It is considered the Brentwood Draft Local Plan and supporting evidence base will require further major revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Brentwood Local Plan should be reviewed to take account of the outcome of testing of other spatial options being considered including the evidence by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

Further work is required to develop the evidence base including the justification for the selection of the spatial options and dismissal of reasonable alternatives, housing capacity and supply further transport evidence and other infrastructure.

Due to the issues highlighted in this response and to the earlier documents it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production. It is recommended that the Brentwood Plan with its current spatial strategy and site allocations should not be submitted for Examination.

The Brentwood Local Plan states in its vision that Brentwood is regarded as a collection of villages (including the proposed Dunton Hills Garden Village). The overall approach of the spatial strategy is to focus growth along two Transit Corridors in the borough at the Central Brentwood Growth Corridor/A12 and the South Brentwood Growth Corridor/A127.

Therefore the overall spatial strategy remains largely the same as the approach set out in the 2016 draft local plan and the 2018 Preferred Site Allocations consultation with development concentrated on land within the borough's transport corridors with Brentwood and Shenfield the main focus of development in the A12 corridor and strategic allocations in the A127 corridor at Dunton Hills Garden Village (35% housing Supply) and Brentwood Enterprise Park (58% of additional employment land). However the revised strategy restates maximising brownfield development and sustainable urban extensions in the transport corridors but also introduces limited growth at larger villages and reinforces the role of a new settlement at Dunton Hills Garden village including the potential for additional dwelling capacity at a later stage or beyond the plan period (up to 4,000 dwellings).

Thurrock Council has previously objected to the spatial strategy through its various iterations in previous stages of Brentwood Local Plan consultation and those objections remain. It is unclear why the spatial strategy should advocate a free-standing greenfield settlement in the Green Belt and why this should be the preferred location for development compared to existing settlement expansion or green field urban extensions which are likely to be more sustainable, less constrained and are closer to existing transport and other existing infrastructure and services.

The development of the Brentwood Local Plan spatial strategy appears to have:
* not considered a suitable range of reasonable alternative options that are easier to deliver and/or less constrained;
* put forward a large free standing settlement at Dunton Hills at an early stage which has pre-determined the spatial approach without being supported by the evidence;
* not assessed reasonable options for a free standing settlement or large scale settlement expansion elsewhere in the borough that should have been tested through local plan development evidence and SA process;
* developed a spatial strategy without key elements of the evidence base including land availability transport assessment;
* not taken account of the emerging spatial options being pursued by the adjoining authorities such as Thurrock and through the joint work of the South Essex authorities.

The Pre-submission local plan sets out the current position with regard to proposed housing supply with a total provision identified of 7,787 dwellings of which 6,088 dwellings are the proposed allocated sites and with Dunton Hills Garden Village allocation representing 35% of the Brentwood housing supply. This is a slight reduction is supply compared to the previous Preferred Options consultation stage.

Brentwood Council have produced a Housing and Economic Land Availability Assessment (HELAA) that identifies sites with just over 14,000 dwelling capacity that are deliverable and developable. It is unclear therefore why 35% of Brentwood's housing supply is focused on one large scale development in the very south of the borough.

A Site Assessment Study has been produced in 2018 that sets out how sites have been selected for inclusion as allocations. However it is also not fully clear how the sites for proposed allocations have been included and others discounted. Further evidence is required to understand why the proposed allocated sites are considered suitable and other potential allocations dismissed including using the existing evidence by undertaking updates to the land capacity and supply and further information provided from Green Belt review, landscape and infrastructure studies.

Thurrock Council remains concerned with regard to the spatial strategy and the levels and distribution of growth proposed between the A12 and A127 corridors and considers that Brentwood Council has not thoroughly tested reasonable alternative options or appropriately evidenced the spatial strategy in the pre-submission plan compared to alternatives. Thurrock Council also remains concerned about the identification and impact on the Green Belt of the proposed free standing Green Belt settlement of Dunton Hills Garden Village (DHGV). In addition limited new or updated evidence has been made available to demonstrate the deliverability or viability of such a scheme.

