1) The Local Plan must be adjusted to incorporate previously discounted development sites, particularly in the Central Brentwood Growth Corridor to restore the flexibility in site supply across a broader range of spatial locations, thereby improving the Plan's effectiveness and deliverability. 2) The methodology to the Local Plan's Housing Trajectory needs to be published and open for comment and challenge of its assumptions.

This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Local Plan Regulation 19 public consultation.
Please be advised that for all of the consultation points below, the Council would like to attend the future oral hearings as part of the Plan's Examination in Public.
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for the Basildon Borough that may arise from Brentwood Borough Council's Local Plan and determine whether it considers it to be compliant with necessary legislation and whether it meets the tests of soundness.
1) Is the Brentwood Borough Local Plan 2016-2033 legally compliant?
The Council has reviewed the Brentwood Borough Local Plan 2016-2033 and supporting documents. It considers that whilst it disagrees with aspects of the Plan from a soundness perspective that it is however legally compliant.
2) Does the Brentwood Borough Local Plan 2016-2033 meet the tests of soundness?
The Council does not believe that the Brentwood Borough Local Plan 2016-2033 meets the tests of soundness in all of its policy areas. It therefore makes the following 1 representation in support of an aspect of the Plan and 17 representations where it considers the Local Plan is unsound and requires modifications to make it sound.
Supporting Representations
Consultation Point: Chapter 1
Soundness - Effectiveness & Compliance with National Policy
Paragraph 26 of the National Planning Policy Framework (NPPF) asserts that effective and on-going joint working between strategic policymaking authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, it considers that joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. To demonstrate effective and on-going joint working, strategic policy-making authorities should
planning.policy@brentwood.gov.uk
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prepare and maintain one or more Statements of Common Ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these.
A major step forward for effective cooperation has been the Memorandum of Understanding that was signed between Basildon, Brentwood, Castle Point, Essex County, Rochford, Southend-on-Sea and Thurrock Councils to form the ASELA. This has ensured that there is now a more coordinated, collective working on a 'place vision' for the sub region, which recognises one of the key delivery tools will be a statutory Joint Strategic Plan (JSP). A Statement of Common Ground has also been agreed between the ASELA to ensure it is embedded into the Local Development Schemes of all the local planning authorities with resources committed to its preparation during 2019/2021. This will ensure it sets the foundations for planning at a broader spatial level, determining how growth and infrastructure can be better coordinated to positively influence place-making in South Essex and provide a more prosperous area for people to live, work, study and visit. The Statement of Common Ground recognises that the planning landscape of South Essex is not perfect and not all authorities can wait for the JSP to be completed before their Local Plans are advanced. It accepts that the JSP will have to be mindful, in particular of Basildon, Brentwood and Castle Point's and the reality that their Local Plans are already too advanced to be paused.
The Council has noted Brentwood Council's commitment in paragraph 1.13 to work as a member of ASELA on a process to develop a long-term growth ambition that would underpin strategic spatial, infrastructure and economic priorities across the wider sub-region. It is acknowledged that this is in accordance with the South Essex JSP Statement of Common Ground - June 2018; of which Basildon and Brentwood Borough Councils are one of the seven joint signatories.
Work on the JSP is at an early stage with Regulation 18 consultation due to take place during 2019, followed by Regulation 19 in 2020, with examination in public and adoption not expected to be until 2020/2021. It will cover a longer plan period extending to 2038; slightly longer than both the Basildon and Brentwood Local Plans. Paragraph 1.38 of the Brentwood Borough Local Plan references that its own allocations can contribute towards some of the delivery of early growth during the JSP plan-period; a position that is also applicable for the soon to be submitted Basildon Borough Local Plan 2014-2034. It is welcomed that the Brentwood Borough Local Plan has mirrored the intent of the Basildon Borough Local Plan in Paragraphs 1.35-1.38 that following the adoption of the JSP, it may be necessary to review the Plan, at least in part, to ensure any opportunities for additional growth and infrastructure provision in the Borough, that may otherwise be additionally identified in the JSP, can be realised. The Council fundamentally supports this policy approach as meeting the soundness tests of being a) effective and b) in accordance with national policy.
The Council considers this to be compatible to its own position and underpins the collective efforts to get an "effective mechanism" in place to address strategic, cross boundary matters in a more holistic and planned manner that has greater potential to realise positive outcomes to South Essex communities. Looking ahead, the Council embraces the opportunity presented by Brentwood Borough Council being part of the ASELA and the JSP, in order to tackle strategic, cross-boundary matters holistically to ensure sustainable growth solutions are achieved that benefit all communities.
Objecting Representations
Consultation Point: Whole Plan
Soundness - Effectiveness, Justified & Compliance with National Policy
Paragraph 26 of the National Planning Policy Framework (NPPF) asserts that effective and on-going joint working between strategic policymaking authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. The Council, as a neighbouring Borough and Duty to Cooperate body, has reviewed and considered previous versions of the Local Plan and its preparatory documents and submitted relevant representations under Regulation 18 consultations. The Council formally wishes to express its disappointment that given fundamental
evidence has been 'in development', but not published during much of its preparation. It has been significantly difficult, therefore, to digest the Plan's rationale and approach as it has evolved. This includes the entire Green Belt Review, Housing and Economic Land Availability Assessment, Landscape Sensitivity and Capacity Study, Local Plan Viability Assessment and Transport Assessment which were not published until the month before Brentwood Council considered the Publication Local Plan in November 2018. It is accepted that not all evidence can be completed by each consultation stage and much may remain as a continual draft until Regulation 19, however it is considered this has created a lack of transparency during critical plan-making stages and contributed to the scale of representations from Basildon Council for its Regulation 19 response.
During 2017/2018, officers from Basildon, Thurrock and Essex County Councils, facilitated by an officer from Rochford District Council, jointly sought to understand and address with Brentwood Borough Council how the Brentwood Borough Local Plan, in particular the Dunton Hills Garden Village (DHGV) strategic allocation, could impact on neighbouring authority areas, particularly in terms of infrastructure and service provision. Meetings were held, and correspondence exchanged, in an effort to seek solutions and resolutions to previous Regulation 18 objections/ observations from all three Councils. The intention was to appreciate the evidenced rationale for identifying the DHGV strategic allocation and ensuring neighbouring authorities could engage more effectively to identify and manage cross-boundary impacts. Despite this engagement, it is considered that not all information and assurances sought from Brentwood Borough Council have been provided and this brings into question the soundness of the rationale and choices made in the Brentwood Borough Local Plan.
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As such, all of Basildon Council's previous responses to Regulation 18 consultations are enclosed as supplementary evidence to the Regulation 19 consultation; affirming that many of the comments made in respects this consultation response have been raised previously, but remain unanswered or inadequately addressed. It is uncertain how the Plan has been informed by this previous input. It is considered that this is not a justified approach and has resulted in a Plan which is less effective at tackling strategic, cross-boundary issues.
Consultation Point: SP02: Managing Growth, Paragraphs 4.15-4.16 and Appendix 1
Soundness - Effectiveness, Justified & Compliance with National Policy
It is acknowledged that Brentwood Borough Council commissioned David Couttie Associates (DCA) in 2013 to undertake a Strategic Housing Market Assessment (SHMA) and define its Housing Market Area (HMA). This concluded that Brentwood Borough's administrative area was a self-contained HMA. This is different to the Basildon Borough, which is a sub-area (with Castle Point) of the much larger South Essex HMA, which also incorporates Rochford, Southend on Sea and Thurrock. The Brentwood SHMA, which was most recently updated in November 2018, forms part of the evidence base for identifying the Objectively Assessed Need (OAN) for housing in Brentwood Borough. However, NPPF/2019 (published after the Publication Local Plan was approved by Brentwood Borough Council in November 2018, in February 2019) now requires housing needs to be calculated in accordance with the Standard Methodology set out in national Planning Practice Guidance.
Basildon Borough Council has acknowledged that this has seen the OAN for Brentwood Borough change three times over the course of the last year as follows:
* In January 2018, the Brentwood SHMA January 2018 identified an OAN for Brentwood of 380. This was calculated using the SHMA Planning Practice Guidance that underpinned the NPPF/2012;
* In July 2018, NPPF/2018 was launched introducing the standard methodology for calculating objectively assessed housing need. The standard methodology requires the use of the most recently published household projections as the starting point. At that time, the 2014-based CLG Household Projections formed that starting point resulting in an OAN for Brentwood of 452 homes per annum; and
* In September 2018, 2016-based ONS Household Projections were published, revising the starting point for the standard method calculation. For Brentwood Borough, these projections showed a reduced rate of household growth going forward, resulting in a reduced housing requirement for Brentwood of 350 homes per annum.
It has been noted by Basildon Council that the Brentwood Borough Local Plan uses this latest 2016 projection to define the minimum OAN target.
The reduced rate of household growth in the 2016-based ONS Household Projections was highlighted as a nation-wide issue driving down the OAN calculations in around two-thirds of authorities, although not Basildon. This resulted in the standard methodology only identifying around 215,000 homes per annum supply for England against a national policy target of 300,000 homes per annum. Consequently, in October 2018 MHCLG launched a consultation on technical changes to the standard methodology, seeking for authorities to continue using the 2014-based CLG Household Projections in the interim. On the 19 February 2019, the Government's response to this consultation was published indicating that the Government will be making clear in national Planning Practice Guidance that the 2016-based ONS Household Projections should not be used for the standard methodology calculation, and the 2014-based CLG Household Projections should be used instead.
The Brentwood Local Plan therefore, which makes provision for 456 homes per annum does meet just over its full OAN for housing, having regard to the standard methodology calculation of need based on the 2014 CLG Household Projections (452 homes per annum), as explained in required by Planning Practice Guidance (Paragraph: 004 Reference ID: 2a-004-20190220 and Paragraph: 005 Reference ID: 2a-005-20190220) that has been adjusted following the Government's response to the technical consultation.
The Brentwood Local Plan, however, as drafted and approved by Brentwood Council in November 2018, sets out in Paragraphs 4.15-4.16 that the housing target for Brentwood is set at 350 homes per annum and it proposes an annual housing supply buffer of 20% taking total supply of 456 homes per annum. This was considered at the time as offering additional flexibility throughout the plan period. This is now not the case as the 2016-based ONS Household Projections must be discounted, as above, with the baseline reverting to the 2014-based projections. This results in a Plan which will now have an insignificant flexibility in its land supply; a component which was considered justified and fundamental to the Plan's strategy when it was approved in November 2018.
When this new position is viewed alongside the variable housing target, it is considered this could cause the plan to be less effective and justified. The initial housing target of 310 homes per annum between 2016 and 2023, should, according to the Plan, increase to 584 homes per annum beyond 2023. It is noted that this increase is substantially reliant on the new Dunton Hills Garden Village (DHGV) in the Southern Brentwood Growth Corridor, which according to the Housing Trajectory set out in Appendix 1 is expected to commence housing delivery in 2023/24, within the first five years of the Plan. That scheme is expected to deliver at the initial ambitious rate of 100 homes per annum upwards from thereon, reaching 300 homes per annum by 2026. These are considered to be overly optimistic delivery assumptions for such a large scale Green Belt allocation, which whilst mostly in a single land ownership that could facilitate delivery, still requires for the boundaries of the Green Belt to be amended on adoption of the Plan (assuming it is found lawful and sound), detailed masterplanning, essential infrastructure programming on-site and off-site to ensure sustainable development can be achieved. It is not clear from any published evidence how such a delivery rate has been formulated having acknowledged these issues and therefore this is challenged in terms that it is not justified.
Summary: As a result in the change to the NPPF, the Plan also now has very little flexibility within its land supply should anything happen to cause delivery of homes to become delayed during the plan period; which was a fundamental principle to the Plan's strategy approved in November 2018. There is an unjustified over-reliance on DHGV in the Southern Brentwood Growth Corridor to
contribute towards supply at an accelerated rate. The Council therefore objects to Policy SP02, 4.15-4.16 and Appendix 1
Modification: 1) The Local Plan must be adjusted to incorporate previously discounted development sites, particularly in the Central Brentwood Growth Corridor to restore the flexibility in site supply across a broader range of spatial locations, thereby improving the Plan's effectiveness and deliverability. 2) The methodology to the Local Plan's Housing Trajectory needs to be published and open for comment and challenge of its assumptions.
Consultation Point: PC02 and PC03
Soundness - Effectiveness, Justified & Compliance with National Policy
Paragraph 80 of the NPPF establishes that planning policies should help create the conditions in which businesses can invest, expand and adapt. The Council notes the new employment land requirements and job growth needs evidence undertaken by Lichfields in 2018. It is considered the amount of new employment land being provided is broadly sufficient to ensure that the Brentwood Borough meets its overall forecast employment land needs, including forecast new needs and losses from allocations and structural change.
It is considered however that the policy makes the assumption that there are no capacity issues for existing infrastructure, or any needs for supporting infrastructure to be provided and it is considered that this lack of clarity will make the policy ineffective, unjustified and will counteract creating conditions to support business growth which the NPPF seeks. As the Local Plan does with its housing target in Policy SP02 and Appendix 1, PC02 and PC03 should therefore incorporate additional provisions to manage the release and expansion of the locations within the Southern Brentwood Growth Corridor, supported by an Employment Land Trajectory in a new Appendix, to make it more effective, justified and consistent with national policy. The Council therefore objects to Policy PC02 and PC03.
Modifications: PC02 and PC03 should be amended to incorporate a staggered delivery target for new employment land, supported by a new Employment Land Trajectory within the Plan's Appendices, to coordinate the phased release of new and expanded employment land to ensure it can be linked to specific and necessary upgrades to supporting infrastructure. This will minimise the impact growth will have on existing highway routes in particular, which could otherwise impact on cross-boundary issues within the wider South Essex economic corridor.
Specialist Accommodation
Consultation Point: HP07
Soundness - Effectiveness
The Council has noted that the Brentwood Gypsy and Traveller Local Needs Accommodation Assessment 2018 (GTAA) assessed the need for Gypsy and Traveller pitches in Brentwood Borough for the period 2016 to 2033 as being 13 pitches. It acknowledges that there were no Travelling Showpeople identified as living in the Brentwood Borough, so there are no current or future accommodation needs for this community.
The evidence is noted as identifying a requirement of 11 additional Gypsy and Traveller pitches (5 total current need and 6 total future need) to be developed between the period 2016 to 2033 and makes a further 10% allowance for Gypsy and Traveller households whose travelling status was recorded as being "unknown", increasing the need to 12 pitches. It is acknowledged that since the completion of the evidence, one Gypsy and Traveller pitch has been lost through an approved change of use application and to replace this lost pitch, the Plan has added an additional pitch to its target, meaning the total requirement of Gypsy and Traveller pitches is 13 pitches.
Whilst it is noted that Brentwood Council proposes to meet this need through the incorporation of
a minimum 5 Gypsy and Traveller pitches as part of the Dunton Hills Garden Village allocation and through the regularisation of 8 existing pitches elsewhere in the Brentwood Borough. This however implies that 8 pitches will contribute towards meeting current need and only 5 pitches towards future need, when 6 are in fact required. The Council therefore objects to Policy HP07.
Modification: The GTAA identified the need for an additional pitch to meet future needs and therefore whilst the Policy HP07 quotes a minimum of 5 new pitches to be provided within its minimum target, the Plan could be more effective by setting 6 pitches as the target.
Consultation Point: Paragraphs 6.52-6.62
Soundness - Positively Prepared & Effectiveness.
The Council is concerned that there is no acknowledgement in the supporting text to the Brentwood Local Plan as to how it will address any unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople should it arise. The Plan should therefore recognise and support the principle of this approach going forward, to ensure that there will be a technical approach in place to support any neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling Showpeople need. This will ensure that the same process is applied throughout Essex therefore making the plan more positively prepared and effective for Gypsy, Traveller and Travelling Showpeople communities. The Council therefore objects to Paragraphs 6.52-6.62.
Modification: The Essex Planning Officers' Association Protocol for Unmet Gypsy, Traveller and Travelling Showpeople Needs 2018 has been developed collaboratively across Essex under the Duty to Cooperate, including with Brentwood Borough Council. It should be referenced in the supporting text to Policy HP07 - within Paragraphs 6.52-6.62. This will help ensure that the Plan recognises and supports the principle of this approach going forward, underling the technical approach in place to support how any requests from neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling will be considered in the future and then addressed as necessary through the Plan review process.
Consultation Point: Paragraphs 6.52-6.62
Soundness - Effectiveness and consistent with national policy.
Paragraph 9 of the Planning Policy for Traveller Sites (PPTS) establishes that "...local planning authorities should set pitch targets...which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring local planning authorities." There is also no mention however in the Brentwood Local Plan of the strategic and cross-boundary matter of Transit Sites, for which there is a study underway during 2019/2020 by the Essex Planning Officers' Association on behalf of all Greater Essex local planning authorities, including Brentwood Borough. Whilst it has not yet been possible to robustly assess the need for transit sites in Essex due to data inconsistencies across Greater Essex, changes have been made to the unauthorised encampment data collection process and an update to Essex Gypsy, Traveller and Travelling Showpeople Local Needs Accommodation Assessment will follow during 2019/2020 to determine whether any transit sites are needed in Greater Essex to help manage development pressures.
Whilst this cannot be included within Policy HE07 due to uncertainty, given that it is a current strategic matter for the Duty to Cooperate, with work in train to seek a resolution, it is considered more effective, for the Plan as a whole, to indicate how any such needs identified in future updates to the GTAA will be dealt with to make it more effective and consistent with the PPTS. The Council therefore objects to Paragraphs 6.52-6.62.
Modification: The Council considers the Local Plan would be more effective and more consistent with the PPTS if the strategic, cross-boundary issue of transit sites, covered by the Duty to
Cooperate were to be supported by a new paragraph explaining the context behind the issue and that it will be addressed as part of its first review.
Consultation Point: PC08 and Figure 7.7
Soundness - Justified & Effective
The Council notes that Nathaniel Litchfield & Partners prepared a Retail and Commercial Leisure Study (RCLS14) for Brentwood Council in 2014. The study identifies that Brentwood Town Centre as the main shopping centre in Brentwood Borough, with Shenfield, Ingatestone and Warley Hill providing smaller scale District Centres offering more local services, whilst smaller communities are supported by a number of village shops/local parades. The relationship between Brentwood Town Centre and larger competing centres including Basildon Town Centre is also noted, which is consistent with the Council's own evidence set out in the South Essex Retail Study 2017.
It is also acknowledged however that the Local Plan's settlement hierarchy proposes that DHGV Village and West Horndon will incorporate District Centres, similar in scale and role to Shenfield and Ingatestone. Figure 7.7 suggests this will apply to just DHGV, but caveats that this may change as a result of masterplanning or new evidence. Whilst the Council accepts that some form of local centre provision that could provide local shopping, community facilities and healthcare facilities would be a sustainable approach to the planning of any new community, helping to reduce the need to travel to larger centres to meet community needs, the positioning of the Garden Village needs to consider how it could impact on other centres and facilities in the locality, including those outside the Brentwood Borough, which may be closer and higher-order than other Brentwood Borough alternatives.
The Council cannot determine from any of Brentwood's published evidence as to what assessments have been carried out to determine the likely impact of installing new District Centres in West Hordon or DHGV on Basildon Borough's Laindon Town Centre. Assuming a central location within the site, DHGV District Centre would be around 2km to its west and West Hordon is only one stop by rail. Laindon Town Centre is the Basildon Borough's smallest town centre, which is currently undergoing a multi-million pound regeneration by Swan Housing Association to redevelop it into a new mixed use commercial and residential development called Laindon Place. It already provides a health centre, community centre, police station and library, which are all set to remain.
It is not considered acceptable as set out in footnote 10 to Figure 7.7 that the "the designation of the DHGV service centre(s) as a District Shopping Centre and/or Local Centre(s) and any subsequent Primary Shopping Area could be altered further by the South Brentwood Masterplan as this should remain a function of policy and not be delegated. The Council therefore objects to Policy PC08 and Figure 7.7.
Modification: Footnote 10 of Figure 7.7 should be amended to remove reference to the South Brentwood Masterplan as the role and order of the designated centre should be established by policy only. The Plan should have been informed by evidence which has tested cross-boundary impacts of installing new District Centres in close proximity to nearby centres including Laindon Town Centre and what measures will be taken in policy to limit any impact. If this evidence does not exist, the District Centre should be removed from DHGV, retaining some local centre provision to ensure DHGV can be sustainable and to enable the Plan to be effective and justified.
Consultation Point: Chapter 3, Chapter 6, Chapter 7 and Sustainability Appraisal
Soundness - Justified and consistent with national policy.
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. The Local Plan's Spatial Strategy is termed "Transit-orientated Growth", concentrating growth in the Local Plan in two transit corridors running through the borough. The 'Central Brentwood Growth Corridor', with the
