and services. The text
should also be modified, in LLLP's view, to include reference to the need to use
greenfield and Green Belt land in and at the edge of Brentwood town for future
housing and economic development.
Settlement Category 2 - Dunton Hills Garden Village
7. LLLP object to the inclusion of Dunton Hills Garden Village as part of Settlement
Category 2. The Garden Village does not exist and does not relate to the text in
Figure 2.3 that describes Settlement Category 2 as larger villages in a rural setting.
8. DHGV is an untested, future, strategic development proposal using greenfield,
Green Belt land. The development proposals are aspirational and it is not an
existing settlement location.
Conclusions
9. LLLP supports the overall approach to the identification of the Settlement Hierarchy
and categorisation.
10. LLLP does however object to the inclusion and approach to Dunton Hills Garden
Village in Figures 2.2 and 2.3 and the supporting text of paragraph 2.14. The
Settlement Categorisation is not sound as it is not:
* Justified - for the reasons identified in this representation, the inclusion of
DHGV as a Settlement Category 2 location is not justified. The settlement
hierarchy needs to reflect the situation now. Future development proposals
(including the provision of a new settlement such as DHGV), which have yet
to be tested in detail and which have not been found to be the most
appropriate growth strategy fall outside the settlement hierarchy. Their
inclusion as if they already exist (and have received planning approval) is
not justified.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
* Effective - the inclusion of DHGV in Settlement Category 2 fails to reflect the
proposed scheme's status and that its development is an aspiration of the
BBLP rather than forming part of the existing settlement hierarchy.
Modifications Sought
11. DHGV should be deleted from Settlement Category 2 and separately identified in
both Figures 2.2 and 2.3 of the Plan in order to make plain its current situation.
Paragraph 2.14 should then be modified accordingly to clearly articulate that the
Garden Village does not yet exist and remains an aspiration of the BBLP rather than
a final development scheme.

Additional land for housing should be allocated at Ingrave to meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.
Paragraph 2.16 of the Plan notes that, in relation to Category 3 settlements;
'Brownfield redevelopment opportunities will be encouraged to meet local needs, and policies in this Plan will help to bring forward nearby redevelopment of brownfield sites in the Green Belt where appropriate.'
This emphasis on bringing forward brownfield sites 'nearby' Category 3 settlements is supported. This approach would provide a more flexible approach and would enable sites such as our client's site to come forward.

RE Planning Policy Framework 1.24 - 1.25
Planning Policy Framework
Since the Local Plan Regulation 18 consultation, which took place in early 2018, the revised NPPF has been published. This Plan will therefore now be examined against the policies set out in the revised NPPF (February 2019). Paragraph 212 of the NPPF confirms this, stating that:
'Plans may ...need to be revised to reflect policy changes which this replacement Framework has made. This should be progressed as quickly as possible, either through a partial revision or by preparing a new plan.'
We question whether, in light of this fundamental change to the planning policy context, as well as changes to the introduction of the Standard Methodology for calculating housing need and the Housing Delivery Test, which will be discussed below, the Plan should progress to Examination.
In addition, we note that significant elements of the evidence base to the Plan, which were prepared under the 2012 NPPF, have not been updated.
For example, the Site Assessment Methodology and Summary of Outcomes - Working Draft provides the basis on which sites have been assessed as suitable for development and whether they should be allocated in the Plan. This document has not been amended to reflect the publication of the revised NPPF, or the Standard Methodology. The paper still refers to making provision for 'slightly above 380 dwellings per annum'; in fact, this number will need to increase significantly, for reasons set out below.
On this basis, we believe that the Plan is unsound. It is not positively prepared because it does not make provision for the Borough's objectively assessed needs and it is not justified because the evidence base on which it is based is not proportionate.
The Plan should be updated so that the housing need is calculated based on the Government's standard methodology for calculating housing need, as well as reflecting the findings of the Housing Delivery Test. This will significantly increase the housing numbers and the number of sites required. Further consultation should then take place on a revised draft Plan, before it is submitted for Examination.