Thurrock Council considers that a more appropriate spatial strategy could be a variation of the previous spatial options with growth including Green Belt release concentrated in the A12 Brentwood/Shenfield corridor including at Ingatestone but with some potential along the A127 corridor including Green Belt release at West Horndon.

Further specific issues on the spatial strategy are set out below. This response should also be read in conjunction with comments submitted at the previous stage Growth Options consultation and the separate Dunton Garden Suburb Consultation.

A12 Corridor.
Thurrock Council considers there is further significant potential to provide housing and other development in the A12 Corridor Broad Area including the potential for urban edge expansion of settlements. Areas to the north of Brentwood and north, east and south east of Shenfield and Pilgrims Hatch south of Hutton and development of Ingatestone should be subject to further consideration for edge of settlement expansion as part of a Green Belt Review. It is considered due to the size and extent of the Green Belt in these locations that a limited number of urban expansions are less likely to have a significant harm to the openness of the Green Belt than locations in other broad areas.

The suggested A12 corridor locations have good existing transport services and community infrastructure and open space. The locations are also within reasonable distance of the railway stations.

Thurrock Council considers the role and potential economic and housing benefits of Crossrail in particular with regard to development at Shenfield have not been fully assessed and incorporated into the emerging Brentwood Local Plan, either as part of the current stage or previous consultations.

It is suggested that the role and development of Brentwood and in particular Shenfield as a terminus of Crossrail should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the undersupply of housing requirement currently identified in the Brentwood Local Plan options and supporting evidence.

The A12 widening and delivery of Crossrail will bring about significant increased capacity and accessibility improvements to transport infrastructure for Brentwood in the A12 Broad Corridor during the later-part of the plan period. This will make the A12 Corridor broad area more suitable for development opportunities.

There is also concern as regards the limited level of detail for the evidence base assessing the transport impacts of the various spatial strategy options and a detailed housing, economic and transport assessment of the impacts of Crossrail and with particular reference to Shenfield.








A127 Corridor

Thurrock Council remains concerned about the proposal for any large scale Strategic Green Belt releases either at Dunton Hill Garden Village or the previous option for the Dunton Garden Suburb. There does not appear to be a sufficiently robust evidence base to justify the development.

Dunton Hill Garden Village/Dunton Garden Suburb
Reference is also made below to the key Thurrock concerns regarding the free standing Dunton Hill Garden Village proposal (that are also covered in other representations) including:
* The Justification for such a free -standing settlement in this location;
* Significant impact and harm to the openness of the Green Belt;
* Coalescence of settlements;
* Detrimental impact on the Landscape;
* The lack of certainty regarding the deliverability of the development;
* Lack of detail on location and phasing of such a development;
* Lack of detail on the viability of such a proposal;
* Impact of the scale of development on adjoining housing markets and ability of Thurrock to deliver its housing;
* Infrastructure delivery and funding;
* Impact on strategic highway network - A127, A128, A13;
* Impact on the local highway network including within Thurrock;
* Lack of comprehensive transport modelling and mitigation measure;
* Assumptions and scoring in the SA/SEA.

Green Belt Issues on the A127 Corridor
The Brentwood Pre-submission Local Plan of 2019 identifies there are several sites for development of brownfield land and Green Belt release along the A127. It is considered that brownfield redevelopment and a Green Belt release at West Horndon would represent a suitable scale of housing development in this location.

It is considered any larger strategic Green Belt development at Dunton Hill Garden Village or the Dunton Garden Suburb or in combination with other development will have significant harm to the openness and function of the Metropolitan Green Belt. The Green Belt west and east of West Horndon meets the purposes of the Green Belt including preventing urban sprawl and coalescence between Basildon and West Horndon in the east and from West Horndon westwards to Cranham and Upminster in London.

The Dunton Hill Garden Village would result in a significant Green Belt release leaving a limited gap between Basildon and West Horndon. Any significant urban extension west of Basildon together with the Dunton Hill Garden Village would also result in potential coalescence and urbanisation of the A127 corridor resulting in significant harm to the openness and strategic function of the Green Belt.

Further Green Belt releases for employment land (Brentwood Enterprise Park) at Junction 29 of the M25 with A127 taken together with a strategic release for housing at Dunton Hills Garden Village will also contribute to a cumulative impact on the openness of the Green Belt in this corridor.