A12, the Great Eastern Main Line to London Liverpool Street Station, and the Elizabeth Line; and the 'Southern Brentwood Growth Corridor', with the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
The Local Plan states that the site selection process for the housing allocations has been based upon the Spatial Strategy, and a sequential approach to selecting sites for development. It is accepted that this approach is intended to maximise brownfield redevelopment opportunities and support growth within compatible locations.
The Council acknowledges that Brentwood Borough Council has now published much of its previously missing evidence as set out in previous Regulation 18 representations. The Council is not satisfied that the Plan has been adequately informed by its evidence, and it questions whether the Spatial Strategy reached is therefore justified and consistent with national policy.
The Council has noted the two Growth Corridors. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia), which helps to put this investment into use through the growth locations. The South Brentwood Growth Corridor, whilst at its far west includes the M25, the remainder of the corridor consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c). It is not considered they offer comparable choices in terms of the capacity of these transport connections and the Central Brentwood Growth Corridor, by the presence of nationally and regionally maintained infrastructure.
In reviewing the appropriateness of the Spatial Strategy, an important element of the Plan's Sustainability Appraisal involves appraising 'reasonable alternatives' to inform development of the Plan. Four reasonable site alternatives in the Central Brentwood Corridor have been disregarded (AECOM Sustainability Apprial - Table 5.2), despite having few constraints and being able to tap into the potential for movement capacity offered by this superior corridor. This is considered to be in conflict with sustainable development when sites which have significant constraints to development or delivery have been included within the Plan, at the expense of sites which have fewer constraints. This raises fundamental concerns about the Plan's spatial distribution of growth and whether it has made the most of the capacity in this alternative corridor, before embarking on a new standalone settlement at DHGV in the Southern Brentwood Growth Corridor. The Council has noted that four sites on Table 5.2 of the Sustainability Appraisal have the potential to deliver 2,200 homes through extensions to villages, thereby questioning the need for a new settlement of the scale envisaged to deal with growth in the plan-period, which it considers means the Spatial Strategy is unjustified. The Council therefore objects to Chapter 3, the Sustainability Appraisal and land use allocations in Chapter 6 and 7.
Modification: Using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the superior infrastructure available. This should help encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Chapter 3 should be modified as a result along with all land use allocations in Chapter 6 and Chapter 7.
Consultation Point: Sustainability Appraisal
Soundness - Justified and consistent with national policy.
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contribution to the achievement of sustainable development. The Council challenges whether the Sustainability Appraisal has informed the choices made in the Spatial Strategy as
required by national policy, given it states that there was an early intention by Brentwood Council to deliver at least one new large-scale strategic site, which could be judged as artificially limiting the exploration of other plausible and deliverable urban/ village extensions. It is considered that Brentwood Council's lack of a Housing and Economic Land Availability Assessment (HELAA) between 2011 and 2018 has negatively impacted upon previous Regulation 18 drafts, which could have evolved differently having been informed by such evidence, demonstrating that other suitable, available and deliverable site options were present. This is unjustified, not consistent with the Plan's Strategic Objective SO1 and not in accordance with the NPPF. The Council therefore objects to the Sustainability Appraisal.
Modification: The Sustainability Appraisal should be reviewed to test an alternative strategy which does not include the artificial assumption that at least one new large scale strategic site should be incorporated into the Local Plan and then it should be amended accordingly. The Plan should then be reviewed informed by the outcome.
Consultation Point: BE11 and Paragraphs 5.106
The Council has reviewed the Brentwood Borough Infrastructure Delivery Plan (IDP) accompanying the Local Plan. It is acknowledged that this is intended to be a 'live' working document, much the same as the Basildon Borough IDP.
Paragraph 5.105 acknowledges that in respects of the South Brentwood Growth Corridor "...the provision of sustainable transport in this area is poor". The Council considers that it is surprising therefore that there are no specific highway mitigation measures provided in the Plan, just a statement that "the Council will work proactively with developers, key stakeholder and service providers to implement...new measures which would seek to mitigate transport impacts of sites on the highway infrastructure...". Whilst it is acknowledged within the Plan of the joint working being undertaken by ASELA, and the A127 Task Force for the Route Management Strategies and Joint Strategic Plan, both of which are supported by Basildon Council. The Council does however consider that highway modelling should have been tested to determine impact in development locations in Brentwood Borough, so it can be clear in policy terms how negative impacts are being mitigated and therefore prove that the Plan's spatial choices are reasonable in sustainability terms. It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace as suggested in Appendix 1, becomes hindered by a lack of infrastructure capacity and outline solutions to overcome them. It is not considered that Policy BE11 is therefore effective at delivering the Plan's Strategic Objectives.
It is noted that Paragraph 5.106-5.107 acknowledges the Lower Thames Crossing and the outline concept of its preferred route and that it is not expected to have a direct impact on Brentwood Borough in terms of land safeguarding. It is however suggested that the Plan also acknowledges that following the engagement of authorities in Essex, including Basildon Borough Council, Highways England has accepted that its impact modelling was deficient in determining how driver behaviour in South Essex and further afield could alter when the scheme opens. This is particularly an issue for this Plan, as its includes land allocations in West Horndon and the DHGV along the A127 corridor, which will be within a reasonable proximity to the Lower Thames Crossing and could therefore be impacted by it. It should be recognised that Highways England are now taking steps to incorporate growth proposals set out in Local Plans in the vicinity to address this point and identify any measures needed to the scheme or nearby routes to mitigate any adverse impacts. The Council therefore objects to Policy BE11 and Paragraphs 5.106.
Modification: 1) BE11 and the land allocations should have been informed by highway modelling that tests highway mitigation solutions to mitigate impact caused by development. This work should be repeated and the Plan amended in light of its findings.
2) Paragraph 5.106 should be amended to include reference that local authorities have secured additional testing within the Lower Thames Crossing modelling being undertaken by Highways England to determine the extent of local impacts on the road network arising from Local Plan growth.
Consultation Point: R01 & HP01
Soundness - Justified
The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs and it is considered that there may be implications for the future geographical extent of both the Brentwood and South Essex Housing Market Areas as the housing markets evolve.
Furthermore, the policy requirements of the Plan are informed by data collected from Brentwood Borough, or its population; the significant majority of which is located away from this area to the north. Consequently, there is a difference in what might be delivered in DHGV compared to what could be delivered just slightly to the east in Basildon Borough; which might distort the housing markets as they adjust to the new development taking place around the boundary. The following table has been prepared using Figure 6.1 from the Plan and the South Essex Strategic Housing Market Assessment that has informed the Basildon Borough Local Plan 2014-2034 and it is considered both these SHMA's should instead be used to inform the housing mix policy for DHGV. The Council therefore objects to Policy R01 and HP01.
Modification: It is considered the stark contrast between the house size requirements for Basildon and Brentwood in DHGV, which is on a boundary location, means it needs to have taken into account the South Essex SHMA in determining the housing mix for DHGV so that it can better sit within the landscape of the strategic context of South Essex, which is not reflective of the wider Brentwood Borough HMA. Policy HP01 and R01 should be amended in light of this.
Consultation Point: R01(D)(h)
Soundness - Justified and consistent with national policy.
The Council has noted that Policy R01(D)(h) has set a target to retain 50% of the strategic allocation for green and blue infrastructure. Given the location is over 259ha, it is agreed that this helps enshrine the Garden Community values within the policies which will guide the masterplan and the site's development. However, the Council questions whether this is intended to be a permanent resource, given it also determines that a further 2,300 homes could be brought forward in the strategic location after 2033; taking its indicative total to around 4,000 homes. It is considered that if it is not explained clearly in any published evidence, as to whether any of the retained space for green and blue infrastructure would need to be used to meet this higher development scale after 2033. The Council's understanding of this, is frustrated by a lack of published evidence on DHGV, which would enable Basildon Borough to effectively understand the nature, extent and potential implications (positive or negative) of its proposals for DHGV. This would make the policy more justified and compliant with national policy. The Council therefore objects to Policy R01(D)(h).
Modification: Clarify within R01 and its supporting text whether the Green Infrastructure proposed to amount to 50% of the land area is a permanent resource or whether the projected growth in the area beyond the plan-period would need to utilise any of the green infrastructure for growth. If the latter, the percentage should be adjusted accordingly.
Consultation Point: SP02, R01 and Paragraph 8.83-8.84
Soundness - Justified
The Council welcomes the publication of the Brentwood Borough Green Belt Study 2018. It is acknowledged that this comprises two parts; Part 1 is a full Green Belt assessment parcelling up the Green Belt and Part 2 as a separate site assessment of individual sites promoted through the Housing and Economic Land Availability Assessment (HELAA). This is a similar format to the Basildon Borough Green Belt Study.
For Part 1, a scale of high - low was used to assess the contribution 70 separate parcels made to the Green Belt. The DHGV parcel (17) score "Moderate - High". It was one of 21 parcels to score "Moderate - High". 19 parcels scored "High". The remainder scored lower.
In respect of the tests, Parcel 17 was assessed as follows:
* Purpose 1 - to check unrestricted sprawl of large built up areas: Not contained i.e. development would constitute urban sprawl (red)
* Purpose 2 - to prevent neighbouring towns merging into one another: Important
countryside gap between settlements (amber)
Purpose 3 - to assist in safeguarding the countryside from encroachment: Functional countryside (red)
Purpose 4 - to preserve the setting and special character of historic towns: Limited relationship with a historic town. (green)
The Council does not consider it to be clear however, from the published methodology, as to why having scored highly in relation to the Purpose 1 and Purpose 3, as to why this parcel is assessed as making a "moderate to high" contribution to Green Belt purposes, when there are other parcels which make high contributions towards two of the purposes have been assessed as making a "high" contribution towards Green Belt purposes; and are therefore valued to a greater degree as serving towards the purpose of Green Belt.
In respects of Part 2 assessment, the DHGV allocation (Site 200) was assessed alongside other HELAA sites. A total of 92 sites were assessed. The DHGV site assessment matches the entire Parcel 17 assessed in Part 1. Five sites were assessed as making a "high" contribution towards Green Belt purposes. A further 18 sites were assessed as making a "moderate to high contribution". Site 200 - 'Entire land east of A128, south of A127' was assessed as making a "moderate to high" contribution. The remaining 69 sites were assessed as making a less significant contribution to Green Belt purposes.
The DHGV site was assessed as follows:
* Purpose 1 - to check unrestricted sprawl of large built up areas: Not contained i.e. development would constitute urban sprawl (red)
* Purpose 2 - to prevent neighbouring towns merging into one another: Would result in significant separation reduction (amber)
* Purpose 3 - to assist in safeguarding the countryside from encroachment: Functional countryside (red)
* Purpose 4 - to preserve the setting and special character of historic towns: Limited relationship with historic town (green)
The outcomes of Part 2 are considered to be consistent with Part 1. However, it is not clear from the methodology as to why given the site scored highly in relation to Purpose 1 and Purpose 3,
this parcel is then assessed as only making a "moderate to high" contribution to Green Belt purposes, when it could potentially have been assessed as making a "high" contribution for those reasons.
The Council recognise that there is now, no longer an issue with missing evidence in this regard, which it had repeatedly raised in previous Regulation 18 consultation responses. However, the Council considers that the issue now is one of how the Green Belt evidence has informed the Plan. It is not clear how the policy judgements arrived at have considered that development in this strategic gap, which helps prevent settlement coalescence can be adequately mitigated. The Council does not believe that when accounting for this evidence that the Plan has reached a justified position in respects of whether the Green Belt evidence has informed the Local Plan policies, to the degree which the proposals in the DHGV area are set out. The Council therefore objects to Policy SP02, R01 and Paragraphs 8.83-8.84.
Modification: The Plan should demonstrate in more detail, through a tool such as a Topic Paper, how its site selection choices have been informed by the Green Belt Study 2018 and should any inconsistencies occurs the Plan's land use allocations and justification should be changed.
Consultation Point: Paragraph 9.36 and R01(II)
Soundness - Justified & Effective
Brentwood Council will be aware from joint Duty to Cooperate meetings with elected members and officers that during 2017, efforts were made by both Basildon and Brentwood Councils to determine whether a West Basildon urban extension could be delivered in the Basildon Borough Local Plan, alongside DHGV, whilst maintaining a sense of visual separation between both developments. To this end, a joint Dunton Area Landscape Corridor Design Options Study was commissioned by both Councils, which I have enclosed as evidence against this representation, to consider how both Council's Green Belt and land management policies, either side of the boundary, could be coordinated in this location going forward. This was to also help determine whether it was possible for DHGV to co-exist with development in West Basildon without causing harm to heritage and environmental assets within Basildon Borough.
The Council has noted that the Plan does now includes specific references that the joint borough boundary needs a degree of landscape and Green Belt treatment to maintain a visual separation with the edge of Basildon Borough, but it does not elaborate as to how this will be achieved. The Council therefore finds its disappointing that this joint study does not form part of the referenced and published evidence base for the Plan, nor do the outcomes from this work appear to have informed Policy R01(II) as sought through the earlier Duty to Cooperate engagement. The Council therefore objects to Policy R01(II) and Paragraph 9.36.
Modification: The measures set out in the Joint Dunton Area Landscape Corridor Design Options 2017 should be acknowledged in Paragraph 9.36 and incorporated into Policy 9.36 to make it more justified and effective at mitigating the impact the development would otherwise have on the Basildon Borough. This would lead to an effective policy outcome identified as being necessary during Duty to Cooperate engagement to manage this cross-boundary issue. It is considered that as a matter of principle, this would help address the Council's previous Regulation 18 objections as to how the boundary would be treated and how the new community could exist side by side the existing smaller settlement of Dunton Wayletts in the Basildon Borough.
Consultation Point: SP04 and R01(I)
Soundness - Effectiveness, Justified & Compliance with National Policy
It is noted that the Plan assumes that all commuters will use West Horndon railway station and other areas in Brentwood Borough to access a means of travelling to other places. It fails however to investigate the possible impacts on Basildon Borough's road and rail infrastructure, as a
neighbouring authority, arising from commuters or other road users choosing to access facilities within the Basildon Borough instead.
The Transport Assessment (PBA, 2018) discusses measures to ensure more effective bus access to and from West Horndon Station - serving an area including the new DHGV, as well as other employment sites within South Brentwood Growth Corridor. It is noted however that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable.
The Brentwood Borough IDP states that a new multi-modal interchange will be created at West Horndon Station. This will serve the DHGV, Childerditch, West Horndon and Enterprise Development sites. It also mentions the possibility that this could serve any future northern Thurrock developments. The Plan states that, the proposed DHGV settlement's transport mitigation measures will include potential dedicated bus route(s) connecting the development with West Horndon station and improvements at West Horndon station for vehicular, segregated cycle and public transport access from surrounding developments, as well as cycle storage and a bus interchange facility. The Council is therefore confused that in seeking to mitigate DHGV's impacts on the surrounding areas there is no mention of any impact being evaluated as spilling over into Basildon Borough and needing its own mitigation.
Laindon railway station, with three platforms and starter trains has greater commutable capacity than West Horndon and could become an alternative choice for residents within DHGV, despite a lack of new connections hampering their ability to make that choice easily without driving, via the A127. Whilst the Plan seeks to make provision for a new interchange at West Horndon to capture these movements more locally, should commuters still seek to use alternative stations including those outside of the Brentwood Borough such as Laindon, this will lead to increase demands on those stations' facilities, particularly parking, as well as the routes to get to them. Policy SP04 does set out the approach required by Paragraph 34 of the NPPF, but it does not explicitly mention that it has accounted for the spatial context of DHGV and the existing spatial form of the Brentwood Borough, where its higher-order settlements are further to the north. It does not state that it will support the possibility of developer contributions being used to mitigate this impact outside the Brentwood Borough in higher-order settlements which are closer that Brentwood Borough's own settlements, but outside the Brentwood Borough. This is considered to disregard how new residents living in the DHGV could behave in the future in seeking to access services and how this impact will therefore be adequately mitigated.
It seems that it an effort for the new DHGV to be self-sustaining, as set out in Paragraph 9.14, it has meant the Plan remains unclear, as to how it will relate to its neighbouring areas, particularly in terms of access and connectivity. This is considered a core sustainability principle for new developments and whether in exercising that choice, its residents will use what is to be provided within Brentwood Borough remains to be seen. They could use alternative routes (namely the A127 and West Mayne into Laindon) to access different facilities already available in closer higher order settlements outside Brentwood Borough. Considering that there are existing services that are already shared between the Borough's residents, e.g. schools, it is considered essential for a more practical and pragmatic approach to be adopted should the DHGV be permitted, including the policy reality that until such a time as the critical mass for new homes is established on-site, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the neighbouring Brentwood Borough in the short-medium term.
There is no evidence presented by Brentwood Borough Council which indicates that DHGV's growth demands have been evaluated, in combination, with the projected demands arising from the Basildon Borough Local Plan. The Plan should not assume that such growth can just be absorbed by the nearby infrastructure and services in Basildon Borough and investment through developer contributions will be necessary. The infrastructure in the Basildon Borough has been evaluated for its capacity, its ability to grow and the scale of investment necessary to accommodate the growth in the Basildon Borough Local Plan to enable the Basildon growth to occur and there has not been enough information published during Regulation 18 (as set out in previous
representations) to be able to incorporate any testing of Brentwood's growth in as well. The Council therefore objects to Policy SP04 and R01(II).
Modification: The Plan should be modified to recognise that some impacts are likely to be cross-boundary and additional provisions should be incorporated into SP04 and RO1(I) that will support using S106/CIL arising from development in Brentwood Borough to be used for investment outside the Brentwood Borough, where it can be proven that there is reasonable likelihood of a direct or residual impacts otherwise being caused that need to be mitigated. This will make the Plan more effective, justified and in accordance with national policy.
Consultation Point: R01(I) and Appendix 1
Soundness - Justified & Effective
The Council notes the housing trajectory included within the Plan at Appendix 1. With regards to DHGV it is assumed that delivery will commence in 2022/23 (within the next five years) at a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. As set out in earlier representations in respects of housing supply, this seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires masterplanning and will need to go through a planning application and elements of the condition discharge process before development on site can even commence. Development commencement on-site meanwhile, will be reliant on essential utility and infrastructure provision. No evidence is provided alongside the Plan, or within the associated Housing and Economic Land Availability Assessment (HELAA), as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base, or any form of a development framework/ masterplan for the DHGV that explains how the proposed accelerated rate of delivery will be possible to achieve.
The Council considers that the speed and level of growth in this boundary location may have implications for Basildon Borough's own housing market and risks the ability for it to be able to deliver housing at the rates necessary for its own housing trajectory. Early residents of the DHGV will rely on some services and facilities outside the village to meet their initial needs, unless these facilities were all to be front-loaded and wait for the population to gradually build up to make full use of them. As an example, the DHGV will require new primary and secondary school provision. However, whilst the Brentwood IDP shows the primary provision in particular being delivered early, it is understood to not be economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality (principally within the Basildon Borough), whilst operational primary and then secondary education provision is secured and the village becomes more self-sufficient. The Council therefore objects to Policy R01(I) and Appendix 1.
Modification: The Council therefore seeks for evidence to be provided demonstrating the realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby. This will make the Plan justified and effective.
Consultation Point: R01(II)
Soundness - Effectiveness
Notwithstanding that the Council objects to many of the fundamental soundness principles of the DHGV, the Council would like to seek assurances written into Policy R01(II) that it will be invited by Brentwood Borough Council to become more involved in the detailed design and delivery of the new village. This will ensure that the strategic and cross-boundary impacts covered by the Duty to Cooperate and raised during the Council's response to the Plan at Regulation 18 and 19 stages are managed effectively during the development's implementation stages (assuming it is
considered sound), alongside the Basildon Borough Local Plan's own implementation. The Council therefore objects to Policy R01(II).
Modification: The Council would like a criterion added into Policy R01(II) under a new heading "Collaborative Approach" that will make it a requirement for neighbouring authorities to be engaged during the detailed design stages of DHGV to ensure strategic and cross boundary impacts are managed effectively during implementation.
This concludes the Council's representation.