RE: Policy R01 (i) Garden Village Strategic Allocation
Dunton Hills Garden Village Strategic Allocation: Policy R01 (I)
Land at Dunton Hills (east of the A128, south of the A127 and north of the C2C railway line, approximately 259.2 ha in size) is allocated for residential-led development to deliver Dunton Hills Garden Village (DHGV).
The policy states that development will deliver a mix of uses to comprise around 2,700 homes in the plan period (as part of an overall indicative capacity of around 4,000 homes to be delivered beyond 2033 - subject to further feasibility and assessment of impact). This number has increased from 2,500 homes stated in the Preferred Site Allocations Consultation document of March 2018.
We object to this policy to propose a new settlement to deliver 2,700 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged.
We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF.
It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example Braintree District, Tendring District and Colchester Borough councils in relation to the North Essex Garden Communities.
Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings.
The housing trajectory suggest that DHGV will deliver 750 dwellings by 2026. However, given the recent research, adopting the lag of seven years from a Plan adoption date before the end of 2019 (which we consider highly ambitious) would mean there would be no deliveries on site until after 2026.
Paragraph 9.33 states that of the 6,700 homes, 4,000 are to be delivered after 2033. However, this is caveated by the statement 'subject to further feasibility and assessment of impact', calling into doubt whether 4,000 can in fact be delivered on site.
The Plan places significant reliance on the timely delivery of Dunton Hills Garden Village. This is not a positive strategy for meeting housing need and does not provide the flexibility required to address changes in circumstances. The allocation should be complemented by the allocation of small sites, to improve deliverability.
We wish to participate in the Examination to set out the case that additional smaller sites should be allocated, to ensure the Plan's deliverability and to ensure a constant delivery of new homes.

RE Policy SP02 - Managing Growth
Housing Delivery
The Plan proposes that as 'the high proportion of designated Green Belt within the Borough makes it extremely difficult to achieve a five year supply' (Paragraph 4.19), a greater proportion of the required homes are forecast to be delivered in the period beyond 2023. Policy SP02 therefore sets out a stepped trajectory of delivery of 310 homes per annum to 2023, followed by a higher target of 584 per year to 2033.
We do not believe that Policy SP02 is sound because it does not provide an appropriate strategy to comply with the requirements of the NPPF, which states in paragraph 23 that:
'Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development.'
The strategy does not result in the delivery of housing throughout the Plan period. Paragraph 73 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the Plan period. Appendix 1 of the Plan sets out this housing trajectory, which demonstrates that no units will be delivered in 2019/2020 from the site allocations, and only 66 units are proposed to be delivered in 2020/2021, with 318 in 2021/2022 and 632 in 2023/2024.
We question whether this is an appropriate strategy, and believe that on this basis, Policy SP02 is unsound because it is not justified.
To set out the case that the Plan should allocate additional, smaller sites, to enable the Plan to deliver homes throughout the Plan period.

RE Local Housing Need - Paragraphs 4.11 - 4.21
Housing Need
In October 2018, the Government consulted on technical changes to its proposed Standard Methodology to calculate housing need based not on the 2016 household projections published by the Office for National Statistics, but on the 2014 household projections published by the Department for Communities and Local Government (DCLG). These revised projections result in a housing figure for the Borough of 456 dwellings per annum.
In February 2019, the Government published a summary of the responses to its October 2018 technical consultation and its view on the way forward, in which it confirmed that its proposed approach provided the most appropriate approach 'for providing stability and certainty to the planning system in the short term' and that Local Planning Authorities should not use the 2016 household projections, which resulted in lower housing numbers, as a reason to justify lower housing need.
The Plan states that the Borough's annual housing requirement is still 380 homes per annum, based on the findings of the Strategic Housing Market Assessment (2016). However, paragraph 4.16 of the Plan sets out the intention to make provision for an additional housing supply buffer, which provides a 20% uplift to the annual housing figure of 380 units, resulting in provision of 456 dwellings per annum, resulting in a requirement for 7,752 dwellings from 2016 - 2033. This is the same figure as required by the Government's Standard Methodology for Calculating Housing Need.
However, Brentwood Borough Council was recently identified in the publication of the Government's Housing Delivery Test as an authority which has delivered less than 85% of its housing requirement, and therefore has to add a 20% buffer to its housing land supply figure.
We therefore object to the housing requirement set out in the Plan on the basis that it is insufficient to meet the Borough's needs. Paragraph 59 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The Plan does not do this; it only makes provision for the OAN and does not provide for the additional 20% buffer, as required under the Housing Delivery Test.
It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.
The Plan should be updated to make provision for the Borough's objectively assessed need, to take account of the figure in the Government's Standard Methodology for Calculating Housing Need, with an additional 20% buffer to reflect the Housing Delivery Test.
If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary. To set out why the Plan is not making adequate provision for new housing.