Road Capacity and Impact
The A127 is at capacity at peak times and does not represent a better road transport alternative to the A12. Any larger development is going to require additional road infrastructure investment to improve access. It is noted that further work to assess the capacity and improvements is required to be undertaken by the Local authorities and Essex County. This information should have been available at the pre-submission stage of the plan. In terms of the impact on the A128 there are key maintenance safety mitigation measures that have not been properly identified or addressed.

Employment Provision - Brentwood Enterprise Park
The Brentwood Plan and supporting evidence identifies the requirement for additional employment land. However it is unclear why the employment sites at Brentwood Enterprise Park (Site ref E11), Land at East Horndon Hall (site ref E13) and at Dunton Hills Garden Village (site ref part R01) are proposed in the draft Local Plan. It is not always the case that employment land should be located at busy junctions or along the A127 corridor where it would add to traffic flows on a road at current capacity. The sites are not located close to existing centres and are without easy access for workers other than by car. Alternative locations and options should be investigated including the A12 corridor possibly as part of edge of settlement expansion and in mixed use schemes.

No modification would address my concerns. The only plausible form of action is to stop the current Local Plan and protect the modest green belt that is left in Blackmore. More suitable sites should have and could have been identified.

I consider the Local Plan to be unsound because:-

1.There is no clear 'strategy' for the Villages, including Blackmore, in the north of the Borough

2. BBC has not consulted adequately with neighbouring authorities, e.g. Epping Forest District Council (and the construction of c.30 dwellings at the top of Fingrith Hall Lane, and its impact on the Village)

3. The principle of residential development off of Red Rose Lane is wrong - Blackmore is an isolated village with modest services and infrastructure.

4. There are other more suitable (and / or sustainable) locations - e.g. urban extension to Brentwood - and so the locations in Blackmore do not promote sustainable development

5. BBC has not demonstrated that there are other brownfield sites that are available and which should take priority over the greenfield (and Green Belt) land off of Red Rose Lane

6. BBC has failed to demonstrate that the required housing could not be met by increasing housing density on other (allocated) sites

7. There has been no 'Housing Needs Survey' to demonstrate why Blackmore is included in the LDP

8. The access off/from Red Rose Lane is entirely unsuitable for this volume of traffic movements

9. The proposed sites are liable to flood, and building on this land will also increase the flood risk elsewhere in a village that can be prone to severe flooding.

10. The local services including Doctors surgery waiting times, limited parking and local schools are already struggling to meet the demands of the existing Blackmore Population. Increasing this would be adding to this problem.

11. The impact on local wildlife e.g. adders, slowworms, grass snakes, great crested newts, voles and a variety of birds.

No modification would address my concerns. The only plausible form of action is to stop the current Local Plan and protect the modest green belt that is left in Blackmore. More suitable sites should have and could have been identified.

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.

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.

To ensure the Local Plan is sound, land should be allocated to ensure the sustainable growth of Hutton.