Basildon Council therefore seeks for evidence to be provided demonstrating the realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby. This will make the Plan justified and effective.

This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Local Plan Regulation 19 public consultation.
Please be advised that for all of the consultation points below, the Council would like to attend the future oral hearings as part of the Plan's Examination in Public.
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for the Basildon Borough that may arise from Brentwood Borough Council's Local Plan and determine whether it considers it to be compliant with necessary legislation and whether it meets the tests of soundness.
1) Is the Brentwood Borough Local Plan 2016-2033 legally compliant?
The Council has reviewed the Brentwood Borough Local Plan 2016-2033 and supporting documents. It considers that whilst it disagrees with aspects of the Plan from a soundness perspective that it is however legally compliant.
2) Does the Brentwood Borough Local Plan 2016-2033 meet the tests of soundness?
The Council does not believe that the Brentwood Borough Local Plan 2016-2033 meets the tests of soundness in all of its policy areas. It therefore makes the following 1 representation in support of an aspect of the Plan and 17 representations where it considers the Local Plan is unsound and requires modifications to make it sound.
Supporting Representations
Consultation Point: Chapter 1
Soundness - Effectiveness & Compliance with National Policy
Paragraph 26 of the National Planning Policy Framework (NPPF) asserts that effective and on-going joint working between strategic policymaking authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, it considers that joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. To demonstrate effective and on-going joint working, strategic policy-making authorities should
planning.policy@brentwood.gov.uk
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prepare and maintain one or more Statements of Common Ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these.
A major step forward for effective cooperation has been the Memorandum of Understanding that was signed between Basildon, Brentwood, Castle Point, Essex County, Rochford, Southend-on-Sea and Thurrock Councils to form the ASELA. This has ensured that there is now a more coordinated, collective working on a 'place vision' for the sub region, which recognises one of the key delivery tools will be a statutory Joint Strategic Plan (JSP). A Statement of Common Ground has also been agreed between the ASELA to ensure it is embedded into the Local Development Schemes of all the local planning authorities with resources committed to its preparation during 2019/2021. This will ensure it sets the foundations for planning at a broader spatial level, determining how growth and infrastructure can be better coordinated to positively influence place-making in South Essex and provide a more prosperous area for people to live, work, study and visit. The Statement of Common Ground recognises that the planning landscape of South Essex is not perfect and not all authorities can wait for the JSP to be completed before their Local Plans are advanced. It accepts that the JSP will have to be mindful, in particular of Basildon, Brentwood and Castle Point's and the reality that their Local Plans are already too advanced to be paused.
The Council has noted Brentwood Council's commitment in paragraph 1.13 to work as a member of ASELA on a process to develop a long-term growth ambition that would underpin strategic spatial, infrastructure and economic priorities across the wider sub-region. It is acknowledged that this is in accordance with the South Essex JSP Statement of Common Ground - June 2018; of which Basildon and Brentwood Borough Councils are one of the seven joint signatories.
Work on the JSP is at an early stage with Regulation 18 consultation due to take place during 2019, followed by Regulation 19 in 2020, with examination in public and adoption not expected to be until 2020/2021. It will cover a longer plan period extending to 2038; slightly longer than both the Basildon and Brentwood Local Plans. Paragraph 1.38 of the Brentwood Borough Local Plan references that its own allocations can contribute towards some of the delivery of early growth during the JSP plan-period; a position that is also applicable for the soon to be submitted Basildon Borough Local Plan 2014-2034. It is welcomed that the Brentwood Borough Local Plan has mirrored the intent of the Basildon Borough Local Plan in Paragraphs 1.35-1.38 that following the adoption of the JSP, it may be necessary to review the Plan, at least in part, to ensure any opportunities for additional growth and infrastructure provision in the Borough, that may otherwise be additionally identified in the JSP, can be realised. The Council fundamentally supports this policy approach as meeting the soundness tests of being a) effective and b) in accordance with national policy.
The Council considers this to be compatible to its own position and underpins the collective efforts to get an "effective mechanism" in place to address strategic, cross boundary matters in a more holistic and planned manner that has greater potential to realise positive outcomes to South Essex communities. Looking ahead, the Council embraces the opportunity presented by Brentwood Borough Council being part of the ASELA and the JSP, in order to tackle strategic, cross-boundary matters holistically to ensure sustainable growth solutions are achieved that benefit all communities.
Objecting Representations
Consultation Point: Whole Plan
Soundness - Effectiveness, Justified & Compliance with National Policy
Paragraph 26 of the National Planning Policy Framework (NPPF) asserts that effective and on-going joint working between strategic policymaking authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. The Council, as a neighbouring Borough and Duty to Cooperate body, has reviewed and considered previous versions of the Local Plan and its preparatory documents and submitted relevant representations under Regulation 18 consultations. The Council formally wishes to express its disappointment that given fundamental
evidence has been 'in development', but not published during much of its preparation. It has been significantly difficult, therefore, to digest the Plan's rationale and approach as it has evolved. This includes the entire Green Belt Review, Housing and Economic Land Availability Assessment, Landscape Sensitivity and Capacity Study, Local Plan Viability Assessment and Transport Assessment which were not published until the month before Brentwood Council considered the Publication Local Plan in November 2018. It is accepted that not all evidence can be completed by each consultation stage and much may remain as a continual draft until Regulation 19, however it is considered this has created a lack of transparency during critical plan-making stages and contributed to the scale of representations from Basildon Council for its Regulation 19 response.
During 2017/2018, officers from Basildon, Thurrock and Essex County Councils, facilitated by an officer from Rochford District Council, jointly sought to understand and address with Brentwood Borough Council how the Brentwood Borough Local Plan, in particular the Dunton Hills Garden Village (DHGV) strategic allocation, could impact on neighbouring authority areas, particularly in terms of infrastructure and service provision. Meetings were held, and correspondence exchanged, in an effort to seek solutions and resolutions to previous Regulation 18 objections/ observations from all three Councils. The intention was to appreciate the evidenced rationale for identifying the DHGV strategic allocation and ensuring neighbouring authorities could engage more effectively to identify and manage cross-boundary impacts. Despite this engagement, it is considered that not all information and assurances sought from Brentwood Borough Council have been provided and this brings into question the soundness of the rationale and choices made in the Brentwood Borough Local Plan.
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As such, all of Basildon Council's previous responses to Regulation 18 consultations are enclosed as supplementary evidence to the Regulation 19 consultation; affirming that many of the comments made in respects this consultation response have been raised previously, but remain unanswered or inadequately addressed. It is uncertain how the Plan has been informed by this previous input. It is considered that this is not a justified approach and has resulted in a Plan which is less effective at tackling strategic, cross-boundary issues.
Consultation Point: SP02: Managing Growth, Paragraphs 4.15-4.16 and Appendix 1
Soundness - Effectiveness, Justified & Compliance with National Policy
It is acknowledged that Brentwood Borough Council commissioned David Couttie Associates (DCA) in 2013 to undertake a Strategic Housing Market Assessment (SHMA) and define its Housing Market Area (HMA). This concluded that Brentwood Borough's administrative area was a self-contained HMA. This is different to the Basildon Borough, which is a sub-area (with Castle Point) of the much larger South Essex HMA, which also incorporates Rochford, Southend on Sea and Thurrock. The Brentwood SHMA, which was most recently updated in November 2018, forms part of the evidence base for identifying the Objectively Assessed Need (OAN) for housing in Brentwood Borough. However, NPPF/2019 (published after the Publication Local Plan was approved by Brentwood Borough Council in November 2018, in February 2019) now requires housing needs to be calculated in accordance with the Standard Methodology set out in national Planning Practice Guidance.
Basildon Borough Council has acknowledged that this has seen the OAN for Brentwood Borough change three times over the course of the last year as follows:
* In January 2018, the Brentwood SHMA January 2018 identified an OAN for Brentwood of 380. This was calculated using the SHMA Planning Practice Guidance that underpinned the NPPF/2012;
* In July 2018, NPPF/2018 was launched introducing the standard methodology for calculating objectively assessed housing need. The standard methodology requires the use of the most recently published household projections as the starting point. At that time, the 2014-based CLG Household Projections formed that starting point resulting in an OAN for Brentwood of 452 homes per annum; and
* In September 2018, 2016-based ONS Household Projections were published, revising the starting point for the standard method calculation. For Brentwood Borough, these projections showed a reduced rate of household growth going forward, resulting in a reduced housing requirement for Brentwood of 350 homes per annum.
It has been noted by Basildon Council that the Brentwood Borough Local Plan uses this latest 2016 projection to define the minimum OAN target.
The reduced rate of household growth in the 2016-based ONS Household Projections was highlighted as a nation-wide issue driving down the OAN calculations in around two-thirds of authorities, although not Basildon. This resulted in the standard methodology only identifying around 215,000 homes per annum supply for England against a national policy target of 300,000 homes per annum. Consequently, in October 2018 MHCLG launched a consultation on technical changes to the standard methodology, seeking for authorities to continue using the 2014-based CLG Household Projections in the interim. On the 19 February 2019, the Government's response to this consultation was published indicating that the Government will be making clear in national Planning Practice Guidance that the 2016-based ONS Household Projections should not be used for the standard methodology calculation, and the 2014-based CLG Household Projections should be used instead.
The Brentwood Local Plan therefore, which makes provision for 456 homes per annum does meet just over its full OAN for housing, having regard to the standard methodology calculation of need based on the 2014 CLG Household Projections (452 homes per annum), as explained in required by Planning Practice Guidance (Paragraph: 004 Reference ID: 2a-004-20190220 and Paragraph: 005 Reference ID: 2a-005-20190220) that has been adjusted following the Government's response to the technical consultation.
The Brentwood Local Plan, however, as drafted and approved by Brentwood Council in November 2018, sets out in Paragraphs 4.15-4.16 that the housing target for Brentwood is set at 350 homes per annum and it proposes an annual housing supply buffer of 20% taking total supply of 456 homes per annum. This was considered at the time as offering additional flexibility throughout the plan period. This is now not the case as the 2016-based ONS Household Projections must be discounted, as above, with the baseline reverting to the 2014-based projections. This results in a Plan which will now have an insignificant flexibility in its land supply; a component which was considered justified and fundamental to the Plan's strategy when it was approved in November 2018.
When this new position is viewed alongside the variable housing target, it is considered this could cause the plan to be less effective and justified. The initial housing target of 310 homes per annum between 2016 and 2023, should, according to the Plan, increase to 584 homes per annum beyond 2023. It is noted that this increase is substantially reliant on the new Dunton Hills Garden Village (DHGV) in the Southern Brentwood Growth Corridor, which according to the Housing Trajectory set out in Appendix 1 is expected to commence housing delivery in 2023/24, within the first five years of the Plan. That scheme is expected to deliver at the initial ambitious rate of 100 homes per annum upwards from thereon, reaching 300 homes per annum by 2026. These are considered to be overly optimistic delivery assumptions for such a large scale Green Belt allocation, which whilst mostly in a single land ownership that could facilitate delivery, still requires for the boundaries of the Green Belt to be amended on adoption of the Plan (assuming it is found lawful and sound), detailed masterplanning, essential infrastructure programming on-site and off-site to ensure sustainable development can be achieved. It is not clear from any published evidence how such a delivery rate has been formulated having acknowledged these issues and therefore this is challenged in terms that it is not justified.
Summary: As a result in the change to the NPPF, the Plan also now has very little flexibility within its land supply should anything happen to cause delivery of homes to become delayed during the plan period; which was a fundamental principle to the Plan's strategy approved in November 2018. There is an unjustified over-reliance on DHGV in the Southern Brentwood Growth Corridor to
contribute towards supply at an accelerated rate. The Council therefore objects to Policy SP02, 4.15-4.16 and Appendix 1
Modification: 1) The Local Plan must be adjusted to incorporate previously discounted development sites, particularly in the Central Brentwood Growth Corridor to restore the flexibility in site supply across a broader range of spatial locations, thereby improving the Plan's effectiveness and deliverability. 2) The methodology to the Local Plan's Housing Trajectory needs to be published and open for comment and challenge of its assumptions.
Consultation Point: PC02 and PC03
Soundness - Effectiveness, Justified & Compliance with National Policy
Paragraph 80 of the NPPF establishes that planning policies should help create the conditions in which businesses can invest, expand and adapt. The Council notes the new employment land requirements and job growth needs evidence undertaken by Lichfields in 2018. It is considered the amount of new employment land being provided is broadly sufficient to ensure that the Brentwood Borough meets its overall forecast employment land needs, including forecast new needs and losses from allocations and structural change.
It is considered however that the policy makes the assumption that there are no capacity issues for existing infrastructure, or any needs for supporting infrastructure to be provided and it is considered that this lack of clarity will make the policy ineffective, unjustified and will counteract creating conditions to support business growth which the NPPF seeks. As the Local Plan does with its housing target in Policy SP02 and Appendix 1, PC02 and PC03 should therefore incorporate additional provisions to manage the release and expansion of the locations within the Southern Brentwood Growth Corridor, supported by an Employment Land Trajectory in a new Appendix, to make it more effective, justified and consistent with national policy. The Council therefore objects to Policy PC02 and PC03.
Modifications: PC02 and PC03 should be amended to incorporate a staggered delivery target for new employment land, supported by a new Employment Land Trajectory within the Plan's Appendices, to coordinate the phased release of new and expanded employment land to ensure it can be linked to specific and necessary upgrades to supporting infrastructure. This will minimise the impact growth will have on existing highway routes in particular, which could otherwise impact on cross-boundary issues within the wider South Essex economic corridor.
Specialist Accommodation
Consultation Point: HP07
Soundness - Effectiveness
The Council has noted that the Brentwood Gypsy and Traveller Local Needs Accommodation Assessment 2018 (GTAA) assessed the need for Gypsy and Traveller pitches in Brentwood Borough for the period 2016 to 2033 as being 13 pitches. It acknowledges that there were no Travelling Showpeople identified as living in the Brentwood Borough, so there are no current or future accommodation needs for this community.
The evidence is noted as identifying a requirement of 11 additional Gypsy and Traveller pitches (5 total current need and 6 total future need) to be developed between the period 2016 to 2033 and makes a further 10% allowance for Gypsy and Traveller households whose travelling status was recorded as being "unknown", increasing the need to 12 pitches. It is acknowledged that since the completion of the evidence, one Gypsy and Traveller pitch has been lost through an approved change of use application and to replace this lost pitch, the Plan has added an additional pitch to its target, meaning the total requirement of Gypsy and Traveller pitches is 13 pitches.
Whilst it is noted that Brentwood Council proposes to meet this need through the incorporation of
a minimum 5 Gypsy and Traveller pitches as part of the Dunton Hills Garden Village allocation and through the regularisation of 8 existing pitches elsewhere in the Brentwood Borough. This however implies that 8 pitches will contribute towards meeting current need and only 5 pitches towards future need, when 6 are in fact required. The Council therefore objects to Policy HP07.
Modification: The GTAA identified the need for an additional pitch to meet future needs and therefore whilst the Policy HP07 quotes a minimum of 5 new pitches to be provided within its minimum target, the Plan could be more effective by setting 6 pitches as the target.
Consultation Point: Paragraphs 6.52-6.62
Soundness - Positively Prepared & Effectiveness.
The Council is concerned that there is no acknowledgement in the supporting text to the Brentwood Local Plan as to how it will address any unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople should it arise. The Plan should therefore recognise and support the principle of this approach going forward, to ensure that there will be a technical approach in place to support any neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling Showpeople need. This will ensure that the same process is applied throughout Essex therefore making the plan more positively prepared and effective for Gypsy, Traveller and Travelling Showpeople communities. The Council therefore objects to Paragraphs 6.52-6.62.
Modification: The Essex Planning Officers' Association Protocol for Unmet Gypsy, Traveller and Travelling Showpeople Needs 2018 has been developed collaboratively across Essex under the Duty to Cooperate, including with Brentwood Borough Council. It should be referenced in the supporting text to Policy HP07 - within Paragraphs 6.52-6.62. This will help ensure that the Plan recognises and supports the principle of this approach going forward, underling the technical approach in place to support how any requests from neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling will be considered in the future and then addressed as necessary through the Plan review process.
Consultation Point: Paragraphs 6.52-6.62
Soundness - Effectiveness and consistent with national policy.
Paragraph 9 of the Planning Policy for Traveller Sites (PPTS) establishes that "...local planning authorities should set pitch targets...which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring local planning authorities." There is also no mention however in the Brentwood Local Plan of the strategic and cross-boundary matter of Transit Sites, for which there is a study underway during 2019/2020 by the Essex Planning Officers' Association on behalf of all Greater Essex local planning authorities, including Brentwood Borough. Whilst it has not yet been possible to robustly assess the need for transit sites in Essex due to data inconsistencies across Greater Essex, changes have been made to the unauthorised encampment data collection process and an update to Essex Gypsy, Traveller and Travelling Showpeople Local Needs Accommodation Assessment will follow during 2019/2020 to determine whether any transit sites are needed in Greater Essex to help manage development pressures.
Whilst this cannot be included within Policy HE07 due to uncertainty, given that it is a current strategic matter for the Duty to Cooperate, with work in train to seek a resolution, it is considered more effective, for the Plan as a whole, to indicate how any such needs identified in future updates to the GTAA will be dealt with to make it more effective and consistent with the PPTS. The Council therefore objects to Paragraphs 6.52-6.62.
Modification: The Council considers the Local Plan would be more effective and more consistent with the PPTS if the strategic, cross-boundary issue of transit sites, covered by the Duty to
Cooperate were to be supported by a new paragraph explaining the context behind the issue and that it will be addressed as part of its first review.
Consultation Point: PC08 and Figure 7.7
Soundness - Justified & Effective
The Council notes that Nathaniel Litchfield & Partners prepared a Retail and Commercial Leisure Study (RCLS14) for Brentwood Council in 2014. The study identifies that Brentwood Town Centre as the main shopping centre in Brentwood Borough, with Shenfield, Ingatestone and Warley Hill providing smaller scale District Centres offering more local services, whilst smaller communities are supported by a number of village shops/local parades. The relationship between Brentwood Town Centre and larger competing centres including Basildon Town Centre is also noted, which is consistent with the Council's own evidence set out in the South Essex Retail Study 2017.
It is also acknowledged however that the Local Plan's settlement hierarchy proposes that DHGV Village and West Horndon will incorporate District Centres, similar in scale and role to Shenfield and Ingatestone. Figure 7.7 suggests this will apply to just DHGV, but caveats that this may change as a result of masterplanning or new evidence. Whilst the Council accepts that some form of local centre provision that could provide local shopping, community facilities and healthcare facilities would be a sustainable approach to the planning of any new community, helping to reduce the need to travel to larger centres to meet community needs, the positioning of the Garden Village needs to consider how it could impact on other centres and facilities in the locality, including those outside the Brentwood Borough, which may be closer and higher-order than other Brentwood Borough alternatives.
The Council cannot determine from any of Brentwood's published evidence as to what assessments have been carried out to determine the likely impact of installing new District Centres in West Hordon or DHGV on Basildon Borough's Laindon Town Centre. Assuming a central location within the site, DHGV District Centre would be around 2km to its west and West Hordon is only one stop by rail. Laindon Town Centre is the Basildon Borough's smallest town centre, which is currently undergoing a multi-million pound regeneration by Swan Housing Association to redevelop it into a new mixed use commercial and residential development called Laindon Place. It already provides a health centre, community centre, police station and library, which are all set to remain.
It is not considered acceptable as set out in footnote 10 to Figure 7.7 that the "the designation of the DHGV service centre(s) as a District Shopping Centre and/or Local Centre(s) and any subsequent Primary Shopping Area could be altered further by the South Brentwood Masterplan as this should remain a function of policy and not be delegated. The Council therefore objects to Policy PC08 and Figure 7.7.
Modification: Footnote 10 of Figure 7.7 should be amended to remove reference to the South Brentwood Masterplan as the role and order of the designated centre should be established by policy only. The Plan should have been informed by evidence which has tested cross-boundary impacts of installing new District Centres in close proximity to nearby centres including Laindon Town Centre and what measures will be taken in policy to limit any impact. If this evidence does not exist, the District Centre should be removed from DHGV, retaining some local centre provision to ensure DHGV can be sustainable and to enable the Plan to be effective and justified.
Consultation Point: Chapter 3, Chapter 6, Chapter 7 and Sustainability Appraisal
Soundness - Justified and consistent with national policy.
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. The Local Plan's Spatial Strategy is termed "Transit-orientated Growth", concentrating growth in the Local Plan in two transit corridors running through the borough. The 'Central Brentwood Growth Corridor', with the
A12, the Great Eastern Main Line to London Liverpool Street Station, and the Elizabeth Line; and the 'Southern Brentwood Growth Corridor', with the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
The Local Plan states that the site selection process for the housing allocations has been based upon the Spatial Strategy, and a sequential approach to selecting sites for development. It is accepted that this approach is intended to maximise brownfield redevelopment opportunities and support growth within compatible locations.
The Council acknowledges that Brentwood Borough Council has now published much of its previously missing evidence as set out in previous Regulation 18 representations. The Council is not satisfied that the Plan has been adequately informed by its evidence, and it questions whether the Spatial Strategy reached is therefore justified and consistent with national policy.
The Council has noted the two Growth Corridors. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia), which helps to put this investment into use through the growth locations. The South Brentwood Growth Corridor, whilst at its far west includes the M25, the remainder of the corridor consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c). It is not considered they offer comparable choices in terms of the capacity of these transport connections and the Central Brentwood Growth Corridor, by the presence of nationally and regionally maintained infrastructure.
In reviewing the appropriateness of the Spatial Strategy, an important element of the Plan's Sustainability Appraisal involves appraising 'reasonable alternatives' to inform development of the Plan. Four reasonable site alternatives in the Central Brentwood Corridor have been disregarded (AECOM Sustainability Apprial - Table 5.2), despite having few constraints and being able to tap into the potential for movement capacity offered by this superior corridor. This is considered to be in conflict with sustainable development when sites which have significant constraints to development or delivery have been included within the Plan, at the expense of sites which have fewer constraints. This raises fundamental concerns about the Plan's spatial distribution of growth and whether it has made the most of the capacity in this alternative corridor, before embarking on a new standalone settlement at DHGV in the Southern Brentwood Growth Corridor. The Council has noted that four sites on Table 5.2 of the Sustainability Appraisal have the potential to deliver 2,200 homes through extensions to villages, thereby questioning the need for a new settlement of the scale envisaged to deal with growth in the plan-period, which it considers means the Spatial Strategy is unjustified. The Council therefore objects to Chapter 3, the Sustainability Appraisal and land use allocations in Chapter 6 and 7.
Modification: Using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the superior infrastructure available. This should help encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Chapter 3 should be modified as a result along with all land use allocations in Chapter 6 and Chapter 7.
Consultation Point: Sustainability Appraisal
Soundness - Justified and consistent with national policy.
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contribution to the achievement of sustainable development. The Council challenges whether the Sustainability Appraisal has informed the choices made in the Spatial Strategy as
required by national policy, given it states that there was an early intention by Brentwood Council to deliver at least one new large-scale strategic site, which could be judged as artificially limiting the exploration of other plausible and deliverable urban/ village extensions. It is considered that Brentwood Council's lack of a Housing and Economic Land Availability Assessment (HELAA) between 2011 and 2018 has negatively impacted upon previous Regulation 18 drafts, which could have evolved differently having been informed by such evidence, demonstrating that other suitable, available and deliverable site options were present. This is unjustified, not consistent with the Plan's Strategic Objective SO1 and not in accordance with the NPPF. The Council therefore objects to the Sustainability Appraisal.
Modification: The Sustainability Appraisal should be reviewed to test an alternative strategy which does not include the artificial assumption that at least one new large scale strategic site should be incorporated into the Local Plan and then it should be amended accordingly. The Plan should then be reviewed informed by the outcome.
Consultation Point: BE11 and Paragraphs 5.106
The Council has reviewed the Brentwood Borough Infrastructure Delivery Plan (IDP) accompanying the Local Plan. It is acknowledged that this is intended to be a 'live' working document, much the same as the Basildon Borough IDP.
Paragraph 5.105 acknowledges that in respects of the South Brentwood Growth Corridor "...the provision of sustainable transport in this area is poor". The Council considers that it is surprising therefore that there are no specific highway mitigation measures provided in the Plan, just a statement that "the Council will work proactively with developers, key stakeholder and service providers to implement...new measures which would seek to mitigate transport impacts of sites on the highway infrastructure...". Whilst it is acknowledged within the Plan of the joint working being undertaken by ASELA, and the A127 Task Force for the Route Management Strategies and Joint Strategic Plan, both of which are supported by Basildon Council. The Council does however consider that highway modelling should have been tested to determine impact in development locations in Brentwood Borough, so it can be clear in policy terms how negative impacts are being mitigated and therefore prove that the Plan's spatial choices are reasonable in sustainability terms. It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace as suggested in Appendix 1, becomes hindered by a lack of infrastructure capacity and outline solutions to overcome them. It is not considered that Policy BE11 is therefore effective at delivering the Plan's Strategic Objectives.
It is noted that Paragraph 5.106-5.107 acknowledges the Lower Thames Crossing and the outline concept of its preferred route and that it is not expected to have a direct impact on Brentwood Borough in terms of land safeguarding. It is however suggested that the Plan also acknowledges that following the engagement of authorities in Essex, including Basildon Borough Council, Highways England has accepted that its impact modelling was deficient in determining how driver behaviour in South Essex and further afield could alter when the scheme opens. This is particularly an issue for this Plan, as its includes land allocations in West Horndon and the DHGV along the A127 corridor, which will be within a reasonable proximity to the Lower Thames Crossing and could therefore be impacted by it. It should be recognised that Highways England are now taking steps to incorporate growth proposals set out in Local Plans in the vicinity to address this point and identify any measures needed to the scheme or nearby routes to mitigate any adverse impacts. The Council therefore objects to Policy BE11 and Paragraphs 5.106.
Modification: 1) BE11 and the land allocations should have been informed by highway modelling that tests highway mitigation solutions to mitigate impact caused by development. This work should be repeated and the Plan amended in light of its findings.
2) Paragraph 5.106 should be amended to include reference that local authorities have secured additional testing within the Lower Thames Crossing modelling being undertaken by Highways England to determine the extent of local impacts on the road network arising from Local Plan growth.
Consultation Point: R01 & HP01
Soundness - Justified
The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs and it is considered that there may be implications for the future geographical extent of both the Brentwood and South Essex Housing Market Areas as the housing markets evolve.
Furthermore, the policy requirements of the Plan are informed by data collected from Brentwood Borough, or its population; the significant majority of which is located away from this area to the north. Consequently, there is a difference in what might be delivered in DHGV compared to what could be delivered just slightly to the east in Basildon Borough; which might distort the housing markets as they adjust to the new development taking place around the boundary. The following table has been prepared using Figure 6.1 from the Plan and the South Essex Strategic Housing Market Assessment that has informed the Basildon Borough Local Plan 2014-2034 and it is considered both these SHMA's should instead be used to inform the housing mix policy for DHGV. The Council therefore objects to Policy R01 and HP01.
Modification: It is considered the stark contrast between the house size requirements for Basildon and Brentwood in DHGV, which is on a boundary location, means it needs to have taken into account the South Essex SHMA in determining the housing mix for DHGV so that it can better sit within the landscape of the strategic context of South Essex, which is not reflective of the wider Brentwood Borough HMA. Policy HP01 and R01 should be amended in light of this.
Consultation Point: R01(D)(h)
Soundness - Justified and consistent with national policy.
The Council has noted that Policy R01(D)(h) has set a target to retain 50% of the strategic allocation for green and blue infrastructure. Given the location is over 259ha, it is agreed that this helps enshrine the Garden Community values within the policies which will guide the masterplan and the site's development. However, the Council questions whether this is intended to be a permanent resource, given it also determines that a further 2,300 homes could be brought forward in the strategic location after 2033; taking its indicative total to around 4,000 homes. It is considered that if it is not explained clearly in any published evidence, as to whether any of the retained space for green and blue infrastructure would need to be used to meet this higher development scale after 2033. The Council's understanding of this, is frustrated by a lack of published evidence on DHGV, which would enable Basildon Borough to effectively understand the nature, extent and potential implications (positive or negative) of its proposals for DHGV. This would make the policy more justified and compliant with national policy. The Council therefore objects to Policy R01(D)(h).
Modification: Clarify within R01 and its supporting text whether the Green Infrastructure proposed to amount to 50% of the land area is a permanent resource or whether the projected growth in the area beyond the plan-period would need to utilise any of the green infrastructure for growth. If the latter, the percentage should be adjusted accordingly.
Consultation Point: SP02, R01 and Paragraph 8.83-8.84
Soundness - Justified
The Council welcomes the publication of the Brentwood Borough Green Belt Study 2018. It is acknowledged that this comprises two parts; Part 1 is a full Green Belt assessment parcelling up the Green Belt and Part 2 as a separate site assessment of individual sites promoted through the Housing and Economic Land Availability Assessment (HELAA). This is a similar format to the Basildon Borough Green Belt Study.
For Part 1, a scale of high - low was used to assess the contribution 70 separate parcels made to the Green Belt. The DHGV parcel (17) score "Moderate - High". It was one of 21 parcels to score "Moderate - High". 19 parcels scored "High". The remainder scored lower.
In respect of the tests, Parcel 17 was assessed as follows:
* Purpose 1 - to check unrestricted sprawl of large built up areas: Not contained i.e. development would constitute urban sprawl (red)
* Purpose 2 - to prevent neighbouring towns merging into one another: Important
countryside gap between settlements (amber)
Purpose 3 - to assist in safeguarding the countryside from encroachment: Functional countryside (red)
Purpose 4 - to preserve the setting and special character of historic towns: Limited relationship with a historic town. (green)
The Council does not consider it to be clear however, from the published methodology, as to why having scored highly in relation to the Purpose 1 and Purpose 3, as to why this parcel is assessed as making a "moderate to high" contribution to Green Belt purposes, when there are other parcels which make high contributions towards two of the purposes have been assessed as making a "high" contribution towards Green Belt purposes; and are therefore valued to a greater degree as serving towards the purpose of Green Belt.
In respects of Part 2 assessment, the DHGV allocation (Site 200) was assessed alongside other HELAA sites. A total of 92 sites were assessed. The DHGV site assessment matches the entire Parcel 17 assessed in Part 1. Five sites were assessed as making a "high" contribution towards Green Belt purposes. A further 18 sites were assessed as making a "moderate to high contribution". Site 200 - 'Entire land east of A128, south of A127' was assessed as making a "moderate to high" contribution. The remaining 69 sites were assessed as making a less significant contribution to Green Belt purposes.
The DHGV site was assessed as follows:
* Purpose 1 - to check unrestricted sprawl of large built up areas: Not contained i.e. development would constitute urban sprawl (red)
* Purpose 2 - to prevent neighbouring towns merging into one another: Would result in significant separation reduction (amber)
* Purpose 3 - to assist in safeguarding the countryside from encroachment: Functional countryside (red)
* Purpose 4 - to preserve the setting and special character of historic towns: Limited relationship with historic town (green)
The outcomes of Part 2 are considered to be consistent with Part 1. However, it is not clear from the methodology as to why given the site scored highly in relation to Purpose 1 and Purpose 3,
this parcel is then assessed as only making a "moderate to high" contribution to Green Belt purposes, when it could potentially have been assessed as making a "high" contribution for those reasons.
The Council recognise that there is now, no longer an issue with missing evidence in this regard, which it had repeatedly raised in previous Regulation 18 consultation responses. However, the Council considers that the issue now is one of how the Green Belt evidence has informed the Plan. It is not clear how the policy judgements arrived at have considered that development in this strategic gap, which helps prevent settlement coalescence can be adequately mitigated. The Council does not believe that when accounting for this evidence that the Plan has reached a justified position in respects of whether the Green Belt evidence has informed the Local Plan policies, to the degree which the proposals in the DHGV area are set out. The Council therefore objects to Policy SP02, R01 and Paragraphs 8.83-8.84.
Modification: The Plan should demonstrate in more detail, through a tool such as a Topic Paper, how its site selection choices have been informed by the Green Belt Study 2018 and should any inconsistencies occurs the Plan's land use allocations and justification should be changed.
Consultation Point: Paragraph 9.36 and R01(II)
Soundness - Justified & Effective
Brentwood Council will be aware from joint Duty to Cooperate meetings with elected members and officers that during 2017, efforts were made by both Basildon and Brentwood Councils to determine whether a West Basildon urban extension could be delivered in the Basildon Borough Local Plan, alongside DHGV, whilst maintaining a sense of visual separation between both developments. To this end, a joint Dunton Area Landscape Corridor Design Options Study was commissioned by both Councils, which I have enclosed as evidence against this representation, to consider how both Council's Green Belt and land management policies, either side of the boundary, could be coordinated in this location going forward. This was to also help determine whether it was possible for DHGV to co-exist with development in West Basildon without causing harm to heritage and environmental assets within Basildon Borough.
The Council has noted that the Plan does now includes specific references that the joint borough boundary needs a degree of landscape and Green Belt treatment to maintain a visual separation with the edge of Basildon Borough, but it does not elaborate as to how this will be achieved. The Council therefore finds its disappointing that this joint study does not form part of the referenced and published evidence base for the Plan, nor do the outcomes from this work appear to have informed Policy R01(II) as sought through the earlier Duty to Cooperate engagement. The Council therefore objects to Policy R01(II) and Paragraph 9.36.
Modification: The measures set out in the Joint Dunton Area Landscape Corridor Design Options 2017 should be acknowledged in Paragraph 9.36 and incorporated into Policy 9.36 to make it more justified and effective at mitigating the impact the development would otherwise have on the Basildon Borough. This would lead to an effective policy outcome identified as being necessary during Duty to Cooperate engagement to manage this cross-boundary issue. It is considered that as a matter of principle, this would help address the Council's previous Regulation 18 objections as to how the boundary would be treated and how the new community could exist side by side the existing smaller settlement of Dunton Wayletts in the Basildon Borough.
Consultation Point: SP04 and R01(I)
Soundness - Effectiveness, Justified & Compliance with National Policy
It is noted that the Plan assumes that all commuters will use West Horndon railway station and other areas in Brentwood Borough to access a means of travelling to other places. It fails however to investigate the possible impacts on Basildon Borough's road and rail infrastructure, as a
neighbouring authority, arising from commuters or other road users choosing to access facilities within the Basildon Borough instead.
The Transport Assessment (PBA, 2018) discusses measures to ensure more effective bus access to and from West Horndon Station - serving an area including the new DHGV, as well as other employment sites within South Brentwood Growth Corridor. It is noted however that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable.
The Brentwood Borough IDP states that a new multi-modal interchange will be created at West Horndon Station. This will serve the DHGV, Childerditch, West Horndon and Enterprise Development sites. It also mentions the possibility that this could serve any future northern Thurrock developments. The Plan states that, the proposed DHGV settlement's transport mitigation measures will include potential dedicated bus route(s) connecting the development with West Horndon station and improvements at West Horndon station for vehicular, segregated cycle and public transport access from surrounding developments, as well as cycle storage and a bus interchange facility. The Council is therefore confused that in seeking to mitigate DHGV's impacts on the surrounding areas there is no mention of any impact being evaluated as spilling over into Basildon Borough and needing its own mitigation.
Laindon railway station, with three platforms and starter trains has greater commutable capacity than West Horndon and could become an alternative choice for residents within DHGV, despite a lack of new connections hampering their ability to make that choice easily without driving, via the A127. Whilst the Plan seeks to make provision for a new interchange at West Horndon to capture these movements more locally, should commuters still seek to use alternative stations including those outside of the Brentwood Borough such as Laindon, this will lead to increase demands on those stations' facilities, particularly parking, as well as the routes to get to them. Policy SP04 does set out the approach required by Paragraph 34 of the NPPF, but it does not explicitly mention that it has accounted for the spatial context of DHGV and the existing spatial form of the Brentwood Borough, where its higher-order settlements are further to the north. It does not state that it will support the possibility of developer contributions being used to mitigate this impact outside the Brentwood Borough in higher-order settlements which are closer that Brentwood Borough's own settlements, but outside the Brentwood Borough. This is considered to disregard how new residents living in the DHGV could behave in the future in seeking to access services and how this impact will therefore be adequately mitigated.
It seems that it an effort for the new DHGV to be self-sustaining, as set out in Paragraph 9.14, it has meant the Plan remains unclear, as to how it will relate to its neighbouring areas, particularly in terms of access and connectivity. This is considered a core sustainability principle for new developments and whether in exercising that choice, its residents will use what is to be provided within Brentwood Borough remains to be seen. They could use alternative routes (namely the A127 and West Mayne into Laindon) to access different facilities already available in closer higher order settlements outside Brentwood Borough. Considering that there are existing services that are already shared between the Borough's residents, e.g. schools, it is considered essential for a more practical and pragmatic approach to be adopted should the DHGV be permitted, including the policy reality that until such a time as the critical mass for new homes is established on-site, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the neighbouring Brentwood Borough in the short-medium term.
There is no evidence presented by Brentwood Borough Council which indicates that DHGV's growth demands have been evaluated, in combination, with the projected demands arising from the Basildon Borough Local Plan. The Plan should not assume that such growth can just be absorbed by the nearby infrastructure and services in Basildon Borough and investment through developer contributions will be necessary. The infrastructure in the Basildon Borough has been evaluated for its capacity, its ability to grow and the scale of investment necessary to accommodate the growth in the Basildon Borough Local Plan to enable the Basildon growth to occur and there has not been enough information published during Regulation 18 (as set out in previous
representations) to be able to incorporate any testing of Brentwood's growth in as well. The Council therefore objects to Policy SP04 and R01(II).
Modification: The Plan should be modified to recognise that some impacts are likely to be cross-boundary and additional provisions should be incorporated into SP04 and RO1(I) that will support using S106/CIL arising from development in Brentwood Borough to be used for investment outside the Brentwood Borough, where it can be proven that there is reasonable likelihood of a direct or residual impacts otherwise being caused that need to be mitigated. This will make the Plan more effective, justified and in accordance with national policy.
Consultation Point: R01(I) and Appendix 1
Soundness - Justified & Effective
The Council notes the housing trajectory included within the Plan at Appendix 1. With regards to DHGV it is assumed that delivery will commence in 2022/23 (within the next five years) at a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. As set out in earlier representations in respects of housing supply, this seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires masterplanning and will need to go through a planning application and elements of the condition discharge process before development on site can even commence. Development commencement on-site meanwhile, will be reliant on essential utility and infrastructure provision. No evidence is provided alongside the Plan, or within the associated Housing and Economic Land Availability Assessment (HELAA), as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base, or any form of a development framework/ masterplan for the DHGV that explains how the proposed accelerated rate of delivery will be possible to achieve.
The Council considers that the speed and level of growth in this boundary location may have implications for Basildon Borough's own housing market and risks the ability for it to be able to deliver housing at the rates necessary for its own housing trajectory. Early residents of the DHGV will rely on some services and facilities outside the village to meet their initial needs, unless these facilities were all to be front-loaded and wait for the population to gradually build up to make full use of them. As an example, the DHGV will require new primary and secondary school provision. However, whilst the Brentwood IDP shows the primary provision in particular being delivered early, it is understood to not be economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality (principally within the Basildon Borough), whilst operational primary and then secondary education provision is secured and the village becomes more self-sufficient. The Council therefore objects to Policy R01(I) and Appendix 1.
Modification: The Council therefore seeks for evidence to be provided demonstrating the realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby. This will make the Plan justified and effective.
Consultation Point: R01(II)
Soundness - Effectiveness
Notwithstanding that the Council objects to many of the fundamental soundness principles of the DHGV, the Council would like to seek assurances written into Policy R01(II) that it will be invited by Brentwood Borough Council to become more involved in the detailed design and delivery of the new village. This will ensure that the strategic and cross-boundary impacts covered by the Duty to Cooperate and raised during the Council's response to the Plan at Regulation 18 and 19 stages are managed effectively during the development's implementation stages (assuming it is
considered sound), alongside the Basildon Borough Local Plan's own implementation. The Council therefore objects to Policy R01(II).
Modification: The Council would like a criterion added into Policy R01(II) under a new heading "Collaborative Approach" that will make it a requirement for neighbouring authorities to be engaged during the detailed design stages of DHGV to ensure strategic and cross boundary impacts are managed effectively during implementation.
This concludes the Council's representation.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Appendix 1 should be amended to reflect the evidence provided by available evidence on the delivery of major developments. Additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated.