RE Figure 2.3 - Settlement Hierarchy
Settlement hierarchy
To promote sustainable growth in rural areas, the NPPF (2019) paragraph 78 states that housing in rural areas should be located where it will enhance the vitality of rural communities, to ensure villages grow and thrive. To ensure the Local Plan responds to this, a broad Settlement Hierarchy Assessment has been undertaken to understand the role, function and relationship of Brentwood's dispersed settlements.
The Plan sets out the settlement hierarchy in the Borough. Ingrave is classed as a Category 3 settlement. Whilst we support the classification of Ingrave as a "Category 3 - Large Village", we object to the inconsistent treatment of this settlement in comparison to other settlements occupying the same level in the hierarchy.
For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave.
The moratorium of growth in these villages is contrary to the NPPF, which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. The NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 78).
As drafted, the Plan is not sound. It identifies Ingrave as a Category 3 settlement but does not allocate housing in or near the settlement. This is not an appropriate strategy and therefore the Plan is not justified in this respect.
Additional land for housing should be allocated at Ingrave to meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.
Paragraph 2.16 of the Plan notes that, in relation to Category 3 settlements;
'Brownfield redevelopment opportunities will be encouraged to meet local needs, and policies in this Plan will help to bring forward nearby redevelopment of brownfield sites in the Green Belt where appropriate.'
This emphasis on bringing forward brownfield sites 'nearby' Category 3 settlements is supported. This approach would provide a more flexible approach and would enable sites such as our client's site to come forward.
We wish to participate in the Examination to set out the case that additional sites should be allocated in and near to Ingrave, a sustainable, Category 3 settlement.

RE: Site Assessment Methodology and Summary of Outcomes - Working Draft (2018)
The spatial strategy, as set out at paragraph 3.13, focuses upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with paragraph 137 of the NPPF, which requires that:
'Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.'
However, we do not consider that the capacity of brownfield sites has been fully explored. The Stage 2 assessment process discounts sites where they are considered to be in an unsustainable location, (which included sites in the Green Belt with no connecting boundary to an existing urban area,) before considering the potential to use brownfield land. This has resulted in sites such as site 183, our client's site, being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable.
Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. Residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail.
Paragraph 103 of the NPPF acknowledges that:
"opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision taking.'
Paragraph 102 also states that:
'Transport issues should be considered from the earliest stages of plan-making and development proposals, so that c) opportunities to promote walking, cycling and public transport use are identified and pursued.'
Figure 4.2 of the Plan sets out how different types of land use will contribute to how the overall housing need will be met. The Plan's spatial strategy is unsound because it excluded all sites which do not meet the distance thresholds from existing settlements, and has not fully taken into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
In light of the higher housing numbers required, the Plan should be revised to re-assess all sites which do not meet the distance thresholds from existing settlements, and to take into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
We wish to participate in the Examination to set out the case that a further assessment of sites is required, and the opportunity should be taken to re-assess sites which were previously excluded.


RE Spatial Strategy
The draft Plan relies on the delivery of strategic sites, to meet a significant proportion of its housing requirement. Figure 4.2 of the Plan identifies that the Dunton Hills Garden Village strategic allocation will provide 35% of the total housing requirement. We note that in the Regulation 18 document, three strategic sites were proposed; this has now increased to five.
We object to the strategy relying on several large developments to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. As set out in Appendix 1, this strategy results in the delivery of no new housing in the early years of the Plan.
Paragraph 68 of the NPPF notes that:
'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare.'

The Plan should be reviewed and sites identified to meet the higher housing number of 547 dwellings per annum, through the addition of smaller site allocations. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have fewer complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver.
Allocating additional smaller sites will have multiple benefits; it will increase the flexibility of the Plan, it will contribute to the five year housing land supply, it will enable sites which do not require significant infrastructure provision to come forward quickly, and it will attract smaller house building companies who will not be present upon larger strategic sites.
To set out the case that the Plan should allocate additional, smaller sites, to improve the flexibility of the Plan, to ensure that the Plan complies with the NPPF, and to enable the Plan to deliver homes throughout the Plan period.

The issues listed shows that the modification would be to remove sets R25 and R26 from the plan. Blackmore Village Heritage Association has produced a plan which should be referred to by the planners. The Plan sets out our local housing needs for our community.