Introduction and Background
1. These representations on the Brentwood Borough Proposed Submission Local Plan (February 2019) (PSLP) are submitted by Strutt and Parker on behalf of Turn2Us and in relation to land at Rayleigh Road, Hutton.
2. Land at Rayleigh Road, Hutton ('the Site') is also known as Land to the East of Hutton Village, Hutton as part of the Council's plan-making process, and is site reference 219.
3. The Site has been actively promoted by Turn2Us (including under their previous name of Elizabeth Finn Care Trust) throughout the plan-making process. Previous representations have been made at various stages of the Local Plan, including in relation to call for sites exercises and consultations on iterations of the Local Plan.
4. Turn2Us are the freeholder of the majority of the area of land between Hutton Village, Rayleigh Road and Church Lane. A small portion of this land, located immediately adjacent to the existing settlement and adjoining Rayleigh Road and Hutton village, measuring 2.4 ha is being actively promoted by Turn2Us for residential allocation in the Council's new Local Plan.
5. A location plan for this site is provided as Appendix A.
6. In addition, discussions with the Council through the plan-making process established that there is a need for the Local Plan to identify suitable sites to accommodate extra care accommodation (Use Class C2) to meet local needs. Consequently, a larger site within the location of Rayleigh Road, Hutton - suitable to accommodate both extra care accommodation (Use Class C2) and residential development (Use Class C3) was also put forward for consideration. This site was also submitted to the Council for consideration and was appended to our representations at the Regulation 18 stage. For completeness, a copy of this site plan is provided here again as Appendix B.
7. Neither the Site nor the wider land including potential for Use Class C2 accommodation are identified for allocation in the PSLP. Their rejection is considered unjustified, and to result in a PSLP which does not promote sustainable development.
8. By way of background, Turn2Us is a national, registered charity with a mission to fight poverty in the UK and Ireland, helping individuals who are struggling financially to gain access to financial help. Each year the charity assists several million people in a range of different ways. It has seen a steady increase in the number of people turning to the charity for help in recent years.
9. The charity receives no Government funding. It is through donations and legacies that it raises funds, and the charity is committed to ensuring long-term financial sustainability. Following careful implementation of its financial sustainability plan, in 2016/17 Turn2Us delivered its first deficit-free result in a decade. Turn2Us is a not-for-profit organisation, and net income is directed to providing assistance to those in need.
10. As part of efforts to ensure the financial sustainability of the charity, Turn2Us has been reviewing its assets and their potential to assist the charity. Such assets include land at Rayleigh Road, Hutton. The potential for this Site to sustainably help meet housing needs is considered mutually beneficial to the Council, Turn2Us, and the wider community.
11. The Charity's holdings have been promoted for residential development and an extra care scheme to complement the care home opposite the site. The extra-care facility would provide employment at a range of skill levels, benefiting the immediate area and the district. Further, the holdings are not proposed for allocation in full and a majority of the promoted site could be made available to a public body to safeguard the land as public space. This would be a significant benefit to Hutton but such possibilities have not been fully considered in the preparation of the PSLP and in regards to achieving its objectives.
Plan Period
12. The proposed period runs until 2033. Assuming - optimistically - adoption in 2019 this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption.
13. This deficiency in the PSLP is of particular relevance given that the Borough is predominantly Green Belt, and failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt: its permanence (NPPF, paragraph 133).
Total housing requirement
14. At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12, it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying PPG).
15. However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.1
16. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum.
17. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years).
18. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need.
19. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum.
20. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
21. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities.
22. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional year's worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for.
23. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest the PSLP that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period.
Five-year housing land supply and housing trajectory
24. The Council is required to demonstrate a five-year housing land supply at any point in the plan period2.
25. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.3
26. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied.
27. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years.
28. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
29. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
30. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
31. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply.
32. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward.
33. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings).
34. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
35. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan.
36. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
37. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this before development has even begun.
38. As such, it is totally unrealistic to project that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound.
Specialist accommodation for an ageing population
39. At paragraph 6.6, the PSLP rightly recognises that the Borough has an ageing population. At paragraph 6.7 it states that the Government position is that older persons should remain at home rather than enter residential facilities (Use Class C2) where appropriate.
40. However, what the PSLP fails to appropriately recognise and address is that for some people specialist accommodation or Use Class C2 accommodation will be more appropriate or necessary. It must be recognised that 'older people' is not a homogenous group, but a term that encompasses people with greatly varying accommodation requirements.
