Brentwood Local Plan 2016-2033

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Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22234

Received: 10/03/2019

Respondent: Mr Anthony Cross

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Please refer to my representations below (ID 22202 and 22203)Inclusion of site allocations R25 and R26 in the LDP are inappropriate, unsound and not compliant with legal requirements on the following grounds: failure to prove that more suitable (brownfield) sites do not exist in the borough, or that other site allocations couldn't absorb the 70 dwellings proposed; inadequate consultation with Epping Forest District Council and failure to properly consider the impact of other nearby developments on Blackmore; failure to recognise the increased flood risk resulting from the proposed development; adverse impact on roads, noise levels and safety of existing road users from increased traffic; inadequate local amenities/services; other considerations per full representation.

Change suggested by respondent:

Removal of proposed developments R25 and R26 from the plan and reallocation of the 70 dwellings to more suitable brownfield sites in the borough.

Full text:

Please refer to my representations below (ID 22202 and 22203)Inclusion of site allocations R25 and R26 in the LDP are inappropriate, unsound and not compliant with legal requirements on the following grounds: failure to prove that more suitable (brownfield) sites do not exist in the borough, or that other site allocations couldn't absorb the 70 dwellings proposed; inadequate consultation with Epping Forest District Council and failure to properly consider the impact of other nearby developments on Blackmore; failure to recognise the increased flood risk resulting from the proposed development; adverse impact on roads, noise levels and safety of existing road users from increased traffic; inadequate local amenities/services; other considerations per full representation.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22265

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

ECC supports preparation of BBC Local Plan.
Remain significant gaps in evidence base.
Support for Plan can only be provided following completed to ECC satisfaction:
a. appropriate transport evidence base to illustrate site specific, local and cumulative impact on local and strategic transport network, and to identify any infrastructure and/or mitigation measures required, together with costs and phasing;
b. up to date Infrastructure Delivery Plan (IDP) including infrastructure costs, phasing, delivery and viability (need to be agreed with ECC as primary infrastructure provider); and
c. clear references to evidence base within Plan to support spatial strategy, and Local Plan policies.

Change suggested by respondent:

BBC need to complete the following:

a. An appropriate transport evidence base, to reflect ECC's role as Highway Authority, that clearly illustrates the site specific, local and cumulative impact on the local and strategic transport network, and to identify any infrastructure and/or mitigation measures which would be required, together with costs and phasing;
b. An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability; and
c. Clear references to the evidence base within the Plan to support the spatial strategy, and the Local Plan policies.

Full text:

In summary, while ECC supports the preparation of the BBC Local Plan in accordance with the Duty to Co-operate (DtC); and acknowledges the significant changes made since the Regulation 18 stages, to reflect many of ECC's representations, there remain significant gaps in the evidence base and support for the Plan can only be provided once the following has been completed to the satisfaction of ECC:

a. an appropriate transport evidence base, to reflect ECC's role as Highway Authority, that clearly illustrates the site specific, local and cumulative impact on the local and strategic transport network, and to identify any infrastructure and/or mitigation measures which would be required, together with costs and phasing;
b. an up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability, which will need to be agreed with ECC as a primary infrastructure provider; and
c. clear references to the evidence base within the Plan to support the spatial strategy, and the Local Plan policies.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22303

Received: 16/03/2019

Respondent: Mr N McCarthy

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

We object on grounds of unsoundness and inconsistency in application of planning guidelines. Key information needed to assess the Plan has not been readily available leading to concerns over the legality of the undertaking.

Change suggested by respondent:

The immediate withdrawal of sites R25 and R26.