We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.

The Council should take the opportunity to allocate further smaller sites within the Local Plan, assisting in providing flexibility and improving housing delivery in the short term.

1.0 Introduction
1.1 These representations on the Brentwood Borough Council Proposed Submission Local Plan (PSLP) Consultation Document (Regulation 19) are submitted by Strutt & Parker on behalf of Catesby Estates Plc in respect of their land interests at Land at Wyatts Green Lane, Wyatts Green.
1.2 The site is identified under reference 071 in the Council's evidence base documents, including the Sustainability Appraisal. A location plan for the site is provided at Appendix A.
1.3 Representations have previously been made on behalf of Catesby Estates Plc in respect of this site to the 2016 Draft Local Plan Consultation and the 2018 Regulation 18 Preferred Site Allocations Consultation.
1.4 Prior to that, the site was included in the 2011 Strategic Housing Land Availability Assessment (SHLAA), having been promoted on behalf of the landowner W.H. Norris & Sons, under the reference G029. It was identified as suitable, available and achievable.
2.0 Housing Need
Plan Period
2.1 The plan period is currently stated as up to 2033 in paragraph 1.1 of the PSLP, with adoption intended for 2019. The National Planning Policy Framework (NPPF) states that strategic policies should look ahead over a minimum of 15 years from adoption (paragraph 22). Should the Council's timescale be achieved and the Local Plan adopted in 2019, the plan will only address development needs for a maximum of 14 years.
2.2 Furthermore, we consider adoption in 2019 an overly optimistic timescale given the plan is yet to be submitted, there will need to be hearing sessions, likely consultation on main modifications, and the plan to go to Full Council before it can be adopted. It is therefore likely that the plan will not be adopted until after 2019, further reducing the effective plan period.
2.3 This is especially pertinent for Brentwood as, given the constraint of the Green Belt, the failure to plan for development needs over a sufficient period of time is likely to trigger an early review of the Green Belt. This would be contrary to the NPPF (paragraph 136) and would undermine the permanence of the Green Belt (paragraph, 133). Increasing the plan period will also have a subsequent effect on the number of homes required over the plan period and result in an increase requirement, which should be reflected in the plan accordingly.
Total Housing Requirement
2.4 Paragraph 35 of the NPPF sets out that Local Plan should seek to meet the identified housing need as a minimum, with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, being an authority with Green Belt, the Local Plan should ensure the Green Belt can endure beyond the plan period (NPPF paragraph 136).
2.5 At paragraph 4.13 of the PSLP, it states the housing requirement is for 350 dwellings per annum, based on the standard method as set out in the NPPF. However, this does not appear to have been calculated using the current guidance, with the PPG confirming that the 2014-based subnational household projections should be used.1
2.6 The PSLP does apply a buffer to the 350 figure, resulting in a proposed target of 456 dwellings per annum.
2.7 Using the 2014-based figures and following the standard method results in a requirement of 452 dwellings per annum.
2.8 This results in the PSLP planning for 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.
2.9 Councils have a duty to cooperate with one another on strategic matters, including on unmet housing needs (paragraphs 24 to 27 of the NPPF). The PSLP does not make an allowance for any unmet needs from neighbouring authorities. Whilst the South Essex authorities are working together on a joint strategic plan, the Local Plans for each authority must still demonstrate joint working and a consideration of unmet needs where required.
2.10 A number of nearby authorities have identified difficulties in meeting their own housing needs, including Castle Point, Rochford and Southend. Furthermore, the Borough is located within close proximity of London, with the emerging Local Plan identifying high housing delivery on outer London Boroughs and that London will fall short of meeting its housing needs by 10,000 homes over the next ten years. Unmet need from London could therefore be required to be met by nearby authorities, including Brentwood.
2.11 Whilst no authority has formally approached Brentwood in relation to unmet need, it is not inconceivable that an authority will do. Under the current PSLP there is no flexibility to meet any unmet needs from neighbouring authorities, requiring a plan review should a request to meet unmet needs be received once the plan is adopted.
2.12 Allocating additional sites would provide greater flexibility should a request to meet unmet needs be forthcoming, avoiding the need for an early plan review. This flexibility met over the last three years, being significantly below the 85% threshold.
2.15 This identifies the importance of delivering housing in the short term to improve choice and options for local people.
2.16 This is further confirmed through the five-year housing land supply position, which the Council consider to be 4.1 years. However, this understates the need (not being calculated in accordance with the updated standard method) and overstates supply.
2.17 The actual supply is therefore less than the 4.1 years identified by the Council. 2.18 The results of the Housing Delivery Test and shortfall identified supply reiterate the importance of the Local Plan providing a range of sites to deliver housing over the plan period.
Housing Trajectory
2.19 The PSLP sets out housing allocations to meet the identified need within Section 9 of the PSLP, being both strategic and non-strategic allocations. A significant portion of the allocations are strategic sites, with 68% of the houses allocated on strategic sites.
2.20 Whilst strategic sites can deliver a large amount of housing and other infrastructure, by their nature they have a longer lead-in time than smaller sites. Whilst some of the strategic sites will be able to come forward quicker than others, we would caution against some of the anticipated delivery in the housing trajectory within the PSLP.
2.21 Some strategic sites are anticipated to deliver a high number of new homes within 2021/22. Even if the Local Plan is adopted in 2019, which we consider overly optimistic, this does not allow sufficient time for a masterplan to be prepared as required by many of the strategic allocation policies, planning applications brought forward, infrastructure provision negotiated with the various parties, and for conditions to be discharged. We consider that some of the anticipated delivery rates may be overly optimistic.
2.22 Furthermore, the PSLP sets out at paragraph 4.18 that it has not been possible to identify sites to deliver a five-year housing land supply against the full housing need in the first part of the plan period. On this basis, it seeks to provide a stepped trajectory in accordance with Policy SP02.
2.23 We consider that such an approach is not necessary, and not to the extent identified. There is a high reliance on strategic sites within the PSLP, with a limited number of smaller sites identified.
2.24 The allocation of further smaller sites will provide a greater amount of flexibility and additional dwellings within the early part of the plan period. It could also reduce the need for a stepped housing trajectory.
2.25 The Council should take the opportunity to allocate further smaller sites within the Local Plan, assisting in providing flexibility and improving housing delivery in the short term.
3.0 Proposed Approach to Wyatts Green
3.1 Wyatts Green is defined as a Category 4 settlement within the PSLP settlement hierarchy as set out in Figure 2.3.
3.2 The hierarchy predicates that development within category 4 villages is only to be encouraged within brownfield locations. It must be recognized, however, that brownfield opportunities are limited in rural settlements, with the case being no different for Wyatts Green.
3.3 There are currently no sites allocated for any additional growth in Wyatts Green. Given the very limited amount of brownfield land that could be redeveloped to provide housing in the village, it is difficult to envisage any new development coming forward in the area over the plan period.
3.4 Wyatts Green is a small rural settlement north of the Borough amongst a cluster of neighbouring villages, namely Hook End, Doddinghurst and Stondon Massey. The village comprises residential development contained largely to the east of Wyatts Green Road / Mill Lane and south of Hay Green Lane; a small amount of linear housing resides along the west of Wyatt's Green Road.
3.5 A regular bus service runs through Wyatts Green providing frequent buses to surrounding centres including Brentwood, Shenfield, Blackmore and Ongar; all of which have a wide range of services, facilities and employment opportunities for the local population.
3.6 The nearby larger village of Doddinghurst offers a greater level of services, facilities and amenities, with a pharmacy, church, village hall, infant school and a convenience store located along Church Lane; Church Lane dissects Doddinghurst from west to east forming one of the main entry routes from the south into Wyatts Green.
3.7 The NPPF promotes appropriate development steered towards rural locations and settlements to sustain and enhance the vitality of rural communities. Paragraph 78 is of particular relevance as it makes clear:
[...] Where there are groups of smaller settlements, development in one village may support services in a village nearby.
3.8 National policy therefore supports sustainable development in rural settlements with limited services and facilities, such that the size and scale of any new development is proportionate to the level of additional demand for services that can be absorbed by surrounding villages.
3.9 In the case of Wyatts Green, although its offering of services, facilities and amenities islimited, the nearby village of Doddinghurst is well placed to absorb additional demand arising from new development in Wyatts Green, such that the population increase arising from any new development is proportionate and does not place too great a strain on the existing provision in Doddinghurst.
3.10 In the absence of suitable brownfield sites and opportunities to sustain rural vitality, Green Belt release should be strongly considered as means of providing sustainable additional growth in Wyatts Green. The PSLP in its current form is considered contrary to paragraphs 77 and 78 of the NPPF which state Local Planning Authorities should be responsive to local needs and promote sustainable development in rural areas.
3.11 Allocating a site, such as that North of Wyatts Green Lane, would provide housing for local people within the existing community and support the surrounding villages, in accordance with paragraphs 77 and 78 of the NPPF.
4.0 Land North of Wyatts Green Lane
4.1 The site measures circa 4.48 hectares and comprises pastoral grazing land, demarcated by hedgerow in the middle north to south. Thick trees and hedgerow bound the site to the north and south, with a low lying hedgerow to the east. Residential development lies adjacent to the west and south west of the site. Given the boundaries of the site, it is well contained.
4.2 The site is currently on land allocated within the Green Belt and lies outside, but adjacent to, the eastern edge of the settlement boundary of Wyatts Green.
4.3 It is considered the site is suitable to provide a proportionate extension to the existingarea of Wyatts Green, providing a range of housing to meet local needs, includingaffordable housing. A Vision Framework is included at Appendix B demonstrating how the site can be developed in more detail.
4.4 Despite the total site area of 4.48 hectares, the developable area has been restricted to 1.85 hectares to remain sensitive to the local character and surrounding landscape; thiscould deliver in the region of 55 dwellings depending upon density and detailed housing mix.
4.5 The remainder of the site would provide green infrastructure, including natural/seminatural green space, children's play, community green space and SuDS features. New public footpaths can also be provided throughout the green infrastructure.
4.6 No Public Rights of Way (PRoW) cross the site, with it being entirely private with no public access. A PRoW does lie adjacent to the eastern boundary of the site, connecting Wyatts Green Road to Hay Green Lane.
4.7 As part of the development there it the potential to provide a new PRoW along the southern boundary, connecting Wyatts Green Lane to the existing PRoW to the east for the benefit of existing and future residents.
4.8 As part of the development a significant amount of green infrastructure could be provided, opening up a large amount of the site to the public. Compared to the current private use of the site, this represents a significant benefit for existing residents as well as future residents.
Assessment of the Site by the Council
4.9 The site was assessed in the 2011 Strategic Housing Land Availability Assessment (SHLAA). The SHLAA concluded that the site was suitable, available and achievable for development. The circumstances under which the site was assessed in 2011 remain the same and it should therefore still be considered suitable, available and achievable.
4.10 However, within the updated Housing and Economic Land Availability Assessment (HELAA), the site was discounted from the HELAA process due to it being within settlement category 4 and no assessment of the site was undertaken.
4.11 Similarly, the site was discounted at an early stage of the Site Selection process (within the Site Selection Methodology and Summary of Outcomes document) due to its location within a category 4 village.
4.12 It is considered this decision to apply policy considerations to the evidence base has not allowed a full assessment of the suitability of the site for development and is contrary to paragraphs 77 and 78 of the NPPF.
4.13 The site has been assessed through the published Sustainability Appraisal, although it is only considered within Appendix III which considered all sites put forward to the HELAA.
4.14 The site was further assessed under the SA, being scored as having 'no issue' under the majority of the criteria. The site received amber scores against Green Belt (as did the vast majority of sites), agricultural land and primary schools. It should be noted that any agricultural land scored either amber or red by its nature, with amber meaning the site falls within Grade 3, being the lowest quality agricultural land. In relation to primary schools, to score well a site needed to be within 800 metres. The nearest primary school is less than 1 mile from the site, being easily accessible by less than a 20 minute walk or less than a 10 minute bus journey. It is therefore considered the site is well located to a primary school, particularly for a village.
4.15 The site did score red in relation to GP and secondary school. Whilst a range of services and facilities are available in close proximity of the site, it should be recognised that it is within a cluster of villages and some larger services, such as a secondary school, will not be viable in that location and it is reasonable to need to travel for some services.
4.16 Overall it is considered the suitability of the site for development has not been adequately assessed through the evidence base of the Local Plan, with a policy decision made early on in the process to discount all sites within a category 4 village. This approach does not allow for proportionate growth to meet local housing needs, or enhance or maintain the vitality of rural communities (paragraphs 77 and 78 of the NPPF).
Green Belt
4.17 The Green Belt Assessment has been undertaken and refined as the Local Plan has progressed, with various stages published. At Stage 2, the Green Belt across the Borough was divided into parcels which were assessed against the five purposes of the Green Belt.
4.18 The Borough was divided into 56 parcels, with many of these being quite large and only a few subdivided.
4.19 As the Local Plan progressed, Stage 3 was undertaken which considered sites on a sitespecific basis. However, a selective approach was taken to identifying sites at this stage, informed by the HELAA. Sites which were discounted for other environmental or strategic reasons were not considered for further assessment. Sites discounted at an early stage of the HELAA process, including those within category 4 villages, were not taken forward for a site-specific assessment.
4.20 The site North of Wyatts Green Lane was not considered within the Stage 3 Green Belt assessment due to the policy decision to discount category 4 villages.
4.21 As above, we are concerned that this approach has not allowed a full assessment of the site and it was discounted very early on by the Council.
4.22 The only assessment of the contribution of the site to the Green Belt purposes is within the Stage 2 Green Belt assessment. Under this, the site was considered as parcel 48, being a large area of land to the north and west of Wyatts Green. This parcel was found to make a high overall contribution to the Green Belt purposes.
4.23 However, it is considered that the site is not characteristic of the majority of the area assessed under parcel 48.
4.24 In respect of purpose 1, to check the unrestricted sprawl of large built-up areas, the parcel was deemed as 'not contained'. Whilst this is true for much of the parcel, the position of the site adjacent to existing residential development to the west and south, contained by woodland to the north and hedgerow to the east, results in the site being well enclosed and contained.
4.25 Furthermore, parcel 48 was assessed as being a critical countryside gap between Hook End and Blackmore. We consider that the site itself, adjacent to Wyatts Green to the east, does not undermine the ability of the wider parcel to perform this role.
4.26 The development of the site will not result in neighbouring towns merging into one another and is not related to a historic town, not contributing to these Green Belt purposes accordingly.
4.27 Overall the site itself, when considered on its own rather than as part of a large parcel, does not make a high contribution to the purposes of the Green Belt and should be considered suitable for release from the Green Belt for development to support the surrounding villages.
4.28 We would caution the Council against the approach of undertaking a review of large parcels only, with relatively few specific sites assessed. The Inspector examining the Local Plan for Welwyn Hatfield Borough Council raised concerns with such an approach, considering the Stage 1 Green Belt review was undertaken at 'such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development adjacent to the urban areas'2.
4.29 We consider this conclusion is equally as relevant to the Council's current Green Belt review. As set out above, an assessment of the site north of Wyatts Green Lane results in a different conclusion to the assessment of the wider parcel. A more specific assessment should have informed the Council's view on whether the site was suitable for release from the Green Belt. We consider the site is suitable for release to providehousing to meet local needs within the village.
5.0 Conclusion
5.1 Overall we consider the PSLP could take further opportunities to allocate smaller sites to improve delivery in the early part of the plan period, improving the five-year housingland supply position and providing much needed housing.
5.2 The PSLP is currently very reliant upon strategic sites, which can have a long lead-in time and other challenges to delivery. Allocating additional smaller sites would reduce this reliance on strategic sites and could provide additional housing throughout the Borough, allowing residents to remain in their existing communities.
5.3 The site north of Wyatts Green Lane was previously assessed as suitable, available and achievable and it is considered nothing has changed which should have altered this assessment. In assessing the site, the Council made a decision to exclude sites within category 4 villages, resulting in the site not being specifically assessed in the Green Belt Assessment or the detailed site assessments.
5.4 Such an approach is contrary to paragraphs 77 and 78 of the NPPF which set out that Councils should enhance or maintain the vitality of rural areas. The allocation of the site for residential development with a large amount of green infrastructure would be in accordance with paragraphs 77 and 78 of the NPPF.
5.5 We consider the PSLP is currently unsound in its approach to rural housing needs for the reasons set out, not being positively prepared or effective. Allocating additional smaller sites would provide greater flexibility within the plan and bring forward greater development in the early part of the plan period.
5.6 The allocation of such sites, including land north of Wyatts Green Lane, could furthermore provide housing to enhance the vitality of the rural area. The approach of the PSLP to rural areas would therefore be positively prepared, effective and justified, meeting the tests of soundness under paragraph 35 of the NPPF.