41. The NPPF (paragraph 50) requires Local Planning Authorities to plan for a mix of housing having regard to the needs of different groups, including older people. It goes on to state that Local Planning Authorities should identify the range of housing required in particular locations.
42. The PPG4 describes the need to provide housing for older people as critical, given the increase in this part of the population. It stresses that older people will have diverse needs, ranging from active people approaching retirement to the very frail elderly. The PPG confirms that Local Planning Authorities will need to determine the needs of people who will be approaching or reaching retirement as well as older people now. It suggests that future need for specialist accommodation for older people be broken down by tenure and type (e.g. sheltered, enhanced sheltered, extra care, registered care) may need to be assessed.
43. Notwithstanding the requirement of the NPPF and PPG, and the acknowledgment within the PSLP that this issue of accommodation for an ageing population is pertinent to the Borough, we have not been able to identify any evidence of how the accommodation needs for older people have been assessed as part of the plan-making process.
44. The PSLP proposes care homes through residential development within strategic housing allocations at Land at West Horndon Industrial Estate (Policy R02); Land north of Shenfield (Policy R03); Ford Headquarters and Council Depot (Policies R04 and R05). These are proposed to provide, in total, 180 beds of Use Class C2 accommodation.
45. In the absence of an assessment of need, it is unclear if this will meet need in quantitative terms.
46. Furthermore, we note that all of this provision is proposed on strategic allocations. As such, there will inevitably be relatively long lead-in times to their delivery. As such, we question whether the PSLP as currently drafted will ensure provision in the short-term.
47. The PSLP also suggests that there is "potential" for provision of a care home of around 40 beds as part of the proposed residential allocation at Policy R19 for 75 dwellings. However, the policy provides no certainty this will be delivered.
48. In respect of the allocations proposed to incorporate Use Class C2 development, it is unclear if the land is available for this type of development.
49. Policy HP04 of the PSLP states that the Council will "encourage" provision of specialist accommodation, subject to a number of criteria. However, it is not clear how much specialist accommodation, where, or how this will be delivered.
50. Without amendments, the PSLP is considered unsound in relation to its approach to meeting the accommodation needs of an ageing population. The approach is neither positively prepared, consistent with national policy, nor effective. In order to make the PSLP sound, we suggest the Council should identify the need for specialist accommodation, and allocation deliverable site to meet this.
Proposed Approach to Hutton
51. Hutton is the second largest settlement in the Borough.
52. In 2011, the town had a population of 15,578 and a total of 6,564 dwellings (Census 2011). It is a large, established community and a local centre which benefits from a range of services, facilities, access to public transport, and employment opportunities.
53. Hutton is situated approximately 30 kilometres from Central London, 12 kilometres from Chelmsford and in a position well related to regional and national infrastructure. Hutton lies in close proximity to Brentwood and Shenfield on the A12 corridor.
54. Hutton has strong service and education provision. The settlement benefits from excellent access to Shenfield High Street on the Hutton Road which adjoins Rayleigh Road and runs centrally through the settlement on an east-west axis. The High Street provides a variety of services, shops and businesses.
55. The PSLP sets out the Borough's settlement hierarchy. Hutton is identified as Category 1 - Main Town.
56. It is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. In addition, as an established community, it is important that the Local Plan manages the growth of the settlement to ensure the vitality of the community is sustained or enhanced.
57. However, notwithstanding the above, the PSLP proposes to direct no housing growth to Hutton. This contrasts sharply with the proposed approach to the other settlements identified as Category 1 - Main Towns. It is also notable that a considerable amount of growth is being directed to settlements below Hutton within the settlement hierarchy.
58. The PSLP fails to support the sustainable growth of Hutton. The proposal to direct none of the Borough's housing need to Hutton is unjustified, and inconsistent with national policy.
59. To ensure the Local Plan is sound, land should be allocated to ensure the sustainable growth of Hutton.
The Site
60. The Site measures 2.4 ha in area and is low quality grazing land used as paddocks. As such it principally comprises open pastoral grassland of low landscape value. It is located in the north-western corner of the Hutton Conservation Area, to which it could not be said that the site makes a positive contribution.
61. The Site is roughly triangular in shape, and constrained to the west, south-west, and east by existing development, and to the north by the A129 Rayleigh Road.
62. The Site is on land currently allocated as Green Belt in the Brentwood Replacement Local Plan (2005), but is situated immediately adjacent to the settlement boundary of Hutton.
63. A considerable amount of technical work has been undertaken in respect of land at Rayleigh Road, Hutton and previously submitted to the Council through previous stage of the plan-making process. This technical work demonstrates the Site is sustainable, suitable, available and achievable site to help meet the Borough's housing need. Work undertaken, and previously provided by included here again for completeness, includes:
* Green Belt Appraisal prepared by Lockhart Garratt (Appendix C)
* Heritage Assessment prepared by Terence O'Rourke Ltd (Appendix D)
* Site Opportunities and Constraints plan prepared by Go Planning Ltd. (Appendix E)
* Site Master planning prepared by Go Planning Ltd. (Appendix F)
* Landscape Assessment prepared by Lockhart Garratt (Appendix G)
* Tree Constraints and Opportunities Report prepared by Lockhart Garratt (Appendix H)
* Ecological Constraints and Opportunities Report prepared by Lockhart Garratt (Appendix I)
* Access Appraisal prepared by Journey Transport Planning (Appendix XX)