Full text:

This representation is made by Mr Neil McCarthy and Mrs Valerie McCarthy and should therefore be treated as two objections. We object to the two proposals designated R25 and R26, identified here as the Blackmore developments. Continued inclusion of these sites renders the Local Development Plan unsound under national guidelines -- indeed it is also inconsistent with the Borough's own planning criteria as applied elsewhere during compilation of the Plan.
The adjacent sites are in an entirely unsuitable location for housing allocation of a scale that will overwhelm the infrastructure and character of the existing community.
Access to the Blackmore developments is determined to be solely via a narrow country lane that presently carries little if any through traffic and is signposted as unsuitable for heavy vehicles. Redrose Lane is manifestly unfit for the purpose of providing up to an estimated (TRCS™ indicative) 700 additional daily traffic movements. The failure of the Plan to acknowledge and allow for the implications of this defect is sufficient cause to immediately withdraw both Blackmore developments. Withdrawal before Examination - during which the Blackmore developments would be subject to valid legal challenge - will enable the remainder of the Plan to meet the tests of soundness and legality required for adoption.
It is necessary to compare and contrast the case of the Borough's long-standing preference for a site known as Honeypot Lane to deliver 200 new dwellings in a location offering easy walking-distance to all the public and private amenities of Brentwood's town centre. This site complied with or exceeded all the objectives of the Plan by benefiting from immediate proximity to public transport hubs, employment opportunities, and commercial and social facilities. Whereas Honeypot Lane featured as a significant element towards the LDP's social and private housing ambitions from the outset, the Blackmore allocations, previously discounted as unsustainable, were only added in 2018 when number targets were increased.
In November 2018, the then Leader of the Council announced she was authorising withdrawal of the Honeypot Lane site from the published LDP. She confirmed the single reason for this volte-face was that a minor section of Honeypot Lane created a 'pinch-point', creating potential difficulty for access.
We have driven and walked the entire similar lengths of both Honeypot Lane and Redrose Lane. A reasonable person would have to concede that Redrose Lane presents a far worse set of circumstances relating to on-going access than Honeypot Lane. And It can be fairly stated that only minor road works incorporating vacant land to the side of Honeypot Lane would relieve the short 'pinch-point' between the extensive remaining doubly-paved and two-lane sections leading to the site. The entire length of Redrose Lane would require to be brought up to the standard already in place at Honeypot Lane,. This upgrade would have to include the cross road intersecting junction with Fringrith Hall Lane, thus destroying the Green Belt aspect and habitat of its surroundings. Again in comparison, Honeypot Lane has at one end a permanent 20mph limit due to location in the Town Centre Zone, and 30mph for the remainder where it runs parallel with the A12 Brentwood By-Pass. Redrose Lane through its distinct unbuilt rural location is subject to the National Speed Limit for a single-carriageway of its type, 60mph.
We endorse the more comprehensively informed and presented objections contained in the Regulation 19 submission prepared by the Parish Council and the wider village community. However, we believe the unsoundness of the Plan in relation to Blackmore, can be encapsulated in the flawed presumption that Redrose Lane would ever be a satisfactory means of access.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22337

Received: 17/03/2019

Respondent: Dr Philip Gibbs

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation:

The Local Plan was not positively prepared because the council was aiming to "protect" its borough from development by putting housing away from where it was really needed. See attachment for details

Change suggested by respondent:

The strategic options need to be reassessed in the light of housing need throughout the borough rather than a desire to keep it away from villages and towns.

Full text:

The Local Plan was not positively prepared because the council was aiming to "protect" its borough from development by putting housing away from where it was really needed. See attachment for details

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 23096

Received: 19/03/2019

Respondent: Basildon Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Despite the engagement between Brentwood Council and neighbouring authorities, 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. Many of the comments previously raised remain unanswered or inadequately addressed. It is uncertain how the Plan has been informed by this previous input.

Full text:

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.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24055

Received: 17/05/2019

Respondent: Mr Terry Haynes

Agent: Phase 2 Planning and Development Ltd

Representation:

General Support for the plan with specific comment on sections:
Section 4: Managing Growth - specifically Policy SP02: Managing Growth
Section 9: Site Allocations

Full text:

1. Introduction & Background
Introduction

1.1 This Regulation 19 Local Plan representation has been prepared by Phase 2 Planning and Development Ltd on behalf of Mr Terry Haynes, on behalf of the freehold owner of the subject site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX as outlined by the Site Location Plan included at Appendix 1.