Appendix 1 should be amended to reflect the evidence provided by available evidence on the delivery of major developments. Additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated.

1.0 Introduction and Background
1.1 This representation for the Brentwood Pre-Submission Local Plan (PSLP) 2019 is submitted by Strutt & Parker of behalf of BPM Investments Ltd, who hold a Promotion Agreement for Salmonds Grove, Ingrave. The site has been promoted to the Council through the previous Local Plan consultations and has been assessed by the Council. The site is identified by the attached location plan (Appendix 1). Representations were submitted in March 2016 for the Draft Local Plan and the site has been considered by the Council through its Strategic Housing Land Availability Assessment (SHLAA) 2011, the Site Specific Sustainability Appraisal (SA), and the January 2018 Site Assessment Methodology, Site Ref. 067a and 067b. Representations to the Regulation 18 consultation were also submitted highlighting many of the same concerns.
1.2 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 Ingrave and Herongate. It is recognised that the settlement boundaries contained within the Brentwood Replacement Local Plan 2005 were predicated on the need to accommodate significantly less development than currently required, and this site is located in a sustainable position on the eastern boundary of Ingrave, in an area of residential character.
1.3 The specifics of the site, and its sustainability for allocation for residential development, has not been recognised in the PSLP. We have raised a number of concerns in respect of the proposed approach in the Brentwood Borough Council Preferred Site Allocations (PSA) Consultation, and set out that should the Council proceed in the current direction it will result in a plan that is unsound. Our concerns do not appear to have been addressed satisfactorily and it is considered that the PSLP, without modifications, is unsound for the following reasons: a. It fails to meet housing need over the entire plan period and is reliant on strategic allocations that will not deliver as promptly as set out in the PSLP Trajectory; b. The PSLP fails to meet the housing needs in full, as there is no accounting for underdelivery in neighbouring authorities; c. The PSLP provides only a very narrow margin compared to the calculation of housing need under the Standard Method, and is therefore inflexible; and d. The Spatial Strategy fails to meet the housing needs of settlements such as Ingrave.
1.4 It is considered that land at Salmonds Farm, Ingrave, should be removed from the Green Belt and allocated for residential development in order to assist with the soundness of the Plan. An illustrative development for the site, which would be sustainable and in keeping with Ingrave, is provided at Appendix 2 to assist in understanding the nature of the proposal. The site represents a modest extension to an existing residential area, within a sustainable location. It represents a deliverable site to assist in meeting the Borough's housing need in the short term with negligible impact on the Green Belt and surrounding landscape. Plan Period
1.5 The proposed plan period runs until 2033. Assuming 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.
1.6 This deficiency in the PSLP is of particular relevance given that the Borough is predominately 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).
2.0 Housing Need
2.1. There is an acute housing shortage at both the national and the local level. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.2. The National Planning Policy Framework (NPPF) attaches great importance to the need for Local Plans to meet objectively assessed housing needs. It is a requirement of a sound Local Plan. Furthermore, the NPPF calls for a significant boost to the supply of land for housing, and requires Local Planning Authorities to ensure a sufficient supply of sites to provide five years worth of land for housing against housing.
2.3. 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).
2.4. 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.
2.5. 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, not 350.
2.6. 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).
2.7. 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.
2.8. 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.
2.9. 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'.
2.10. 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.
2.11. 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 years' 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.
2.12. 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 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
2.13. The Council is required to demonstrate a five-year housing land supply at any point in the plan period.
2.14. 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.
2.15. 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.
2.16. 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.
2.17. 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.
2.18. 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 fiveyear requirement of 2,712 dwellings.
2.19. 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 just 653 dwellings. It is unclear how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply.
2.21. 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.
2.22. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.23. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.24. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to deliver housing completions from 2022/23, i.e. falling within the first five years of the plan.
2.25. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
2.26. 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 is required before development has even begun.
2.27. The ability of larger sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin review (2018) and issues with their complexity have been ably set out in the Lichfield Study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematic due to a range of factors, including establishing the required infrastructure, and the timings of housing delivery associated with those requirements as well as the prolonged or protracted nature of the planning process. The Litchfield's report confirms that the planning process takes on average 2.5yrs for the planning application determination period for schemes of up to 500 units, but that this can double for sites over 1,000 units.
2.28. BPM Investments Ltd is a company owned by housing specialists Arebray Development Consultancy, DAP Architecture and Silverstone Lane and they all deliver schemes consistently within Essex. They are able to provide detailed evidence on the delivery rates of minor and major developments. Two such hypothetical scenarios are provided with this representations (Appendix 3 and 4)
2.29. Scenario 1 provides a 50 Unit Brownfield site. This has outline planning consent and is to be marketed. It contains existing buildings that will require demolition and there is limited contamination. Access can be gained directly from the highway and all mains services are available to the edge of the site without any works required outside the site boundary.
2.30. Scenario 2 is a 200 unit Greenfield site at the edge of an existing settlement. The site is to have outline planning consent and is to be marketed. It is assumed there will be no significant delays due to Archaeology and Ecological constraints but recognise this could be greater depending upon the time of year the programme starts. It is assumed that the site is available for immediate development. Time is allowed for local infrastructure upgrades and new junction arrangements to provide access into the site.
2.31. These scenarios both assume that there are no delays and therefore represent a best case situation for two current projects. We have presumed that workflows will overlap where there are no commercial risks by doing so.
2.32. The scenarios confirm that large scale development can take up to 3yrs to provide the first dwellings after outline planning permission is approved, while smaller schemes are predicted to require two years for delivery of the first units. The timeframe is compounded by the scale of development, as recognized by the other reviews into delivery rates. For the strategic allocations in Brentwood, it is noted that the masterplanning stages are likely to add significantly to these timeframes, which follow from outline planning permission.
2.33. For the above reasons it is 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.
2.34. The strategic sites are expected to deliver 1,555 dwellings within 5yrs of adoption. Given the matters set out above, this is unrealistic and it would not be justified to rely on these sites to meet short term housing delivery. This emphasises the need to review sites such as ref. 067a and 067b to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is sound.
3.0 Spatial Strategy for Growth
3.1. Ingrave is identified as a Category 3 settlement -Villages in sparse rural locations that provide day to day needs for local residents. Ingrave has an established community, with services commensurate with its population. This is highlighted in the Council's own report of November 2017, paragraph 103, which confirmed that Ingrave and other Large Villages provide opportunities for small edge of settlement release to support housing growth. It is important that the Local Plan manages the growth of the settlement to ensure the vitality of its communities is sustained or enhanced.
3.2. Notwithstanding the above, the PSLP proposes to direct no additional growth to Ingrave. This contrasts with the approach to Blackmore, but otherwise the Council's preferred approach for Category 3 and 4 villages is to direct no growth over the plan period. This approach is considered to be unsustainable for these settlements. These views were raised at previous consultation stages. The spatial strategy fails to ensure the sustainable growth of Ingrave. The proposal to direct none of the Borough's housing need to Ingrave is unjustified, and inconsistent with national policy.
3.3. To ensure the Local Plan is sound, the special strategy should be amended to direct a proportionate level of growth to Ingrave. Housing Delivery
3.4. Paragraph 41 of the PSLP states that affordability ratios in Brentwood require an upward adjustment to the housing supply to be made.
3.5. It is recognised that the Council is deficient in providing a five year supply of housing land. It is therefore important to balance the strategic allocations with smaller sites, as these will generally have fewer constraints and can be delivered quickly to assist with meeting the persistent undersupply of housing in Brentwood. Such sites include land at Salmonds Grove, which can be delivered within the first five years of the plan.
3.6. The NPPF expects LPAs to identify the scale and mix of housing the local population is likely to need over the plan period which, among other matters, meets household and population projections, taking account of migration and demographic change; caters for housing demand and the scale of housing supply necessary to meet this demand.
3.7. The proposed plan does not account for migration from London, as identified in the PBA OAN report. This is contrary to the NPPF.
Green Belt
3.8. A detailed Green Belt Appraisal was prepared in respect of the Site by The Landscape Partnership and submitted at the Regulation 18 stage consultation. A copy is provided again here, for completeness (Appendix 5).
3.9. 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: * 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.
3.10. The Green Belt Appraisal provides a thorough review of the site in relation to these purposes, and concludes that: "The initial landscape appraisal fond that developing the site in the manner proposed, e.g. c.24 residential units, would be unlikely to result in any adverse effects on land with a landscape related designation, Conservation Area, or Ancient Woodland. Salmond's Grove Farmhouse to the south of the site is a Grade II Listed Building; however, there is intervening built form between it and the site and it is thus unlikely that development of the type proposed would have a material effect on the farmhouse's landscape setting" (paragraph 5.1.2).
3.11. The Green Belt and Visual Appraisal further concludes that the removal of the site from the Green Belt and its subsequent residential development, would have no significant adverse effect on other landscape features such as topography, hedges, etc.:
3.12. A Part 3 Green Belt Appraisal (dated 31 January 2019) has been published by the Council. This considers specific sites, albeit in limited detail.
3.13. There is no evidence that the findings of the Green Belt Appraisal that was produced in respect of the Site by the Landscape Partnership, and which considered the Site in far greater detail than the Council's Part 3 Green Belt Appraisal, have been taken into account.
3.14. 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. Overview
3.15. The Council's own evidence base states that the site 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.
3.16. The reasons given for the rejection of the site are spurious and based on erroneous conclusions.
3.17. The rejection of the site 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 over the plan period and the lack of support for any growth at Ingrave.
4.0 Land at Salmonds Grove, Ingrave
4.1. The site was discounted from the Site Considerations as part of the Council's Site Assessment Methodology (January 2018). Larger Villages (Category 3 Settlements) are set out in Appendix 6 of the Methodology and repeated in this representation as Appendix 4. The site was discounted on the basis of 'Green Belt Impact'.
4.2. Discounting Salmonds Grove on this basis is unjustified. The Methodology report states that sites were selected based on initial high-level assessments of the key assessment criteria, being, amongst other matters, flood risk, Green Belt, landscape, highways, historic assets, ecological designations, utilities, education and health facilities. There was, therefore, a reasonably extensive set of criteria analysed for each site (para.3.22- 23 of the Brentwood Draft Local Plan - Preferred Site Allocations Site Selection Methodology and Summary of Outcomes Working Draft). The conclusions for each assessment are summarised in the associated appendices of the Report, with Salmonds Grove in Appendix 6 (sites 067a&b).
4.3. For Salmonds Grove, the Site Assessment simply states that there would be 'Green Belt impact'. We are concerned that the assessment and the reasons for discounting an otherwise suitable, available and sustainable site, are not robust.
4.4. Salmond's Grove has been discounted at Stage 4 of the Site Assessments on the basis of an initial high-level assessment, which found that a site was (presumably) satisfactory and suitable on all criteria with the sole exception of impact on the Green Belt. If the site were unsuitable for other reasons, these would also be listed in Appendix 6 of the BBC Report.
4.5. Salmonds Grove adjoins Ingrave and is within Parcel 15 of the BBC Strategic Green Belt Assessment (SGBA). Parcel 15 is 458.4ha in extent, being a roughly square parcel extending from the east of Ingrave to the Borough Boundary. The Assessment concludes that the parcel is of high value to the purposes of the Green Belt. This is not surprising, given the extent of the parcel. However, this assessment is less helpful when assessing smaller sites that are well associated with the urban area, such as Salmonds Grove. The Assessment actually notes under Purpose 1 that the area is 'Very large parcel relative to Ingrave and Herogate'. This belies the unsatisfactory nature of the assessment when considering smaller sites and acknowledges the limitations of the Assessment for such sites. Tellingly, the Green Belt parcels with the least impact, Low-Moderate as identified through the Assessment, are mostly the smaller sites on the edges of urban areas (parcel Nos. 32; 45; 56; 07a (BBC Green Belt Study Part II: Green Belt Parcel Definition and Review; p.43).
4.6. Accordingly, in order to assist the Council in identifying suitable sites within large GB parcels, it is considered that a more fine-grain assessment of sites should be undertaken. This is particularly important, given that the Council are not able to meet the housing needs of the Borough and would meet the tests set out in Calverton Parish Council v Nottingham City Council & ors. [2015] EWHC 1078 (Admin).
4.7. As set out above, the promotor of the site has prepared a Landscape and Green Belt Assessment, providing a full analysis of how it contributes to the five purposes of including land in the Green Belt (Appendix 5).
4.8. This focused assessment concludes that the site: * would be unlikely to result in any adverse effects on land with a landscape-related designation, Conservation Area, or Ancient Woodland; * there would be no significant adverse effect on other landscape features such as topography, hedges; * the site exerts relatively little influence on the surrounding townscape and landscape beyond its immediate vicinity; * Salmond's Grove site makes a Low contribution to the Green Belt purposes, and it could be developed in the manner proposed without compromising the objectives of the wider Green Belt.
4.9. To ensure the plan is sound, it is considered that additional sites should be identified and allocated. Those sites should include those of less importance to the Green Belt, such as Salmonds Grove, Ingrave. Not to include the site in the Local Plan is unjustified.