* Delivery Statement (Appendix J)
64. Within previous submissions to the Council, we have set out the sustainability of land adjacent to Rayleigh Road, Hutton for residential development, and an overview of these is provided again here, as follows.
65. There are three dimensions to sustainable development: economic; social and environmental.
66. In terms of economic impact, there is an inherent link between providing homes and the creation of jobs. Benefits of the site's development include additional local expenditure in and around Hutton from the additional residents. The intention for the land adjacent to Rayleigh Road, Hutton is to provide homes for people working in and around the Hutton area, assisting in local economic development.
67. The body of environmental consultancy work including detailed landscape appraisal, arboricultural investigations, ecological surveying and site master planning previously submitted to the Council have confirmed that the site can be brought forward for development without undue harm to the environment. Development of the site will reduce pressure to accommodate development on potentially more environmentally sensitive sites.
68. In respect of social impacts, the land adjacent to Rayleigh Road, Hutton is very well connected to local service provision with the majority of Hutton and Shenfield's services within a 2km radius of the site. In addition, the site benefits from excellent public transport links. The provision of homes to meet housing needs will have very significant social sustainability benefits.
69. Notably, the Council's evidence base supports the view that the Site is suitable, available and achievable for development, as confirmed by through by the assessment of the Site within the Brentwood Borough Council Housing and Economic Land Availability Assessment (October 2018) (HELAA). The HELAA projects the site can be delivered in years 1-5, and we concur with this view given the relatively small scale of the proposed development and the lack of constraints to delivery.
Strategic Environmental Assessment / Sustainability Appraisal (SEA/SA)
70. The Environmental Assessment of Plans and Programmes Regulations (2004) requires SA/SEAs to inter alia set out the reasons for the selection of preferred alternatives, and the rejection of others, be made set out.
71. In addition, the Planning Practice Guidance5 makes clear that the strategic environmental assessment should outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives.
72. Sustainability appraisal of the PSLP has been published: the Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA).
73. Site 219 is one of the 'shortlisted omission sites' in the SA, but did not progress to the final shortlist.
74. The SA explains that a number of sites were identified through the HELAA that were considered developable or deliverable, but are nevertheless not proposed to be allocated in the PSLP.
75. Table A of the SA provides commentary on these shortlisted omission sites. Of relevance to Site 219 it states:
"Hutton Village Conservation Area (CA) comprises the land to the south of the A129, stretching as far south as Hutton Hall and All Saints Church. Two shortlisted omission sites (HELAA 219, 317) comprise the areas of open land; however, both are heavily constrained in heritage terms. Maintaining the landscape gap between Hutton (Brentwood/Shenfield) and Billericay is a further consideration".
76. No details are provided to explain in what way Site 219 is heavily constrained in heritage terms.
77. In contrast, at the Regulation 18 stage consultation, a detailed Heritage Assessment was undertaken by Terence O'Rourke Ltd in respect of this site, and submitted as part of the plan-making process. It is provided again here for completeness (Appendix D).
78. As the Heritage Assessment notes, the site is located within the Hutton Conservation Area. The Heritage Assessment considers the character of the Conservation Area in detail, heritage assets within the locality, and the potential for development to be accommodated on the site without harming the character or significance of these.
79. The Heritage Assessment identified the following key characteristics of the Conservation Area, which would need to be taken into account in the consideration of the development of the site:
80. The survival and legibility of the historically dispersed pattern and the separate development areas.
81. The contrast with the modern development to the west of Hutton Village, which creates a very clear distinction between the conservation area and its setting, with no blurred boundaries.
82. The distinctive road layout allows extensive views within and across the parkland at the centre of the Conservation Area.
83. Trees within house plots and along boundaries are effective in screening the existing development including the large buildings of the care home in views across the parkland from the south.
84. The band of trees and stables to the rear of Hutton Court creates a division and gives the northern triangle of land a weaker parkland character.
85. The estate cottages and the linear group at Hutton Village are a possible model for new development.
86. The Heritage Statement suggests detailed appraisal of any future proposals for development within the Conservation Area by design and heritage advisors be used to inform the details of the future development of the site.
87. The Heritage Statement concludes that the site is capable of accommodating varying forms of development that in themselves would not result in harmful change to the significance of the Conservation Area. The acceptability and degree of change would have to be subject to careful consideration of layout and design, but it is clear that heritage issues are not a reason to reject outright the development of the site or its allocation in the Local Plan.
88. This detailed evidence from the Heritage Assessment has been provided to the Council, and we are not aware of any assessment of equivalent detail which contradicts its findings.
89. Having regard to all of the above, heritage concerns do not justify the rejection of the Site.
90. The SA also makes reference to maintaining a landscape gap between Hutton (Brentwood / Shenfield) and Billericay, though this is not expressed as a reason for rejection, nor does it appear to have been a determinant factor in the decision not to allocate the site.
91. However, for completeness, it should be recognised that the Green Belt Assessment Part 3 produced in respect of the Local Plan confirms that development of the site does not give rise to concerns in respect of coalescence of settlements. Green Belt issues are discussed further, later within this representation.