1.2 This submission is made under the Provisions of Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations (2012) and relates to the following sections of the Council's Pre-Submission Draft Local Plan:
- Section 4: Managing Growth
Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Representation summary
1.3 In summary, the landowner wishes to highlight the sustainability of the proposed site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality. Please see the remainder of this supporting statement for further consideration in support of the subject site's inclusion in this emerging Local Plan strategy.

2. Soundness & Modifications
2.1 As the attached representation form confirms the landowners representations relate specifically and solely to the soundness of the draft Submission Local Plan in respect of being positively prepared, justified, effective, and consistent with national policy in relation to the following sections of the emerging Local Plan:

- Section 4: Managing Growth

Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Soundness
Section 4: Managing Growth
Draft Policy SP02: Managing Growth
2.2 Although on the whole it is generally considered that the Council's Pre-Submission Local Plan is sound there is some concern that the Council's Housing Requirement is not fully robust.

2.3 Planning Practice Guidance (PPG) on 'Housing and economic needs assessment', which was updated on the 20th 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.

2.4 Paragraph 4.13 of the Council's Pre-Submission Draft 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.

2.5 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) with this assessment confirming 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 fully sound on this basis.

2.6 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.

2.7 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.

2.8 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.

2.9 With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan-Pre-Submission Document can be considered to be robustly sound as, in accordance with paragraph 35 of NPPF3, the Plan is not fully 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 in full as it will not, as a minimum, meet its objectively assessed needs.

Section 9: Site Allocations
2.10 The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Pre-Submission draft 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).

2.11 Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not fully sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation.
1.4 The following section of this representation provides support for land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX, to be allocated for new residential development.
1.5 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 fully agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears ambitious.
1.6 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.
1.7 This level of growth from such a strategic allocation does not appear realistic and no evidence has been put forward to date to support this forecast. For example, it is unlikely that the Local Plan will be adopted until 2020 at the earliest (the Council's Local Development Scheme
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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).
1.8 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 up to two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission.
1.9 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.
1.10 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.
1.11 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.
1.12 Furthermore, it is considered that the Local Plan is not entirely sound as it does not comply fully with paragraph 68 of the National Planning Policy Framework (NPPF3) (February 2019).
1.13 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.
1.14 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.
1.15 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,
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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.
1.16 Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX) should be identified for allocation.

1.17 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.

Necessary modifications to make the Pre-Submission Draft Local Plan sound
1.18 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
1.19 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 agrees 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.
1.20 Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3.
1.21 It is considered that land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX is an appropriate site for residential development and should be allocated for appropriate new residential development.
1.22 The site itself includes land directly east of Hook End and north of Wyatts Green which would continue the existing pattern of development in this location as well as extend north comprising a logical and well-contained urban extension to the village with existing residential development already neighbouring the site to the south and west. Despite this the subject site still remains of a greenfield nature situated within the Metropolitan Green Belt.

1.23 Although noted that Hook End/Wyatts Green are proposed to be classified as smaller villages within the Borough's Settlement Hierarchy the importance of allocating appropriate growth throughout the Borough cannot be underestimated. The subject site itself would be well-placed to assist in enhancing the vitality of these rural communities allowing these villages to grow and thrive, especially where there are groups of smaller settlements, with development
Page 6 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


in one village able to support services in villages nearby as advocated by para 78 of NPPF3. This is particularly relevant in this instance given Hook End/Wyatt Green's physical relationship to the nearby villages of Stondon Massey and Doddinghurst as well as the village of Blackmore which itself includes some planned growth under the current Local Plan strategy.

1.24 Importantly NPPF3 also highlights at para 84 that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. It adds at para 103 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-making.

1.25 Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed this part of Hay Green Lane lying on the southern edge of 'Parcel 48 Wyatt's Green East. The report when assessing the parcel as a whole, confirms that it makes a 'high' overall contribution to Green Belt Purposes although it is noted that the majority of this parcel is open to the east of Wyatt's Green with the subject site adjacent to the physical extent of the village to the north and much more likely to play a less substantial role in such purposes.