1. Introduction
1.1 This representation has been is made towards the Brentwood Local Plan Pre-Submission Regulation 19 consultation document, on behalf of our client, RS2 Properties Ltd, who is seeking to promote land at 41 Shenfield Road through the Local Plan process for residential development. A site location plan is attached as Appendix 1.
1.2 The site comprises the dwelling at No.41 Shenfield Road, which is sited within the residential area and outside the Green Belt. Land to the south of the dwelling lies within the Green Belt, albeit abutting the residential area on its southern, western and eastern boundaries.
1.3 Shenfield Road is the main road which links the centre of Brentwood with the A12, which runs through Essex into London. The site lies within a clearly sustainable location, lying 600m from the town centre; 1200m from the train station; adjacent to the Brentwood Sports Ground and Cricket Club; 1200m from primary schools and sports pitches on Sawyers Hall Lane; 300m from Brentwood Community Hospital; and 400m from Brentwood School.
1.4 In all respects, the site lies within a sustainable location and development on this site would comply with the Government's core planning principle to focus development in locations which are sustainable.
1.5 A development on this site of between 30-65 dwellings per hectare (as Policy H14 of the existing Local Plan would require) could result in a scheme of between 21-46 dwellings. RS2 Properties Ltd have not identified any site-specific constraints which would preclude development on this site coming forward and would bring forward development on this site within five years.
1.6 This representation follows the submission of the site, during the 'Call for Sites' in November 2017, as a site suitable for residential development, and representations made in March 2018 in respect of the Preferred Site Allocations (Regulation 18). A copy of these earlier representations are provided as Appendix 2.
1.7 These representations have adopted the format of the Local Plan comments form and are based around answering the following questions:
* Question 5: Please provide details of either:
Why you consider the Plan to be sound, legally compliant, or adheres to the Duty to Cooperate; or
Why you consider that the Local Plan is unsound, is not legally compliant, or fails to comply with the Duty to Cooperate;
* Question 6: Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above; and
* Question 8: If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
2. Question 5
Please provide details of either: Why you consider the Plan to be sound, legally compliant, or adheres to the Duty to Cooperate; or
Why you consider that the Local Plan is unsound, is not legally compliant, or fails to comply with the Duty to Cooperate.
STRATEGIC POLICY SP02: Managing Growth
2.1 It is not considered that the Local Plan is sound, as the Council's Housing Requirement is not considered to have been calculated correctly.
2.2 The Planning Practice Guidance section on 'Housing and economic needs assessment', which was updated on 20 February 2019, confirms at 'Paragraph: 005 Reference ID: 2a-005- 20190220' that 2014 based household projections should be used as the baseline for the 'standard method'. The reason given for this approach is to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government's objective of significantly boosting the supply of homes.
2.3 Paragraph 4.13 of the Local Plan confirms that Council's 'housing requirement figure' to be 350 dwellings per year. With a 20% uplift, the total annual housing requirement is 456 dwellings per year.
2.4 This housing requirement has been calculated within the Strategic Housing Market Assessment, published in October 2018 (i.e. before the latest Planning Practice Guidance assessment). This Assessment confirms that the housing requirement has been calculated using the 2016 population projections as a starting point (see paragraph 8.26 of the SHMA in particular). Accordingly, the Plan cannot be considered to be sound on this basis.
2.5 An indicative assessment of housing need based on the Standard Method using the 2014 population projections was published in September 2017. This stated that Brentwood's housing need, based on the Standard Method, was 454 dwellings per annum. Applying the 20% uplift to this figure would result in a housing requirement of 545 homes per year, or a total of 9,262 homes during the plan period 2016-2033.
2.6 This is an increase of 1,510 dwellings from the housing requirement calculated by the SHMA calculations which uses the 2016 population projections as a starting point.
2.7 Accordingly, we consider that the Inspector should, during the Examination, request that Brentwood update its evidence base, and its housing requirement, to reflect the 2014 based population projections. This will result in the requirement to identify additional site allocations, as considered further below.
2.8 With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan - Pre-Submission Document can be considered to be sound as, in accordance with paragraph 35 of the NPPF, the Plan has not consistent with National Policy in its use of 2016 population projections to determine its housing requirement. In this respect, the plan has also not been positively prepared as it will not, as a minimum, meet its objectively assessed needs.
Chapter 9 - Site Allocations & Local Development Plan Housing Trajectory
2.9 The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Local Plan. Table 4.2 of the Local Plan identifies that the allocations total 6,088 dwellings, with the remaining dwellings comprising completions between 2016/17 & 2017/18 (363 dwellings); extant permissions (926 dwellings); and the windfall allowance between 2023-2033 (410 dwellings).
2.10 Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation.
2.11 The following section of this Representation provides support for land at 41 Shenfield Road, Brentwood, to be allocated for residential development.
2.12 Notwithstanding this, it is considered that additional sites will be required in any event to ensure the housing requirement is met. Appendix 1 of the Local Plan sets out the Council's anticipated Housing Trajectory, which we do not agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears overly ambitious.
2.13 In particular, Dunton Hills Garden Village is identified as being capable of delivering 2,700 dwellings during the plan period, with the site being capable of delivering 100 dwellings starting from 2022/23 (i.e. within 3 years), and then between 150 - 300 dwellings each year thereafter.
2.14 This level of growth from such a strategic allocation does not appear realistic. For example, it is unlikely that the Local Plan will be adopted until 2020 at the earliest (the Council's Local Development Scheme suggests that the plan would be adopted in Q3 2019, but the timescales have slipped as the Plan was due to have been submitted in Q1 2019).
2.15 For a scheme of Dunton Hills, and the level of constraints that it faces, and the vast range of application documents that would be required, including Environmental Assessment, it is realistic to assume that an outline application could take 9-12 months to be determined. Given the level of information that would be required to support the application (Consultant Reports, EA, Public/Statutory Consultation), therefore, it is realistic and reasonable to assume that it may take upto two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission.
2.16 There would then, of course, follow further applications to discharge conditions and Reserved Matters applications, none of which would be straight forward and would require similar levels of detail to an Outline Planning Application. This process could, itself, take 9-12 months, if not longer.
2.17 Accordingly, it is realistic to assume that, from adoption, it would take close to three years before planning permissions have been approved, and conditions discharged, such that development can commence on site. This would mean that, at the earliest, dwellings will not be brought forward until 2023/24, and not 2022/23 as considered by the Housing Trajectory. Such delays in the Council's Housing Trajectory will have inevitable consequences on the Local Authority being able to deliver its housing requirement during the Plan Period.
2.18 As such, it is considered that additional sites will be required during the Plan Period to ensure that a) the Local Authority is able to deliver its housing requirement during the Plan Period (notwithstanding our view that the Council has not calculated its correct requirement); and b) that additional sites will be required to allow for flexibility in allocated sites not being brought forward within the timescales identified within the Housing Trajectory.
2.19 Furthermore, it is considered that the Local Plan is not sound as it does not comply with paragraph 68 of the NPPF.
2.20 Paragraph 59 of the NPPF requires Local Authorities to 'boost significantly' the supply of housing and must, "ensure choice and competition in the market for land". This involves boosting provision of housing from a variety of sources, including small sites which are suitable for smaller housebuilders.
2.21 This is reinforced by paragraph 68 of the revised NPPF, which confirms that small sites make an important contribution to meeting housing requirements and confirms that planning authorities should accommodate at least 10% of their housing requirement on sites no larger than one hectare.
2.22 The Council's housing strategy only allocates 5% on sites no larger than one hectare. The NPPF confirms that smaller sites make an important contribution to meeting housing requirement, in part as they are able to be developed quickly and are able to therefore contribute towards housing supply whilst Strategic Sites are being brought forward in the background.
2.23 Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land at 41 Shenfield Road) should be identified for allocation.
2.24 We would therefore request that the Local Authority reviews its housing supply, and particularly its approach to small sites, and allocate suitable smaller sites which can be brought forward early in the plan period.
2.25 With regards to the Council's approach to housing allocations and its housing trajectory, therefore, it is not considered that the Brentwood Local Plan - Pre-Submission Document can be considered to be sound as, in accordance with paragraph 35 of the NPPF, the Local Plan has not been positively prepared (as it is unlikely that the strategy will ensure that, as a minimum, the plan will meet the Council's Objectively Assessed Need), and is not consistent with national policy in its approach to allocated development on smaller sites.
3. Question 6
Question 6: Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.
STRATEGIC POLICY SP02: Managing Growth
3.1 With regards to Section 2, it is considered that Brentwood Borough Council will need to revisit its evidence base to determine a housing requirement which uses the 2014 population projections as a starting point. This will result in a larger housing requirement, with our estimate based on the indicative Standard Method being approximately 545 homes per year, or a total of 9,262 homes during the plan period 2016-2033.
Chapter 9 - Site Allocations & Local Development Plan Housing Trajectory
3.2 It is considered that additional sites should be allocated to ensure that the Local Authority can meet its housing requirement to 2033. Even if the Inspector agree with the Council's objectively assessed need, it is likely that additional sites will be required to be brought forward given the Council's overly optimistic approach to its housing trajectory, particularly with regards to Dunton Hills Garden Village.
3.3 Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of the NPPF.
3.4 It is considered that land at 41 Shenfield Road is an appropriate site for residential development and should be allocated for between 21-46 dwellings.
3.5 The site includes 41 Shenfield Road, which is sited within the residential area and outside of the Green Belt, and land to the north of the swelling, which lies within the Green Belt. This part of the site is bordered to the south and east by residential development on Shenfield Road and Glanmead.
3.6 There can be no dispute that the site lies within a sustainable location, lying within walking distance of Brentwood Town Centre, Brentwood Rail Station, Brentwood Community Hospital and Brentwood School. The site is therefore a suitable site for residential development, other than for the fact that it lies with the Green Belt and is therefore, technically within the Countryside (albeit bordered on two boundaries by residential development, and entirely enclosed by mature landscaping and woodland on other boundaries).
3.7 Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed 41 Shenfield Road lying on the southern edge of 'Parcel 42 Northwest of Shenfield'. The report when assessing the parcel as a whole, confirms that it abuts the large built up area, and that development within this parcel would be seen as an 'urban extension'.
3.8 The Green Belt Study Part 3 - "Assessment of Potential Housing, Employment and Mixed Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation" - was published in November 2018, and subsequently amended in January 2019. This part of the Green Belt Study assesses the potential Site Allocations against the purposes of the Green Belt.
3.9 41 Shenfield Road is included within Part 3 as site reference 320, with the report considering that the site makes a 'moderate' contribution towards the Green Belt. The report confirms that the site is a relatively small site, contained by woodland cover and adjacent to Shenfield.
3.10 Our own assessment against the purposes of the Green Belt is given below.
* Purpose 1: to check the unrestricted sprawl of large built-up areas The site lies within the urban area of Brentwood, a short distance from the town centre. The site is well constrained by existing built development and mature trees and woodland. Development would be seen as a small infill development and would have a very limited encroachment into the countryside. Existing site boundaries would prevent any further development into the Green Belt, with these boundaries presenting a strong and definite boundary to further development. * Purpose 2: to prevent neighbouring towns merging into one another Development on this site would not significantly reduce the countryside gap between Shenfield and Brentwood. The countryside separation between Shenfield and Brentwood would be retained. * Purpose 3: to assist in safeguarding the countryside from encroachment The site has no specific countryside function, being seen as residential gardens within the context of an Urban Settlement. * Purpose 4: to preserve the setting and special character of historic towns The site has a limited relationship with the historic town of Brentwood.
3.11 Accordingly, it is considered that the site is suitable to be released from the Green Belt.
3.12 Furthermore, it is noted that the Borough Council's proposed allocations allocates a number of sites within the Green Belt which the Green Belt Study confirms as making a 'moderate' contribution to the Green Belt, similar to 41 Shenfield Road, including:
* Site R23 Brizes Corner Field, Kelvedon Hatch (23 dwellings);
* Site R25 Land north of Woolard Way, Blackmore (40 dwellings); and
* Site R26 Land north of Orchard Piece, Blackmore (30 dwellings).
3.13 The spatial strategy shown within the plan as 'Figure 5' confirms that the site lies within a 'Main Town'. Land at 41 Shenfield Road is therefore more sequentially preferable for development than a number of Preferred Site Allocations, such as those within the villages of Ingatestone, Kelvedon Hatch and West Thorndon, and to those identified at paragraph 3.12 of this representation.
3.14 Furthermore, paragraph 3.23 of the Pre-Submission Local Plan confirms that Brentwood will deliver development in terms of a sequential land use test, with land within Urban Areas preferred to all other land. There can be no doubt that land at 41 Shenfield Road lies within the urban area of Brentwood.
.15 Those sites listed at paragraph 3.12 of this representation are located within villages and the
rural area which can offer, as a result of their location, far fewer services and facilities than land at 41 Shenfield Road. These sites, especially, are less sequentially preferable than the site at 41 Shenfield Road.
3.16 Accordingly, we would request that the Local Plan be modified to allocate Land at 41 Shenfield Road for residential development, for 24 dwellings, in accordance with Policy HP03 of the Pre- Submission Local Plan which confirms that residential development proposals will generally be expected to achieve a net density of at least 35 dwellings per hectare or higher. Given the sites location within such a sustainable location, it is considered that 35dph on the site is appropriate and would accord with paragraph 123 of the NPPF which confirms that planning policies should avoid homes being built at low densities, and to ensure that development make optimal use of the potential of each site.
4. Question 8
If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
4.1 RS2 Properties Ltd would welcome the opportunity to present oral evidence to the Inspector, if required, in order to provide further detail in respect of the proposed allocation and to provide further evidence in respect of application timescales and the deliverability of development on this site.
4.2 We would therefore like to participate in the examination process.
5. Summary & Conclusions
5.1 RS2 Properties Ltd is presenting the Council and Local Plan Inspector with a site that is capable of delivering 24 dwellings, within a sustainable location. The site is suitable, available, achievable within five years, is in a highly sustainable location and performs a similar contribution to Green Belt purposes to many of the proposed site allocation within the Pre- Submission Plan. The site is sequentially preferable to these sites, given its location within the Urban Area and its location, therefore, to many shops and services and accessibility to public transport.
5.2 The site and its promoter meet the Governments aspirations and direction of travel in policy in terms of supporting the delivery of much needed small and medium sites to boost significantly the supply of housing and provide choice and competition as required by the NPPF, and which has been reinforced by the revised NPPF.
5.3 It is considered that additional smaller sites need to be allocated to allow for flexibility in the Council's housing supply; and that the Council's OAN may need to be reconsidered in light of the proposed Standard Method for calculating housing supply.
5.4 We therefore urge the Local Authority and Local Plan Inspector to recognise the Governments strategy and allocate the land at 41 Shenfield Road, Brentwood, Essex, CM15 8EN for delivery of 24 dwellings in the first five years of the Plan period.
5.5 Please record this representation as a formal submission towards the Local Plan evidence base and drafting stages and we look forward to the opportunity to presenting evidence to the Local Plan Inspector and answering any questions that the Inspector may have with regards to residential development on this site.

To ensure the Local Plan is sound, there is a need for smaller sites to be supported by policies which will allow their short term delivery.

1. Introduction

1.1 These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients land at Doddinghurst Road (North & South of the A12), which has been allocated under Policy R16 & 17 of the PSLP. A plan showing the site is provided as Appendix A to this representation.

1.2 Countryside was founded in Essex 60 years ago by Alan Cherry and has since established a reputation for delivering high quality developments. With the ethos 'creating places people love', Countryside's achievements are exemplified through having won more Housing Design Awards than any other house builder.

1.3 Countryside is a major development and place-maker, having secured planning permission and building out developments in varying scales: from smaller 30 dwelling schemes on the edge of village's through to large urban extensions of 3,500 new homes plus associated community facilities. Countryside has a proven track record of delivery. The company is headquartered in Brentwood and has a proud legacy of local sites such as Clements Park and the Square on Hart Street.

1.4 The representations set out Countryside's position in relation to the residential site allocation of R16 and R17, both parcels of which fall within their control. The proposed allocation provides for around 200 dwellings and is an important contribution towards BBC's land supply for Brentwood Borough's Draft Plan. The representations provide comments on the relevant policies relating to those interests in the Draft Plan.

1.5 As the Council will be aware, representations have previously been made on behalf of Countryside Properties and in respect of the two parcels of land, towards the Preferred Options Consultation in October 2013 and the Strategic Growth Options Consultation February 2015, and the Regulation 18 Local Plan in March 2018. As a result of these representations, and the discussions that have been held with officers at Brentwood Borough Council alongside the Local Plan process, the two parcels either side of the A12 at Doddinghurst Road have been proposed as a housing allocation within PSLP. From here, the two parcels of land are referred to as "the site", in respect of their joint allocation and policy.

1.6 Countryside's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to the elements of the Housing and Development Management Policies and the housing trajectory relating to the delivery of Policy R16 and R17 during the Plan period.

1.7 Where such concerns are raised, specific changes to the relevant polices are sought and these are indicated in the following representations in order to assist the Council to make the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy.


1.8 Site 023A measures at approximately 5.99ha and Site 023B measures at approximately 2.2ha. The Council have defined the total net developable area of the two sites as 6.14ha. The site is currently designated as Green Belt in the adopted development plan.

1.9 The PSLP has recognised the sustainability of the site and enclosed character, and have therefore proposed it for removal from the Green Belt and for its allocation to provide housing. We support this allocation but do however have some concerns over other policies in the PSLP that may have implications for the efficient and timely delivery of this site.








 

2. Brentwood Local Plan Regulation 19 Consultation
Housing Need
2.1. Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 dwellings per annum. Paragraph 4.12 confirms that this figure is calculated using the Standard Method (as per the NPPF and respective Planning Practice Guidance(PPG)). We note that the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).

2.2. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum.

2.3. The NPPF requires Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.

2.4. At paragraph 4.16 the PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.

2.5. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility or Green Belt protection. Moreover, the figure does not allow provision for unmet need from neighbouring authorities in addition to the minimum requirement.

2.6. At 4.18 the PSLP confirms the Council have not been able to identify a five-year housing land supply to deliver the annualised requirement. Further to this, at 4.19 the PSLP confirms that there is a high proportion of designated Green Belt within the Borough, making it extremely difficult to achieve a five-year supply due to the fact that sites on the edge of settlements, currently within the Green Belt are not available for development purposes until the adoption of the Plan.

2.7. The Borough has a limited amount of previously developed land within its authority to provide for short term delivery, as such Green Belt release is required in order to meet the Authorities housing need and deliver within the short, medium and long term, as stated at paragraph 2.54 of the PSLP. The approach to amend the Green Belt boundaries is therefore supported.

2.8. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement.

2.9. In respect of the above, whilst the current PSLP and associated housing allocations seek to go some way in delivering housing that will support the recognised needs of the Borough over the next 15 years, there is clearly a need to increase this provision. Whilst this could be helped through the identification of additional sites, ensuring the delivery and efficient use of the sites that are allocated for housing will also provide a degree of buffer. Further commentary and recommendations in this regard are provided later within this representation.
Five-year Housing Land Supply and Housing Trajectory
2.10. The Council is required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).

2.11. The NPPF (Paragraph 73) confirms that a 20% buffer should be applied to the initial calculation for a five-year housing land supply requirement, in the event that the results of the Housing Delivery Test show that there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. From November 2018, significant under delivery indicates that delivery was below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037-20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.

2.12. The results of the 2018 Housing Delivery Test confirmed that Brentwood have delivered just 50% of the housing requirement over the last three years and this is therefore well below the threshold for the 20% buffer requirement.

2.13. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is noticeably less.

2.14. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.

2.15. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be 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.

2.16. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can delivery early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.

2.17. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.

2.18. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.

2.19. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is anticipated to deliver housing completions from 2022/23, falling within the first five years of the plan.

2.20. Dunton Hills Garden Village is a proposed major strategic development, intended to provide a new settlement supported by a range of facilities and infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared to ensure that a cohesive approach is taken to the development of the Garden Village.

2.21. As such, it is a concern 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 again demonstrate an inability to rely on large strategic sites for short term housing delivery, and emphasises the need for smaller sites to be supported by policies which will allow their short term delivery to ensure the Local Plan is sound.

Policy R16 & R17: Land off Doddinghurst Road
2.22. Policy R16 & R17 proposes the release of the site from the Green Belt and allocation for around 200 new homes. This approach is supported as an achievable and deliverable solution to contributing towards the Borough's housing land supply to meet the housing need requirement.

2.23. Having regard to the PSLP's housing trajectory, paragraph 9.160 the PSLP states the dwellings are anticipated to be delivered between 2023/24 and 2026/27. We do not support this assumption and object to the timing of the delivery of this site, as set out in the above mentioned paragraph and Appendix 1 of the PSLP. As the Council will be aware, representations have been made to earlier iterations of the emerging Local Plan to confirm the site is available, deliverable and achievable within the first five years of the plan period.

2.24. As currently proposed the trajectory is unsound in relation to this site, and as such is not justified. This is because the site can be delivered earlier than the stated timescales in Appendix 1 of the PSLP. In order to make the housing trajectory sound, amendments to the trajectory must be made to reflect the earlier delivery of the site in the plan period. The proposed amendments would result in a justified approach and a sound policy.

2.25. In addition to amending the housing trajectory to reflect the realistic and earlier delivery of the site, as proposed by a developer with an option on the land, the inclusion of the site within the first five years on the plan period will assist BBC with their five-year housing land supply position, not only assisting in housing delivery of the PSLP is effective and can be found sound at Examination.

Unit Numbers
2.26. Whilst we are supportive of the allocation, we raise concerns in relation to the wording of allocation policies such as Policy R16 & R17 should take this requirement for flexibility into account and worded as such to provide "at least 200 homes", as opposed to "around 200 homes". We consider that this would provide greater certainty on the number of homes to be delivered as part of each allocation for Brentwood Borough Council, and also allows for the delivery of additional units where appropriate opportunities may arise.

2.27. For sites R16 and R17, a significant amount of feasibility work has been undertaken to establish any site constraints, and as a result of this, Countryside are confident in the ability for the site to provide at least 250 homes. We have concerns that the respective policy's current format may be interpreted to confirm the optimum use of the site, rather than a lower limit. In fact, the 200-unit figure has been produced by Brentwood Borough Council with far less rationale and technical justification than has been undertaken by Countryside Properties and may lessen the ability of this site and other policies with similar wording to support Brentwood's need for a buffer and flexibility in their housing land supply.

Access

2.28. It is noted that there has been a change in wording of Part B (b) of Policy R16 & R17 from the November 2018 Proposed Submission Local Plan presented to Committee, and that now being consulted on (February 2019), with no explanation. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.

2.29. Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways.

Policy SP03 Health Impact Assessments
2.30. The Policy requires planning applications for developments of 50 or more to be dwellings, non-residential development of 1,000sqm or more or schemes for C2 class developments to be supported by HIAs. The HBF response to this policy is unsupportive and they consider the policy to be unsound as it is not consistent with national policy and is ineffective.

2.31. We are in agreement with the HBF's response, dated 17th March 2019, in relation to the requirement for HIAs to be provided for 50 or more dwellings and consider the requirement to be unnecessary and an additional burden on applicants. Referring to the PPG we note that HIAs may be useful tools, however the PPG also expresses the importance of the local plan needing to consider the wider health issues in an area and ensuring the policies respond to these concerns. The guidance is provided below for completeness.

2.32. Paragraph: 002 Reference ID: 53-002-20140306 confirms that provision of the required health infrastructure should be supported and taken into account at local and neighbourhood plan making, and when determining planning applications.

2.33. Referring to National policy, paragraph 20 states that Strategic Policies should set out an overall strategy for the pattern, scale and quality of development, this includes infrastructure and community facilities.

2.34. In order for the local plan to be consistent with national policy, the Local Plan should already consider the impact of development on the health and wellbeing of the communities and any identified infrastructure should be addressed in policy. Therefore, whilst Countryside support the important consideration of health and wellbeing of communities where development is in line with the policies contained within the development plan a HIA should not be necessary. The requirement for a HIA should only be triggered where there is a departure from the plan, enabling the Council to assess any impacts on the health and well-being of the community as a result of said proposals.


Policy SP05 Construction Management

2.35. The Policy expects all major development schemes/developers to sign up to the Considerate Constructors Scheme, or equivalent. The scheme is a non-profit making, independent organisation which monitors construction sites signed up to the scheme, with the aim of managing and mitigating impacts arising from construction. This requirement is considered unjustified and inconsistent with national policy.

2.36. Whilst we recognise the importance of managing the potential impacts on construction sites, we consider this policy to be unsound because it is unjustified and not consistent with national policy. We would suggest that consideration for the scheme is best dealt with through planning applications and development management without it being written into formal planning policy.

2.37. We are not aware of any other adopted or emerging Local Plan which requires applicants and developers of major sites to enter into a specified construction management scheme and therefore question the reasonableness of this policy. The matter of construction management should be assessed on a case by case basis and should not be a matter for a strategic policy to prescribe. How a construction scheme is managed and mitigated should be an item for consideration by the decision taker and assessed on a case by case basis.

2.38. The imposition of Policy SP05 requires all major developments to be signed up to the Considerate Constructors Scheme regardless of the site or proposal details. It is recommended that this policy is removed.


Policy BE02 Sustainable Construction and Resource Efficiency

2.39. We consider the policy to be unsound as it is inconsistent with national policy. Part (f) of Policy BE02 requires the inclusion of renewable and decentralised energy as part of a new development, this is not consistent with national policy. Whilst Countryside recognise the importance of sustainable construction, a policy approach to such requirements does not allow for the appropriate flexibility in this regard, as recognised in the NPPF.

2.40. Paragraph 153 of the NPPF states that local plans can expect development to meet such provisions, however the NPPF also states that they are only required to comply with such policies where it is either feasible or viable. To ensure consistency with national policy part (f) of Policy BE02 should be amended to reflect this position.


Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency

2.41. It is Government policy to seek to deliver improvements to emissions from buildings through the building regulations regime. As such we do not consider it necessary to include the table at part (a) of this policy. Should a national zero carbon policy be introduced it will be achieved and applied through building regulations, as noted at paragraph 5.33.

2.42. We therefore echo those comments of the HBF's consultation response, dated 17th March 2019, and suggest that if the building regulations are updated then the Council should revisit the policy through a local plan review at that stage, but that such matters are dealt with through building regulations in the meantime to prevent unnecessary duplicate consideration of such matters through both planning and construction stages.


Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network

2.43. It is acknowledged that the Government support the transition to a low carbon future in a changing climate, including support towards renewable and low carbon energy and associated infrastructure. Countryside support these intentions.

2.44. Part (b) of Policy BE04 expects sites of over 500 dwellings, including where there are clusters of neighbouring sites that total over 500 units, shall incorporate decentralised energy infrastructure in line with a hierarchy however.

2.45. We raise concerns in relation to the deliverability of part (b) of the policy in relation to sites within a cluster of 500 or more dwellings given that neighbouring sites will not necessary come forward by multiple landowners and developers at similar times. The coordinating and implementation of a heat network to serve smaller scale sites as separate applications but adjacent to other similar sized sites in the locality, is unreasonable and unjustified and could result in a delay in delivery of new homes, resulting in an ineffective local plan.

2.46. It is recommended that the requirement for new development located where 'clusters' of neighbouring sites totals over 500 units should be removed from the policy in order to make the policy effective.


Policy BE10 Connecting New Developments to Digital Infrastructure

2.47. It is Government policy to support the expansion of electronic communications networks. However, we would draw the Council's attention to the Written Ministerial Statement, 25th March 2015, which announced that local planning authorities preparing Local Plans, "should not set any additional standards or requirements relating to the construction, internal layout or performance of new dwellings."

2.48. The Local Planning Authority are only allowed to adopt the three optional technical standards, in relation to construction, internal layout and performance, subject to evidenced need and viability. As such, the Council should not seek higher standards than Building Regulations, as already referred to in our response to Policy BE03. Therefore, Policy BE10 is considered unsound because it is unjustified and contrary to national policy.

2.49. We are also unaware of National Policy requiring benches and bins to be connected to mobile digital infrastructure. As such the policy is unjustified and contrary to national policy.