92. In short, the SA does not provide a justified reason for the rejection of the Site.
93. Turning to the specifics of the SA assessment of the Site, these are set out in Table C of the SA. This provides a 'traffic light' assessment of sites' sustainability. Green indicates sites perform well; amber poorly; red particularly poorly, against specific criteria.
94. Our first point in relation to the approach taken is that it is very simplistic - the assessment of sites appears to be based purely on physical distance to various features / facilities / designations.
95. For example, in relation to criteria 10 (Conservation Area) a site is considered to automatically score 'particularly poorly' if it intersects with a Conservation Area. There is no evidence that any consideration has been given as to whether a particular Conservation Areas is particularly sensitive to development (in many instances (e.g. town centres) Conservation Areas will be very much sustainable locations for development, provided development is implemented sensitively); or how development may impact on a Conservation Area. There may be cases where development could enhance a Conservation Area. Indeed, and somewhat confusingly, the SA acknowledges itself within Table A and in relation to cultural heritage, that it will also sometimes be the case that development can enhance heritage assets.
96. In respect of Site 219, it is deemed to perform particularly poorly in relation to criteria 10 (Conservation Area) due to it being located within a Conservation Area. As noted earlier, in the case of the Site, a detailed Heritage Assessment has been undertaken which confirms that heritage issues do not render the Site unsuitable for development.
97. We would also comment that it is unclear how the SA scoring has been used in decision-making, given that Site 219 has been assessed within Table C as more positive than a number of sites which are proposed to be allocated. It is not clear what weight has been applied to the different criteria.
98. The only other criteria against which the SA assesses the site as performing poorly is criteria 7 (GP surgery). Again, as with other criteria, assessment is based purely on physical distance. It is clear that this alone is a determinant factor, as there are other sites which are also measured as being over 1.5km from a GP surgery, but which are proposed to be allocated.
Green Belt
99. A detailed Green Belt Appraisal was prepared in respect of the Site by Lockhart Garratt and submitted at the Regulation 18 stage consultation. A copy is provided again here, for completeness (Appendix C).
100. The Green Belt Appraisal considers the contribution of the site in relation to the five purposes of including land in the Green Belt, as per paragraph 134 of the NPPF:
101. To check the unrestricted sprawl of large built-up areas:
* To prevent neighbouring towns merging into one another;
* To assist in safeguarding the countryside from encroachment;
* To preserve the setting and special character of historic towns; and
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
102. The Green Belt Appraisal provides a thorough review of the site in relation to these purposes, and concludes that the site does not perform as Green Belt land as defined by national policy. It is therefore, the Appraisal finds, "not suited to being included within the geographical extent of the Metropolitan Green Belt" (paragraph 5.3.2).
103. The Green Belt Appraisal further concludes that the removal of the site from the Green Belt and its subsequent residential development would not:
* Cause undue harm to the setting of Hutton;
* Lead to settlement coalescence; or
* Diminish the wider character of the Metropolitan Green Belt.
104. A Part 3 Green Belt Appraisal (dated 31 January 2019) has been published by the Council. This considers specific sites, albeit in limited detail. Site 219 has been assessed through the Part 3 Green Belt Appraisal.
105. There is no evidence that the findings of the Green Belt Appraisal that was produced in respect of the Site by Lockhart Garratt, and which considered the Site in far greater detail than the Council's Part 3 Green Belt Appraisal, have been taken into account.
106. We are concerned with the simplistic approach that appears to have been taken in considering the contribution sites make to the purposes of the Green Belt. For example, in relation to Purpose 3 (to assist in safeguarding the countryside from encroachment) the methodology states that where the majority of the existing land use is considered an appropriate land use with regard to Green Belt policy, and which contribute strongly to the functional countryside, such land will automatically be regarded as functional countryside. Such a finding then appears to contribute to a site being found to a high overall contribution to the purposes of the Green Belt. This approach to Green Belt assessment contrasts to that undertaken by Lockhart Garratt in respect of the Site, which - taking the consideration of Purpose 3 again by way of example - examines the relationship between the Site and the existing settlement in far greater detail, resulting in the provision of information which is of far greater use for the purposes of plan-making.
107. The Lockhart Garratt Green Belt Assessment provides a far more detailed and robust review of the Site's contribution to the purposes of Green Belt than that published by the Council, and should be considered as part of the plan-making process.
108. In addition, we note that despite the Council's Part 3 Green Belt Appraisal stating that Site 219 has "little or no relationship to historic town" on the first page of the Site's assessment. However, on the second and final page of the assessment it concludes that the Site has a "Strong Relationship with Historic Town (SHRT)", which appears to have contributed to the Site being found to have a moderate / high overall contribution to the purposes of the Green Belt. This is clearly an error.
Overview
109. The Council's own evidence base states that Site 219 is suitable, available and achievable for development. Development of the site is supported by a wealth of technical evidence that confirms its suitability, including in relation to the lack of harm to its development to the purposes of the Green Belt.
110. The reasons given for the rejection of the Site are spurious and based on erroneous conclusions.
111. The rejection of Site 219 is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton.
112. The allocation of Site 219 for development will assist in curing defects in respect of the Local Plan, enabling it to be a sound plan.