1.26 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.

1.27 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 rural area of Hook End and is well contained by existing built development and mature trees. Development would be seen as a logical extension to the physical extent of the village 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 Hook End/Wyatts Green and nearby villages. Such countryside separation would be retained.
Purpose 3: to assist in safeguarding the countryside from encroachment: The site has no specific countryside function and would utilise a well-contained parcel of land surrounded by residential development.
Purpose 4: to preserve the setting and special character of historic towns: The site has no physical relationship with any historic town.

1.28 Accordingly, it is considered that the site is suitable to be released from the Green Belt.
1.29 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, 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).
1.30 Those sites listed above are located within villages and the rural area comparable to that of the subject site.

1.31 Accordingly, we would request that the Local Plan be modified to allocate land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas.

Conclusions
1.32 Based on the information set out above, it is considered that the inclusion of the subject site within the Council's proposed housing growth strategy or as an alternative reserve site would be sustainable and fully deliverable early within the Local Plan period, improving the overall soundness of the emerging Local Plan itself.

1.33 The possible low density nature of the allocation gives scope to provide a sensitively designed scheme which can be designed to integrate within and enhance the existing landscape having appropriate regard to local features and surrounding land uses, including existing neighbouring residential development.

1.34 Subsequently, the landowner contends that the relevant sections of the emerging Local Plan referred to within would be sound but could be improved further with the inclusion of this site ensuring the emerging Plan is positively prepared, effective and justified, and would be fully consistent with national policy including 'boosting significantly' the delivery of new homes within a borough that is heavily constrained by the Metropolitan Green Belt.

Inclusion of a red line boundary map for the site in question.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24056

Received: 17/05/2019

Respondent: Mr Terry Haynes

Agent: Phase 2 Planning and Development Ltd

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Representation:

Representation summary. The landowner wishes to highlight the sustainability of the proposed site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality.

Change suggested by respondent:

Add site to plan

Full text:

1. Introduction & Background
Introduction

1.1 This Regulation 19 Local Plan representation has been prepared by Phase 2 Planning and Development Ltd on behalf of Mr Terry Haynes, on behalf of the freehold owner of the subject site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX as outlined by the Site Location Plan included at Appendix 1.

1.2 This submission is made under the Provisions of Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations (2012) and relates to the following sections of the Council's Pre-Submission Draft Local Plan:
- Section 4: Managing Growth
Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Representation summary
1.3 In summary, the landowner wishes to highlight the sustainability of the proposed site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality. Please see the remainder of this supporting statement for further consideration in support of the subject site's inclusion in this emerging Local Plan strategy.

2. Soundness & Modifications
2.1 As the attached representation form confirms the landowners representations relate specifically and solely to the soundness of the draft Submission Local Plan in respect of being positively prepared, justified, effective, and consistent with national policy in relation to the following sections of the emerging Local Plan:

- Section 4: Managing Growth

Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Soundness
Section 4: Managing Growth
Draft Policy SP02: Managing Growth
2.2 Although on the whole it is generally considered that the Council's Pre-Submission Local Plan is sound there is some concern that the Council's Housing Requirement is not fully robust.

2.3 Planning Practice Guidance (PPG) on 'Housing and economic needs assessment', which was updated on the 20th 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.

2.4 Paragraph 4.13 of the Council's Pre-Submission Draft 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.

2.5 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) with this assessment confirming 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 fully sound on this basis.

2.6 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.

2.7 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.

2.8 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.

2.9 With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan-Pre-Submission Document can be considered to be robustly sound as, in accordance with paragraph 35 of NPPF3, the Plan is not fully 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 in full as it will not, as a minimum, meet its objectively assessed needs.

Section 9: Site Allocations
2.10 The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Pre-Submission draft 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).