2.50. Countryside are committed to ensuring that all developments go as far as is practical to meet national intentions to ensure the quality, practicality and future-proofing of new housing developments. We have concerns however that by introducing a wealth of additional planning policies in these areas, there will be unnecessary duplication to building regulations, and potentially delays to planning applications which will in turn impact on the timely delivery of new homes.



3. Site Deliverability

3.1. The site represents a deliverable, sustainable and achievable site for residential development. A number of technical reports and associated documents have been completed which demonstrate this. The below section provides a summary of these documents.

Density Study
3.2. A Density Study (January 2018) has been undertaken by JTP Architects.

3.3. As per Paragraph 2.23 of this representation, the Preferred Site Allocations Document (January 2018) states that the indicative dwelling yield of the site is 200 dwellings.

3.4. The Density Study confirms that the total site area is 8.02ha and the total developable area is 6.17ha. Furthermore, it confirms that the site can accommodate up to 250 dwellings with 180 dwellings on Site 023A and 40 dwellings on parcel 023B, which results in 40 dwellings per hectare and 25 dwellings per hectare, respectively.

3.5. The Density Study also provides a Developable Area Plan which illustrates the developable area, the existing trees and root protections areas (RPA), the easements and attenuation and drainage. The plan proposed that the most significant existing trees and foliage are retained.

3.6. Furthermore, the Study characterises the existing landscape features of Site 023A as three naturally formed developable areas. This natural formation will enable an orthogonal street pattern and regular frontage and a more efficient layout of a potentially higher density.

3.7. The study characterises Site 023B as a more irregular shape due to the present underground services. Furthermore, the Density Study identifies that the site has more constrained access opportunities. This has led to a more organic layout of a potentially lower density.

3.8. Given the evidence in the Density Study, the site could accommodate up to 250 dwellings. Further detail on how the site could present a sustainable development opportunity can be found in the summaries below.
Air Quality
3.9. An Air Quality Assessment was undertaken by Ardent Consulting Engineers in February 2017. The assessment reviews air quality constraints affecting the site.

3.10. The assessment concludes that it is unlikely that the proposed development will be considered high risk in terms of construction impacts. It also suggests that there has been a general improvement in local air quality over recent years which is evidenced by the monitored concentrations which are detailed within the report. Nevertheless, the assessment recommends that mitigation measures may need to be adopted as part of the development and be further considered in due course.

3.11. The assessment recommends that the impact of any potential increase in traffic flow on the local road network should be determined by way of a detailed air quality assessment.

3.12. Given the proximity of the A12, there is the potential for the introduction of a new exposure adjacent to the A12. This is dependent on the distance between individual units and the A12 which is to be addressed through careful design by the Architects.


Archaeology
3.13. An Archaeological Desk Based Assessment was undertaken by CGMS Consulting in November 2014.

3.14. The assessment confirms that the site does not lie within an area of archaeological priority, as previously designated by Brentwood Borough Council. It confirms that the site can be considered to have a modest potential for the late prehistoric.

3.15. The assessment also confirms that the site has remained undeveloped land through its documented history.

3.16. The assessment anticipates that Essex County Council archaeological advisors may request additional archaeological mitigation measures, initially in the form of a geophysical survey.

Desktop Noise Report
3.17. A Desktop Noise Report was completed by Ardent Consulting Engineers in March 2016.

3.18. The Noise Report concludes that subject to appropriate mitigation measures, the proposed internal and external areas of the proposed development could be demonstrated to be within desirable noise levels, subject to a detailed assessment.

3.19. The report states that ambient vibration levels may be a concern due to the sites proximity to the A12. These will need to be further addressed during more detailed assessment works.

3.20. Furthermore, a Noise Feasibility Plan has also been produced by Ardent Consulting Engineers. The plan provides a number of layout recommendations for Glazing, Ventilation, Rear Gardens and Balconies and Standalone Barriers. The Noise Feasibility Plan also outlines the closest possible building line on site which has reasonable attenuation and the recommended approximate minimum effective extent of an acoustic barrier. The plan also provides dimensions between the site and the nearest channel of the A12.


Drainage Strategy
3.21. A Drainage Strategy Technical Note was produced by Ardent Consulting Engineers in 2016. The note confirms that existing foul and surface water sewers navigate the site, together with a number of watercourses which will continue to serve the site, post development.

3.22. The report also confirms that the site is within Flood Zone 1 and is therefore suitable for residential development. The note suggests that subject to further investigation and detailed design, a Flood Risk Assessment and Detailed Drainage Strategy can be prepared to support a successful planning application for the development.

Phase 1 Habitat Survey
3.23. A Phase 1 Habitat Survey was produced by SES in 2014. The survey concluded that the habitats on site have the potential to be of value to protected species, as well as being of general biodiversity value themselves. As a result, the Phase 1 Habitat Survey recommends that the following works are undertaken;

* Reptiles (presence/likely absence survey - northern site only);
* Badgers (monitoring of setts on site);
* Bats (tree inspection surveys, activity surveys);
* Breeding Bird (walkover survey during breeding bird season, generally March to August); and
* Invertebrates (walkover survey to establish value for rate and vulnerable beetles).


3.24. It is considered within the survey that any potential adverse impacts from the proposed development upon specific protected species will be able to be wholly mitigated for with careful design.

Social Infrastructure Review
3.25. A Social Infrastructure Review was produced by Quod in February 2017. The review looked to provide an assessment of the likely impact of the development of the site on the demand for school places and healthcare provision.

3.26. The review confirms that based on average household sizes for the area, it is anticipated that the site could accommodate a resident population of approximately 600 people and generate demand for 68 primary school places and 45 secondary school places.

3.27. In line with this estimated growth, the review provides a summary of the education and healthcare provision within Brentwood.

3.28. The review states that although a number of existing primary schools in the Brentwood urban area are being expanded or are due to be expanded, Essex County Council is still expecting to be facing a deficit of places by 2020/21, with the Preferred Site Allocations Document stating that there is an estimated deficit of 541 places by 2021/2022 for Primary Schools. In terms of Secondary School Provision, the Preferred Site Allocations document states that there will be an estimated deficit of 9 places by 2021/22.

3.29. In terms of healthcare provision, the report confirms that the capacity to absorb additional demand arising from developments in the Brentwood Urban Area is limited. The Preferred Site Allocations document confirms this and states that there is likely to be significant pressures on GP Surgeries due to housing growth in the Borough throughout the lifetime of the plan.

Transport
3.30. A Transport Technical Note was prepared by Ardent Consulting Engineers in January 2018. The technical note provides an initial review of the anticipated highway and transportation impacts, based on a potential development of up to 250 dwellings at the site.

3.31. The note confirms that vehicular access to the site could be provided from Doddinghurst Road for the 23A of the site and provided via the extension of Karen Close and Russell Close at the 23B parcel.

3.32. In response to local concerns regarding the suitability of existing public transport provision, the note suggests that the site could generate an additional 7 peak hour bus trips and 35 peak hour rail trips. It is considered that there is sufficient capacity to accommodate these trips. The note confirms that there does not appear to be any specific issues relating to public transport.

3.33. The technical note confirms that the impacts on surrounding roads including Doddinghurst Road and Ongar Road would not be severe and should not be a reason for the site not to be allocated.

3.34. The note confirms that there are no highways issues that would prevent the site from being allocated for residential development in the emerging Local Development Plan.

3.35. The above studies demonstrate that the site is deliverable and sustainable.

Amendments to the trajectory must be made to reflect the earlier delivery of site R16&17 in the plan period.

1. Introduction

1.1 These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients land at Doddinghurst Road (North & South of the A12), which has been allocated under Policy R16 & 17 of the PSLP. A plan showing the site is provided as Appendix A to this representation.

1.2 Countryside was founded in Essex 60 years ago by Alan Cherry and has since established a reputation for delivering high quality developments. With the ethos 'creating places people love', Countryside's achievements are exemplified through having won more Housing Design Awards than any other house builder.

1.3 Countryside is a major development and place-maker, having secured planning permission and building out developments in varying scales: from smaller 30 dwelling schemes on the edge of village's through to large urban extensions of 3,500 new homes plus associated community facilities. Countryside has a proven track record of delivery. The company is headquartered in Brentwood and has a proud legacy of local sites such as Clements Park and the Square on Hart Street.

1.4 The representations set out Countryside's position in relation to the residential site allocation of R16 and R17, both parcels of which fall within their control. The proposed allocation provides for around 200 dwellings and is an important contribution towards BBC's land supply for Brentwood Borough's Draft Plan. The representations provide comments on the relevant policies relating to those interests in the Draft Plan.

1.5 As the Council will be aware, representations have previously been made on behalf of Countryside Properties and in respect of the two parcels of land, towards the Preferred Options Consultation in October 2013 and the Strategic Growth Options Consultation February 2015, and the Regulation 18 Local Plan in March 2018. As a result of these representations, and the discussions that have been held with officers at Brentwood Borough Council alongside the Local Plan process, the two parcels either side of the A12 at Doddinghurst Road have been proposed as a housing allocation within PSLP. From here, the two parcels of land are referred to as "the site", in respect of their joint allocation and policy.

1.6 Countryside's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to the elements of the Housing and Development Management Policies and the housing trajectory relating to the delivery of Policy R16 and R17 during the Plan period.

1.7 Where such concerns are raised, specific changes to the relevant polices are sought and these are indicated in the following representations in order to assist the Council to make the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy.


1.8 Site 023A measures at approximately 5.99ha and Site 023B measures at approximately 2.2ha. The Council have defined the total net developable area of the two sites as 6.14ha. The site is currently designated as Green Belt in the adopted development plan.

1.9 The PSLP has recognised the sustainability of the site and enclosed character, and have therefore proposed it for removal from the Green Belt and for its allocation to provide housing. We support this allocation but do however have some concerns over other policies in the PSLP that may have implications for the efficient and timely delivery of this site.








 

2. Brentwood Local Plan Regulation 19 Consultation
Housing Need
2.1. Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 dwellings per annum. Paragraph 4.12 confirms that this figure is calculated using the Standard Method (as per the NPPF and respective Planning Practice Guidance(PPG)). We note that the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).

2.2. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum.

2.3. The NPPF requires Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.

2.4. At paragraph 4.16 the PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.

2.5. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility or Green Belt protection. Moreover, the figure does not allow provision for unmet need from neighbouring authorities in addition to the minimum requirement.

2.6. At 4.18 the PSLP confirms the Council have not been able to identify a five-year housing land supply to deliver the annualised requirement. Further to this, at 4.19 the PSLP confirms that there is a high proportion of designated Green Belt within the Borough, making it extremely difficult to achieve a five-year supply due to the fact that sites on the edge of settlements, currently within the Green Belt are not available for development purposes until the adoption of the Plan.

2.7. The Borough has a limited amount of previously developed land within its authority to provide for short term delivery, as such Green Belt release is required in order to meet the Authorities housing need and deliver within the short, medium and long term, as stated at paragraph 2.54 of the PSLP. The approach to amend the Green Belt boundaries is therefore supported.

2.8. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement.

2.9. In respect of the above, whilst the current PSLP and associated housing allocations seek to go some way in delivering housing that will support the recognised needs of the Borough over the next 15 years, there is clearly a need to increase this provision. Whilst this could be helped through the identification of additional sites, ensuring the delivery and efficient use of the sites that are allocated for housing will also provide a degree of buffer. Further commentary and recommendations in this regard are provided later within this representation.
Five-year Housing Land Supply and Housing Trajectory
2.10. The Council is required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).

2.11. The NPPF (Paragraph 73) confirms that a 20% buffer should be applied to the initial calculation for a five-year housing land supply requirement, in the event that the results of the Housing Delivery Test show that there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. From November 2018, significant under delivery indicates that delivery was below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037-20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.

2.12. The results of the 2018 Housing Delivery Test confirmed that Brentwood have delivered just 50% of the housing requirement over the last three years and this is therefore well below the threshold for the 20% buffer requirement.

2.13. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is noticeably less.

2.14. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.

2.15. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be 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.

2.16. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can delivery early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.

2.17. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.

2.18. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.

2.19. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is anticipated to deliver housing completions from 2022/23, falling within the first five years of the plan.

2.20. Dunton Hills Garden Village is a proposed major strategic development, intended to provide a new settlement supported by a range of facilities and infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared to ensure that a cohesive approach is taken to the development of the Garden Village.

2.21. As such, it is a concern 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 again demonstrate an inability to rely on large strategic sites for short term housing delivery, and emphasises the need for smaller sites to be supported by policies which will allow their short term delivery to ensure the Local Plan is sound.

Policy R16 & R17: Land off Doddinghurst Road
2.22. Policy R16 & R17 proposes the release of the site from the Green Belt and allocation for around 200 new homes. This approach is supported as an achievable and deliverable solution to contributing towards the Borough's housing land supply to meet the housing need requirement.

2.23. Having regard to the PSLP's housing trajectory, paragraph 9.160 the PSLP states the dwellings are anticipated to be delivered between 2023/24 and 2026/27. We do not support this assumption and object to the timing of the delivery of this site, as set out in the above mentioned paragraph and Appendix 1 of the PSLP. As the Council will be aware, representations have been made to earlier iterations of the emerging Local Plan to confirm the site is available, deliverable and achievable within the first five years of the plan period.

2.24. As currently proposed the trajectory is unsound in relation to this site, and as such is not justified. This is because the site can be delivered earlier than the stated timescales in Appendix 1 of the PSLP. In order to make the housing trajectory sound, amendments to the trajectory must be made to reflect the earlier delivery of the site in the plan period. The proposed amendments would result in a justified approach and a sound policy.

2.25. In addition to amending the housing trajectory to reflect the realistic and earlier delivery of the site, as proposed by a developer with an option on the land, the inclusion of the site within the first five years on the plan period will assist BBC with their five-year housing land supply position, not only assisting in housing delivery of the PSLP is effective and can be found sound at Examination.

Unit Numbers
2.26. Whilst we are supportive of the allocation, we raise concerns in relation to the wording of allocation policies such as Policy R16 & R17 should take this requirement for flexibility into account and worded as such to provide "at least 200 homes", as opposed to "around 200 homes". We consider that this would provide greater certainty on the number of homes to be delivered as part of each allocation for Brentwood Borough Council, and also allows for the delivery of additional units where appropriate opportunities may arise.

2.27. For sites R16 and R17, a significant amount of feasibility work has been undertaken to establish any site constraints, and as a result of this, Countryside are confident in the ability for the site to provide at least 250 homes. We have concerns that the respective policy's current format may be interpreted to confirm the optimum use of the site, rather than a lower limit. In fact, the 200-unit figure has been produced by Brentwood Borough Council with far less rationale and technical justification than has been undertaken by Countryside Properties and may lessen the ability of this site and other policies with similar wording to support Brentwood's need for a buffer and flexibility in their housing land supply.

Access

2.28. It is noted that there has been a change in wording of Part B (b) of Policy R16 & R17 from the November 2018 Proposed Submission Local Plan presented to Committee, and that now being consulted on (February 2019), with no explanation. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.

2.29. Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways.

Policy SP03 Health Impact Assessments
2.30. The Policy requires planning applications for developments of 50 or more to be dwellings, non-residential development of 1,000sqm or more or schemes for C2 class developments to be supported by HIAs. The HBF response to this policy is unsupportive and they consider the policy to be unsound as it is not consistent with national policy and is ineffective.

2.31. We are in agreement with the HBF's response, dated 17th March 2019, in relation to the requirement for HIAs to be provided for 50 or more dwellings and consider the requirement to be unnecessary and an additional burden on applicants. Referring to the PPG we note that HIAs may be useful tools, however the PPG also expresses the importance of the local plan needing to consider the wider health issues in an area and ensuring the policies respond to these concerns. The guidance is provided below for completeness.

2.32. Paragraph: 002 Reference ID: 53-002-20140306 confirms that provision of the required health infrastructure should be supported and taken into account at local and neighbourhood plan making, and when determining planning applications.

2.33. Referring to National policy, paragraph 20 states that Strategic Policies should set out an overall strategy for the pattern, scale and quality of development, this includes infrastructure and community facilities.

2.34. In order for the local plan to be consistent with national policy, the Local Plan should already consider the impact of development on the health and wellbeing of the communities and any identified infrastructure should be addressed in policy. Therefore, whilst Countryside support the important consideration of health and wellbeing of communities where development is in line with the policies contained within the development plan a HIA should not be necessary. The requirement for a HIA should only be triggered where there is a departure from the plan, enabling the Council to assess any impacts on the health and well-being of the community as a result of said proposals.


Policy SP05 Construction Management

2.35. The Policy expects all major development schemes/developers to sign up to the Considerate Constructors Scheme, or equivalent. The scheme is a non-profit making, independent organisation which monitors construction sites signed up to the scheme, with the aim of managing and mitigating impacts arising from construction. This requirement is considered unjustified and inconsistent with national policy.

2.36. Whilst we recognise the importance of managing the potential impacts on construction sites, we consider this policy to be unsound because it is unjustified and not consistent with national policy. We would suggest that consideration for the scheme is best dealt with through planning applications and development management without it being written into formal planning policy.

2.37. We are not aware of any other adopted or emerging Local Plan which requires applicants and developers of major sites to enter into a specified construction management scheme and therefore question the reasonableness of this policy. The matter of construction management should be assessed on a case by case basis and should not be a matter for a strategic policy to prescribe. How a construction scheme is managed and mitigated should be an item for consideration by the decision taker and assessed on a case by case basis.

2.38. The imposition of Policy SP05 requires all major developments to be signed up to the Considerate Constructors Scheme regardless of the site or proposal details. It is recommended that this policy is removed.


Policy BE02 Sustainable Construction and Resource Efficiency

2.39. We consider the policy to be unsound as it is inconsistent with national policy. Part (f) of Policy BE02 requires the inclusion of renewable and decentralised energy as part of a new development, this is not consistent with national policy. Whilst Countryside recognise the importance of sustainable construction, a policy approach to such requirements does not allow for the appropriate flexibility in this regard, as recognised in the NPPF.

2.40. Paragraph 153 of the NPPF states that local plans can expect development to meet such provisions, however the NPPF also states that they are only required to comply with such policies where it is either feasible or viable. To ensure consistency with national policy part (f) of Policy BE02 should be amended to reflect this position.


Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency

2.41. It is Government policy to seek to deliver improvements to emissions from buildings through the building regulations regime. As such we do not consider it necessary to include the table at part (a) of this policy. Should a national zero carbon policy be introduced it will be achieved and applied through building regulations, as noted at paragraph 5.33.

2.42. We therefore echo those comments of the HBF's consultation response, dated 17th March 2019, and suggest that if the building regulations are updated then the Council should revisit the policy through a local plan review at that stage, but that such matters are dealt with through building regulations in the meantime to prevent unnecessary duplicate consideration of such matters through both planning and construction stages.


Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network

2.43. It is acknowledged that the Government support the transition to a low carbon future in a changing climate, including support towards renewable and low carbon energy and associated infrastructure. Countryside support these intentions.

2.44. Part (b) of Policy BE04 expects sites of over 500 dwellings, including where there are clusters of neighbouring sites that total over 500 units, shall incorporate decentralised energy infrastructure in line with a hierarchy however.

2.45. We raise concerns in relation to the deliverability of part (b) of the policy in relation to sites within a cluster of 500 or more dwellings given that neighbouring sites will not necessary come forward by multiple landowners and developers at similar times. The coordinating and implementation of a heat network to serve smaller scale sites as separate applications but adjacent to other similar sized sites in the locality, is unreasonable and unjustified and could result in a delay in delivery of new homes, resulting in an ineffective local plan.

2.46. It is recommended that the requirement for new development located where 'clusters' of neighbouring sites totals over 500 units should be removed from the policy in order to make the policy effective.


Policy BE10 Connecting New Developments to Digital Infrastructure

2.47. It is Government policy to support the expansion of electronic communications networks. However, we would draw the Council's attention to the Written Ministerial Statement, 25th March 2015, which announced that local planning authorities preparing Local Plans, "should not set any additional standards or requirements relating to the construction, internal layout or performance of new dwellings."

2.48. The Local Planning Authority are only allowed to adopt the three optional technical standards, in relation to construction, internal layout and performance, subject to evidenced need and viability. As such, the Council should not seek higher standards than Building Regulations, as already referred to in our response to Policy BE03. Therefore, Policy BE10 is considered unsound because it is unjustified and contrary to national policy.

2.49. We are also unaware of National Policy requiring benches and bins to be connected to mobile digital infrastructure. As such the policy is unjustified and contrary to national policy.

2.50. Countryside are committed to ensuring that all developments go as far as is practical to meet national intentions to ensure the quality, practicality and future-proofing of new housing developments. We have concerns however that by introducing a wealth of additional planning policies in these areas, there will be unnecessary duplication to building regulations, and potentially delays to planning applications which will in turn impact on the timely delivery of new homes.



3. Site Deliverability

3.1. The site represents a deliverable, sustainable and achievable site for residential development. A number of technical reports and associated documents have been completed which demonstrate this. The below section provides a summary of these documents.

Density Study
3.2. A Density Study (January 2018) has been undertaken by JTP Architects.

3.3. As per Paragraph 2.23 of this representation, the Preferred Site Allocations Document (January 2018) states that the indicative dwelling yield of the site is 200 dwellings.

3.4. The Density Study confirms that the total site area is 8.02ha and the total developable area is 6.17ha. Furthermore, it confirms that the site can accommodate up to 250 dwellings with 180 dwellings on Site 023A and 40 dwellings on parcel 023B, which results in 40 dwellings per hectare and 25 dwellings per hectare, respectively.

3.5. The Density Study also provides a Developable Area Plan which illustrates the developable area, the existing trees and root protections areas (RPA), the easements and attenuation and drainage. The plan proposed that the most significant existing trees and foliage are retained.

3.6. Furthermore, the Study characterises the existing landscape features of Site 023A as three naturally formed developable areas. This natural formation will enable an orthogonal street pattern and regular frontage and a more efficient layout of a potentially higher density.

3.7. The study characterises Site 023B as a more irregular shape due to the present underground services. Furthermore, the Density Study identifies that the site has more constrained access opportunities. This has led to a more organic layout of a potentially lower density.

3.8. Given the evidence in the Density Study, the site could accommodate up to 250 dwellings. Further detail on how the site could present a sustainable development opportunity can be found in the summaries below.
Air Quality
3.9. An Air Quality Assessment was undertaken by Ardent Consulting Engineers in February 2017. The assessment reviews air quality constraints affecting the site.

3.10. The assessment concludes that it is unlikely that the proposed development will be considered high risk in terms of construction impacts. It also suggests that there has been a general improvement in local air quality over recent years which is evidenced by the monitored concentrations which are detailed within the report. Nevertheless, the assessment recommends that mitigation measures may need to be adopted as part of the development and be further considered in due course.

3.11. The assessment recommends that the impact of any potential increase in traffic flow on the local road network should be determined by way of a detailed air quality assessment.

3.12. Given the proximity of the A12, there is the potential for the introduction of a new exposure adjacent to the A12. This is dependent on the distance between individual units and the A12 which is to be addressed through careful design by the Architects.


Archaeology
3.13. An Archaeological Desk Based Assessment was undertaken by CGMS Consulting in November 2014.