A sound local plan would require: 1. The assessment must take into account the modest and limited services in the village, including the shop, doctor surgery, primary school and parking. 2. The character and nature of the village must be carefully considered, and the current residents quality of life must be protected. 3. BBC needs to look at the many other suitable locations in the area which can sustain this type of development. 4. The problems with flooding need to be taken into account and current problems with flooding addressed.

Blackmore is a small isolated village with modest services and infrastructure. The large scale development plan being proposed will, without a doubt, negatively effect the quality of life of its residents. The plan is being proposed by a developer who holds no knowledge of the village itself, which has resulted in a proposal that is completely inappropriate. The facilities in Blackmore are limited and an influx of new residents would be detrimental. The following reasons clarify why: 1. The proposed plan would produce overcrowding, resulting in an unacceptable increase in traffic and noise, destroying the very nature of our village. 2. There is no clear 'strategy' for the village and there are many other more suitable and sustainable locations for development. 3. Parts of the village are liable to flood. Building on the proposed land would increase the flood risk everywhere in the village. 4. There is just one shop in our village, an overcrowded primary school, and a local doctor surgery where it is extremely difficult to get an appointment. Such an increase in residents is simply unmanageable. A sound local plan would require: 1. The assessment must take into account the modest and limited services in the village, including the shop, doctor surgery, primary school and parking. 2. The character and nature of the village must be carefully considered, and the current residents quality of life must be protected. 3. BBC needs to look at the many other suitable locations in the area which can sustain this type of development. 4. The problems with flooding need to be taken into account and current problems with flooding addressed.

I fully agree with the objectives of Blackmore Village Heritage Association.

In my opinion there is no clear 'strategy' for the village of Blackmore. There are more suitable sites and the green belt land does not have to be touched. Building the houses in Blackmore would put unwelcomed pressure on the already very busy doctors, schools, parking and bus services etc.