LDP Fig 2.3 Settlement hierarchy
LDP Section 04 (management growth)
Policies:
SP01 - D
Paras 4.6 4.9 4.20
Policy SP02
Policy SP04 - A
LDP Section 06 (housing provision)
Policy HP 08
Section 08
Natural Environment
Policy NE 06 paras 8.51 -8.64; Para 8.85 (IV); Para 8.90; Para 8.101
Policy NE13
Section 09 site allocation
Policy R25 para 9.197 -9.200
Policy R26 paras 9.201 - 9.204
LPP Fig 2.3 settlement hierarchy. There are errors in the plan, population states 829 but does not include houses past Red Rose Lane or the residents in Chelmsford Road and Traveller site.
Duty to cooperate. Not enough consultation with neighbouring authorities.
Red Rose Lane is single track and wont cope with more traffic
Flood Risk
Policy NE06 Flood Risk 8.52
Infrastructure requirements - no infrastructure improvements have been listed in R25 or R25. The local school is at capacity with no room for more children.
The doctors is too at capacity, waiting times are bad already.
Electricity and services wont be able to cope with 70 extra houses.

Amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

BRENTWOOD LOCAL PLAN
REGULATION 19 CONSULATION REPONSE
ON BEHALF OF
BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION

1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')

Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.

3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.

4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.

5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1. Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2. Without prejudice to the above contention, if no such sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3. In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4. Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.

7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).

8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

Background

9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.

10. Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle.
In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.

11. The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.

12. In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.

13. Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.

14. Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).

15. Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).

16. The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over 300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.

Issues concerning Consultation and Consistency

17. It is a maxim that "good planning is consistent planning".

18. The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".

19. In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.

20. It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.

21. More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver selfsustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.

22. There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.

23. The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.

Evidence Base

24. Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.

25. Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).

26. Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.

27. The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.

28. There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.

Sustainable Development

29. It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.

30. The proposed allocation of sites R25 and R26 meets none of these objectives in that:
30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school is at capacity sending additional village children to school elsewhere will further erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.

31. There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.

32. Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.

Green Belt

33. Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134 NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.

34. The NPPF further confirms that, once established, Green Blt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.

35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.

36. In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.

37. Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt. Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.

A Settlement Category 3 village?

38. As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because:
38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in Doddinghurst (which is ~3 miles away and on roads not suitable for walking); and
38.3. There are no, or very few, local jobs. Of those of working age nearly all commute out of the village.

39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.

40. Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.

41. This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.

42. Simply put, the Parish Council and BVHA say that the classification of, and proposed
housing allocation in, Blackmore is incorrect.
Other

43. The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.

44. The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.

45. The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.

46. The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.

Summary/Conclusion

47. The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

48. Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.

49. Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.

50. Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.

51. The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

52. There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).

53. The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

54. The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

55. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

HOLMES & HILLS LLP
Dated 18 March 2019
 
Appendix One - Redrose Lane PHOTOS

Redrose Lane from Chelmsford Road junction Redrose Lane from Nine Ashes
Road junction
Further image of Redrose Lane - note Above: image illustrating width (or lack
cut-up verges and lack of centre lines of) of Redrose Lane
(i.e. delineating insufficient width for two
vehicles to pass)

Appendix Two - re R25 and R26 as Important Habitat sites PLUS PHOTOS


Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard
Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite,
Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge
sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding
season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1-
list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority
for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/ukconservation-
status-explained/
Above: Owl on Site R25/R26 Above: Sparrowhawk in adjacent
garden
Turtle Dove - video:
IMG_8370 turtle
dove.MOV
Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Above (both): Great Crested Newt in "composting bin" in neighbouring garden to R26
Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-andthe-
law
They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible
nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view


Appendix Three - Agricultural Land Assessment and Flooding/Flood Risk

Map extract - ECC
Flood risk map 2018 (source - Essex County Council website - "check if you are
at risk of flooding" - with annotations)

Above: Chelmsford Road flooding- 1987 Above: Redrose Lane flooding - 1987

Above: Flooding on The Green - 2016 Above: Flooding on Redrose
Lane - 2016 (note depth of water)


Above: Chelmsford Road flooding - Above: Redrose Lane flooding -
23 June 2016 (n.b. next to site R26) 23 June 2016

Above: Redrose Lane - March 2018

Extract from Daily Telegraph re 2011 Flooding:

Extract from Express re 2011 Flooding:

A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday newspaper article inc photo
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road. (see picture below)
Extract from Romford Recorder re 2011 flooding: including an incident where a person had to be rescued from their car in Red Rose Lane, Blackmore.