3.14. The assessment confirms that the site does not lie within an area of archaeological priority, as previously designated by Brentwood Borough Council. It confirms that the site can be considered to have a modest potential for the late prehistoric.

3.15. The assessment also confirms that the site has remained undeveloped land through its documented history.

3.16. The assessment anticipates that Essex County Council archaeological advisors may request additional archaeological mitigation measures, initially in the form of a geophysical survey.

Desktop Noise Report
3.17. A Desktop Noise Report was completed by Ardent Consulting Engineers in March 2016.

3.18. The Noise Report concludes that subject to appropriate mitigation measures, the proposed internal and external areas of the proposed development could be demonstrated to be within desirable noise levels, subject to a detailed assessment.

3.19. The report states that ambient vibration levels may be a concern due to the sites proximity to the A12. These will need to be further addressed during more detailed assessment works.

3.20. Furthermore, a Noise Feasibility Plan has also been produced by Ardent Consulting Engineers. The plan provides a number of layout recommendations for Glazing, Ventilation, Rear Gardens and Balconies and Standalone Barriers. The Noise Feasibility Plan also outlines the closest possible building line on site which has reasonable attenuation and the recommended approximate minimum effective extent of an acoustic barrier. The plan also provides dimensions between the site and the nearest channel of the A12.


Drainage Strategy
3.21. A Drainage Strategy Technical Note was produced by Ardent Consulting Engineers in 2016. The note confirms that existing foul and surface water sewers navigate the site, together with a number of watercourses which will continue to serve the site, post development.

3.22. The report also confirms that the site is within Flood Zone 1 and is therefore suitable for residential development. The note suggests that subject to further investigation and detailed design, a Flood Risk Assessment and Detailed Drainage Strategy can be prepared to support a successful planning application for the development.

Phase 1 Habitat Survey
3.23. A Phase 1 Habitat Survey was produced by SES in 2014. The survey concluded that the habitats on site have the potential to be of value to protected species, as well as being of general biodiversity value themselves. As a result, the Phase 1 Habitat Survey recommends that the following works are undertaken;

* Reptiles (presence/likely absence survey - northern site only);
* Badgers (monitoring of setts on site);
* Bats (tree inspection surveys, activity surveys);
* Breeding Bird (walkover survey during breeding bird season, generally March to August); and
* Invertebrates (walkover survey to establish value for rate and vulnerable beetles).


3.24. It is considered within the survey that any potential adverse impacts from the proposed development upon specific protected species will be able to be wholly mitigated for with careful design.

Social Infrastructure Review
3.25. A Social Infrastructure Review was produced by Quod in February 2017. The review looked to provide an assessment of the likely impact of the development of the site on the demand for school places and healthcare provision.

3.26. The review confirms that based on average household sizes for the area, it is anticipated that the site could accommodate a resident population of approximately 600 people and generate demand for 68 primary school places and 45 secondary school places.

3.27. In line with this estimated growth, the review provides a summary of the education and healthcare provision within Brentwood.

3.28. The review states that although a number of existing primary schools in the Brentwood urban area are being expanded or are due to be expanded, Essex County Council is still expecting to be facing a deficit of places by 2020/21, with the Preferred Site Allocations Document stating that there is an estimated deficit of 541 places by 2021/2022 for Primary Schools. In terms of Secondary School Provision, the Preferred Site Allocations document states that there will be an estimated deficit of 9 places by 2021/22.

3.29. In terms of healthcare provision, the report confirms that the capacity to absorb additional demand arising from developments in the Brentwood Urban Area is limited. The Preferred Site Allocations document confirms this and states that there is likely to be significant pressures on GP Surgeries due to housing growth in the Borough throughout the lifetime of the plan.

Transport
3.30. A Transport Technical Note was prepared by Ardent Consulting Engineers in January 2018. The technical note provides an initial review of the anticipated highway and transportation impacts, based on a potential development of up to 250 dwellings at the site.

3.31. The note confirms that vehicular access to the site could be provided from Doddinghurst Road for the 23A of the site and provided via the extension of Karen Close and Russell Close at the 23B parcel.

3.32. In response to local concerns regarding the suitability of existing public transport provision, the note suggests that the site could generate an additional 7 peak hour bus trips and 35 peak hour rail trips. It is considered that there is sufficient capacity to accommodate these trips. The note confirms that there does not appear to be any specific issues relating to public transport.

3.33. The technical note confirms that the impacts on surrounding roads including Doddinghurst Road and Ongar Road would not be severe and should not be a reason for the site not to be allocated.

3.34. The note confirms that there are no highways issues that would prevent the site from being allocated for residential development in the emerging Local Development Plan.

3.35. The above studies demonstrate that the site is deliverable and sustainable.

1. Introduction
1.1 These representations are submitted by Strutt & Parker on behalf of Marden Homes Ltd in relation to the Brentwood Borough Council Consultation Draft Local Plan (Regulation 19), and in particular with regards to our client's land adjacent to 7 Hanging Hill Lane, Hutton, Brentwood (ref. 284). A plan showing the site is provided at Appendix 1 of this representation.
1.2 Representations have previously been made on behalf of Marden Homes Ltd and in respect of Site 284 land adjacent to 7 Hanging Hill Lane on the Brentwood Borough Council Preferred Site Allocation Consultation Document (Regulation 18) in March 2018.
1.3 Site 284 lies to the south of Hutton and is adjacent to existing development. It measures approximately 0.9ha and it is proposed that the majority of the site is suitable for development. The front of the site is made up of a number of derelict sheds and structures which are single storey in height, along with dense vegetation. The majority of the site comprises grassland. The site is situated within the Green Belt.
1.4 Site 284 has been discounted as a site for residential development through the Local Plan process, for reasons which are considered in further detail later within this representation. We consider the rejection of the site to be unjustified, and to result in a Pre-Submission Local Plan (PSLP) which does not promote sustainable development.
1.5 The allocation of the site at Hanging Hill Lane, Hutton, would represent a sustainable and deliverable proposal for residential development to help meet housing need over the coming plan period. This representation sets out comments on the Regulation 19 Draft Local Plan, as well as providing detail on the sustainability and deliverability of the site with regards to technical considerations and the latest assessment work.
2. Brentwood Local Plan Regulation 19 Consultation
Plan Period
2.1. The Draft Local Plan is proposed to guide development in the Brentwood Borough until 2033. The National Planning Policy Framework (NPPF, 2019) clearly states at Paragraph 22 that strategic policies within Local Plans should look ahead over a minimum of 15 years.
2.2. At this stage it would be optimistic to assume that the adoption of the Draft Plan which forms the subject of this representation will happen within 2019 and therefore the plan will only address development needs in the area for a maximum of 14 years.
2.3. This shortfall is particularly relevant in respect of Green Belt, whereby a failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of Green Belt being required. This review ahead of a new Local Plan would be contrary to the NPPF (paragraph 136), and also undermines one of the two essential characteristics of the Green Belt: its permanence (NPPF, Paragraph 133).
Total Housing Requirement
2.4. The required housing need figures as calculated through the Borough's SHMA, follows national guidance using the Standard Method (as per the NPPF and respective Planning Practice Guidance (PPG) 2018). Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 new homes per year.
2.5. However, the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).
2.6. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum.
2.7. The NPPF requires for Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.
2.8. As mentioned previously, the Plan should also ensure that the revised Green Belt boundary should be robust enough to be maintained beyond the Plan period and therefore account for development needs beyond 2033 (or a revised later end to the Plan period to ensure strategic policies will cover at least 15 years).
2.9. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In respect of this, 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 011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of any objection to this approach from Brentwood Borough Council, but neither is there any indication that the PSLP addresses any of this unmet need.
2.10. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to be maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.11. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement. We consider that the Plan in its current form is ineffective. It has not been positively prepared to provide for the appropriate level of contingency for housing delivery, nor does it comply with national planning policies in this regard. As such we consider the PSLP to be unsound.
2.12. We therefore consider that the housing need within the PSLP should be amended to at least ensure that an additional year's worth of housing can be accommodated for, and so that the relevant strategic policies of the Plan can cover 15 years from adoption. Realistically, we consider that the Council may actually need an additional 2 years worth of housing in order to support a plan which runs to 2035. Therefore one additional year should be regarded as the minimum.
2.13. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Allocating further sites for housing, like sites at Hanging Hill Lane, would provide additional housing delivery in a sustainable location, and would therefore help to ensure that the Draft Local Plan can be found sound.
Five-year Housing Land Supply and Housing Trajectory
2.14. Councils are required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).
2.15. At paragraph 73 of the NPPF it confirms that a 20% buffer should be applied to the initial calculation for a five year housing land supply requirement, in the event that the results of the Housing Delivery Test show for delivery to have fallen below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037- 20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.16. The results of the 2018 Housing Delivery Test showed that Brentwood Borough Council delivered just 50% of its housing requirements over the last three years. This is well below the threshold of 20% as required by national guidance.
2.17. The Borough's most recent five-year housing land supply figure, as reported in their' Five Year Housing Land Supply Statement as at 31 March 2018' (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.18. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
2.19. The HLSS includes sites without detailed planning permission within their supply and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considered deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. These sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can deliver early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.
2.21. The housing trajectory provided at Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.22. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.23. Furthermore, Dunton Hills Garden Village is a proposed major strategic development that is 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. The delivery of Dunston Hills will be dependent on the coordination and input of multiple landowners, developers, infrastructure providers and other relevant stakeholders.
2.24. Once allocated, the PSLP proposed that a masterplan and design guidance will be required. Following this, an outline application will need to be prepared, submitted and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations.
2.25. We therefore question how likely the 100 homes at Dunton Hills will be completed by 2022/23. Of course, Dunton Hills can still form part of a sound Local Plan, however this does demonstrate that the reliance on large strategic sites for shorter term housing delivery is not appropriate. Additional smaller sites are capable of providing homes through the early years of a plan period and should be allocated through the PSLP to ensure the Local Plan is sound.
2.26. Whilst the plan can demonstrate housing delivery appropriate to meet minimum recognised requirements, it is evident that the suggested inability of the plan to ensure a consistent five-year supply is not consistent with national policy. National Policy requires that local planning authorities should identify and update a supply of specific deliverable sites sufficient to provide a minimum of five years' worth of housing against their housing requirement set out in the adopted strategic policies, on an annual basis.
The PSLP should support this requirement through the allocation of smaller scale sites that can be delivered over a shorter time period, in order to be found sound. Land at Hanging Hill Lane, could cater to this need. Its deliverability is discussed in greater detail in subsequent sections.
Proposed Approach to Hutton
2.27. Hutton is recognised as Category 1 - 'a main town' within the PLSP's settlement hierarchy. Hutton is the second largest settlement in the Borough, with an approximate population 15,578 (according to the 2011 Census). It has an established local centre which benefits, from a range of services, facilities, access to public transport, and employment opportunities.
2.28. Hutton is well-connected in respect of regional and national infrastructure, situated approximately 30km from Central London, 12km from Chelmsford, accessible from the A12 or national rail services.
2.29. Hutton is therefore a highly sustainable location, and makes it an ideal location to accommodate a proportion of Brentwood's housing need. The Local Plan should manage growth of such settlements to sustain and enhance their vitality.
2.30. The PSLP proposes no growth for Hutton, despite its identification as a Category 1 settlement. This is in direct contrast to the level of growth afforded to other settlements which are also identified as Category 1 or are below Hutton within the Borough's settlement hierarchy. We therefore have concerns that the PSLP is failing to support the sustainable growth of Hutton and this omission is unjustified and inconsistent with national policy.
2.31. Land at Hanging Hill Lane should be allocated in Hutton to ensure the sustainable growth of the settlement, and to ensure the soundness of the Local Plan.
Green Belt
2.32. A Green Belt Study (November 2018) supports the PSLP. This study provides an assessment of Green Belt parcels against the five purposes of the Green Belt, as set ut within the NPPF.
2.33. The study includes an 'assessment of Housing Sites (being considered as part of the SHLAA) within the Green Belt and their relative contribution to the purposes of the Green Belt designation'.
2.34. The site has been assessed against the five purposes of the Green Belt, as part of the Green Belt Study methodology as follows:
Purpose 1: To check the unrestricted sprawl of large built up areas
Parcel 14 is defined by the Council as 'partly contained', and recognises that it abuts a large built up area. This categorisation does however advise that the boundary is 'weak/degraded/unclear'. Site 284 abuts a large built-up area on two out of four boundaries, the remaining boundaries are bounded by established vegetation that could be incorporated and enhanced as part of a landscaping scheme. We consider that the site boundaries are clearly defined and the site is well contained. A conclusion of containment should not consider built form exclusively.
Purpose 2: To prevent neighbouring towns from merging into one another The site is adjacent to the eastern/south-eastern limit of Hutton Mount. The Green Belt Study correctly recognises that its development will retain separation between towns. The site sits at the eastern/south-eastern limit of Hutton mount, the nearest settlement to the east of the site is Billericay which is approximately 3 miles away. The green gap etween the two settlements is considerable. The rest of the settlement at Hutton Mount extends significantly further east than Site 284 in this regard and should be considered very low risk in terms of purpose 2, especially in the context of the other sites that have been assigned the 'Separation Retained' designation.
Purpose 3: To assist in safeguarding the countryside from encroachment Site 284 is defined within the Green Belt Study as being 'Functional Countryside'. The assessment defines Functional Countryside as 'High degree or important public access'. Access is defined as 'access land, public right of ways and important routes'. The site itself, is in private ownership and does not provide access to the public. It is not used for agricultural purposes and therefore should not be considered 'functional countryside'. We therefore consider this assessment to be incorrect.
Purpose 4: To preserve the setting and special character of historic towns Brentwood Borough Council have recognised that site 284 has no physical or visual relationship with the Historic Town. The site is located some distance from the Town Centre with no direct relationship. The site is directly associated with the contemporary developments of the surrounding roads, which have limited historic character.
Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land Brentwood Borough Council have not provided an analysis for Purpose 5.
2.35. Overall, Brentwood Borough Council have assessed the site as having a moderate overall contribution to the Green Belt, despite the favourable assessment of the site.
2.36. We have outlined above that where the site was assessed to have important role in the Green belt, that certain elements of the assessment are incorrect and are not a true reflection of the site's characteristics.
2.37. The development of this Green Belt site, which has limited environmental value and offers a minimal contribution to the Green Belt when assessed against its five intended purposes, would help to support housing delivery in a sustainable location in the Brentwood Borough, whilst protecting other Green Belt sites of much higher environmental value.
2.38. The weaknesses and inconsistencies recognised in the individual site assessments made, again demonstrate a flaw in the evidence base for the Local Plan and could again result in the unjustified omission of Green Belt sites from consideration for allocation as part of the new Local Plan.
2.39. The above analysis of Hanging Hill Lane, Hutton demonstrates that there remains small scale opportunities for sustainable development within the Green Belt and that the Local Plan should give consideration to the allocation of such sites alongside larger scale areas of release.
Strategic Environmental Assessment/Sustainability Appraisal (SEA/SA)
2.40. The PSLP is supported by a range of technical work, including the Sustainability Appraisal (SA) January 2019. The SA presents a number of sustainability issues/objectives which have been established through SA scoping. Together, these sustainability topics and objectives provide a methodological framework for the appraisal of potential allocation sites - including site 284.
2.41. The SA indicates that the allocation of Site 284 would have a positive effect in relation to one of the SA objectives. The SA analysis states that Site 284 is in good proximity to a secondary school (less than 1.5km), but in 'red' proximity from a GP surgery and a primary school. Willowbrook Primary School is located within 1.3 miles of the site, whilst Hogarth Primary School is also 1.5 miles from the site, both considered to be within walking distance from site. The nearest GP Surgery, Mount Avenue Surgery is located less than 1.5 miles away. Mount Avenue is defined in the Regulation 18 document to be 1 of 3 surgeries which has an average of 0.58 GPs per 1,000 patients, which is the national average. Furthermore, Mount Avenue Surgery has a large catchment area, therefore it is considered that it would provide service to those living at the site. Brentwood Community Hospital is also located less than 3 miles away.
2.42. The SA, through its analysis also states that the site at Hanging Hill Lane is an area that 'performs poorly' in respect of its proximity to an Ancient Woodland, SSSI, Local Wildlife Site, Listed Buildings and Agricultural Land. This scoring metric is considered to be highly assumptive and does not consider the potential opportunities for biological enhancement or mitigative measures of impact through landscape led schemes. The proximity of the site near these designations as referenced above, does not necessarily mean that there will be any direct impact to them from the development of the site.
2.43. In relation to Green Belt, the assessment is binary in its approach - if a potential site falls within the defined Green Belt, it will be given an 'Amber score'. The methodology notes that Green Belt is not a specific a landscape designation, as such the effects on the setting have not been appraised. Without appraising the effects on the setting, assigning a blanket 'amber' score to Green Belt sites, seem arbitrary.
2.44. As discussed above, a Green Belt Review of the Borough, and the contribution that each individual site makes to the Green Belt has been undertaken. This recognition that each individual site has differing values should have an influence on the scoring for the Green Belt element within the SA, rather than the binary approach taken.
2.45. In general, we consider that the SA Report is simplistic in its approach to individual site assessment. The SA has used a predominantly spatial or 'GIS' (use of Geographical Information Systems) approach to the assessment of each criteria, using the distance between the site and various factors to judge the extent to which it either achieves or opposes certain objectives. It has had no consideration for the positive contribution that the development of sites can make to the natural environment and local facilities.
2.46. The assumption made within the Sustainability Appraisal that sites will only negatively impact the Green Belt and other landscape and natural environment designations leading to the unjustified omission of sites from allocation, has resulted in the Local Plan being unsound.
3. Site Deliverability
3.1. Site 284 represents a deliverable, sustainable and achievable site for residential development. The below section provides overview of its deliverability and some of the technical reports that have been undertaken which help to demonstrate this.
Access & Connectivity
3.2. The site is considered to have a good access and connectivity to the surrounding area. The vehicular and pedestrian access to the site is proposed to be taken directly from Hanging Hill Lane, as existing.
3.3. The site is approximately 1.5 miles from Shenfield Station (less than a 30 minute walk). Shenfield Station provides frequent services to London Liverpool Street, Chelmsford, Colchester and Ipswich and settlements between. These destinations also provide connections to wider national transport network.
3.4. A public bus stop is located less than 13m from the site. This bus stop provides frequent services to Brentwood High Street, Basildon Town Centre, Billericay and Shenfield Rail Station, amongst other neighbouring settlements and the wider area.
3.5. The site is well-connected to the surrounding road network, and is approximately 2.5 miles from the A12. The A12 provides efficient access to settlements across Essex and East Anglia such as Chelmsford, Colchester and Ipswich, as well as direct connection to the M25.
3.6. Given the high access and connectivity levels of the site, it is evident that land at Hanging Hill Lane is within a sustainable location and should therefore be considered as one of a number of small sites around Hutton that would be suitable for accommodating growth that would be suitable for accommodating growth that would support the recognised housing needs of Brentwood.
Ecology
3.7. A full ecological appraisal of the site would be undertaken prior to any development. It is anticipated however that the development could easily mitigate potential impacts through retention of existing landscape features and replacement planting where appropriate, whilst also presenting an opportunity for enhancement of the ecological value of the site above the existing.
3.8. Any impacts could be easily mitigated and enhanced through a landscaping scheme to support any future development on the site.
Drainage
3.9. The site is adjacent to existing built development and it is anticipated that connections could therefore be made to the existing sewerage networks.
3.10. A sustainable urban strategy would form part of any design for the site to ensure the surface water run-off rates are maintained at the existing greenfield rates.
Contamination
3.11. The perceived history of the use of the site indicated that the site is unlikely to be contaminated.
Highways
3.12. There is an existing access to the site from Hanging Hill Lane which would be maintained and used to access any new development on the site. We understand that this access has good visibility splays and that it is therefore safe for continued use.
3.13. Any development on the site would be supported by a transport statement which consider the suitability of the local highway network to accommodate increased vehicular movements to and from the site.
3.14. It is however considered that sustainably located sites such as sites at Hanging Hill Lane will help provide new homes in locations where there is a minimal reliance on the use of the private car. There are direct footpath links to local convenience shops and schools in Hutton Mount, as well as further into the centre of Hutton. Other local services and facilities, including Shenfield station are also easily accessible by bike.
3.15. There have been no reasons recognised why existing highways and access arrangements should present a risk to the suitability and deliverability of the site.
Heritage
3.16. Grade II Listed Hare Hall is immediately to the south of the site. A Heritage Statement has been prepared by Architectural Management to assess the significance of this asset in respect of the potential residential development of the site, and accompanies this representation.
3.17. The assessment recognises that Hare Hall has been altered significantly over time and that the current building does not carry the level of significance which the original Hare Hall may have done.
3.18. In considering the setting of the listed building, the report also recognises that historically the Hall enjoyed an open outlook to the east and south and that the existing buildings on the site (subject of this rep), and its established vegetation means that the north of the site of has always been more enclosed with a limited outlook.
3.19. The report includes some specific recommendations towards site layout and design that will ensure that the development of this site will have no detrimental impact on the setting of Hare Hall.
4. Summary
4.1. Whilst the current proposed allocations and strategic polices of the PSLP appropriately address the minimum requirement of housing recognised for the Plan period, we query the length of the Plan period, and a lack of flexibility in the housing provision. As such we consider the Plan to be unsound due to its inability to comply with national policy, the unjustified omission of a housing supply which exceeds minimum requirements, and failure to positively prepare for potential changes to markets and housing requirements beyond these forecasts.
4.2. There is clearly a case for Site 284 to be further considered as a sustainable opportunity in respect of Brentwood Borough Council needing to further increase their housing delivery over the plan period. The development of the site would not impact the function of the Green belt in this location as it is immediately adjacent to Hutton, a 'main town' with the facilities and services that could support sustainable growth in Brentwood Borough. Development here would also accord with the Brentwood Borough Council Spatial Strategy which directs growth towards the A12 transport
corridor.
4.3. The accompanying studies evidence the deliverability, achievability and suitability of the site. It is anticipated that any impact on historical sites and settings, landscapes, ecology and ecological designations could be mitigated through appropriate measures. We therefore consider that the site should be allocated by Brentwood Borough Council as a site for residential development. There is an opportunity to identify sustainable sites that are suitable for delivering housing over short term timescales, and to ensure that the Plan is flexible and robust, and well prepared to meeting housing needs over the entirety of the Plan period.
4.4. Development of the site is supported by technical evidence that confirms its suitability, including in relation to the lack of harm the development would have to the purposes of the Green Belt. The reasons given for the rejection of the Site are therefore based on a number of assumptions and simplistic conclusions.
4.5. The exclusion of Site 284 is unjustified, and overlooks an opportunity to correct 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 at Hutton. The allocation of Site 284 for development will assist in resolving these deficiencies in respect of the Local Plan, enabling it to be found sound.

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.

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 Plan should be amended to allocate a number of additional smaller and medium sized sites, as required by paragraph 68 of the NPPF, which will ensure provision of a
five year housing supply, to enable continued delivery of homes throughout the Plan period.

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.

Allocate additional smaller sites capable of providing homes in the early years of the plan period in order to ensure the Local Plan is sound.

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.