2.11 Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not fully sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation.
1.4 The following section of this representation provides support for land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX, to be allocated for new residential development.
1.5 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 fully agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears ambitious.
1.6 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.
1.7 This level of growth from such a strategic allocation does not appear realistic and no evidence has been put forward to date to support this forecast. For example, it is unlikely that the Local Plan will be adopted until 2020 at the earliest (the Council's Local Development Scheme
Page 4 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


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).
1.8 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 up to two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission.
1.9 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.
1.10 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.
1.11 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.
1.12 Furthermore, it is considered that the Local Plan is not entirely sound as it does not comply fully with paragraph 68 of the National Planning Policy Framework (NPPF3) (February 2019).
1.13 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.
1.14 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.
1.15 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,
Page 5 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


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.
1.16 Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX) should be identified for allocation.

1.17 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.

Necessary modifications to make the Pre-Submission Draft Local Plan sound
1.18 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
1.19 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 agrees 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.
1.20 Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3.
1.21 It is considered that land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX is an appropriate site for residential development and should be allocated for appropriate new residential development.
1.22 The site itself includes land directly east of Hook End and north of Wyatts Green which would continue the existing pattern of development in this location as well as extend north comprising a logical and well-contained urban extension to the village with existing residential development already neighbouring the site to the south and west. Despite this the subject site still remains of a greenfield nature situated within the Metropolitan Green Belt.

1.23 Although noted that Hook End/Wyatts Green are proposed to be classified as smaller villages within the Borough's Settlement Hierarchy the importance of allocating appropriate growth throughout the Borough cannot be underestimated. The subject site itself would be well-placed to assist in enhancing the vitality of these rural communities allowing these villages to grow and thrive, especially where there are groups of smaller settlements, with development
Page 6 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


in one village able to support services in villages nearby as advocated by para 78 of NPPF3. This is particularly relevant in this instance given Hook End/Wyatt Green's physical relationship to the nearby villages of Stondon Massey and Doddinghurst as well as the village of Blackmore which itself includes some planned growth under the current Local Plan strategy.

1.24 Importantly NPPF3 also highlights at para 84 that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. It adds at para 103 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-making.

1.25 Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed this part of Hay Green Lane lying on the southern edge of 'Parcel 48 Wyatt's Green East. The report when assessing the parcel as a whole, confirms that it makes a 'high' overall contribution to Green Belt Purposes although it is noted that the majority of this parcel is open to the east of Wyatt's Green with the subject site adjacent to the physical extent of the village to the north and much more likely to play a less substantial role in such purposes.

1.26 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.

1.27 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 rural area of Hook End and is well contained by existing built development and mature trees. Development would be seen as a logical extension to the physical extent of the village 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 Hook End/Wyatts Green and nearby villages. Such countryside separation would be retained.
Purpose 3: to assist in safeguarding the countryside from encroachment: The site has no specific countryside function and would utilise a well-contained parcel of land surrounded by residential development.
Purpose 4: to preserve the setting and special character of historic towns: The site has no physical relationship with any historic town.

1.28 Accordingly, it is considered that the site is suitable to be released from the Green Belt.
1.29 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, 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).
1.30 Those sites listed above are located within villages and the rural area comparable to that of the subject site.

1.31 Accordingly, we would request that the Local Plan be modified to allocate land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas.

Conclusions
1.32 Based on the information set out above, it is considered that the inclusion of the subject site within the Council's proposed housing growth strategy or as an alternative reserve site would be sustainable and fully deliverable early within the Local Plan period, improving the overall soundness of the emerging Local Plan itself.

1.33 The possible low density nature of the allocation gives scope to provide a sensitively designed scheme which can be designed to integrate within and enhance the existing landscape having appropriate regard to local features and surrounding land uses, including existing neighbouring residential development.

1.34 Subsequently, the landowner contends that the relevant sections of the emerging Local Plan referred to within would be sound but could be improved further with the inclusion of this site ensuring the emerging Plan is positively prepared, effective and justified, and would be fully consistent with national policy including 'boosting significantly' the delivery of new homes within a borough that is heavily constrained by the Metropolitan Green Belt.

Inclusion of a red line boundary map for the site in question.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24061

Received: 17/05/2019

Respondent: Mr Terry Haynes

Agent: Phase 2 Planning and Development Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The plan needs more flexibility for smaller housing sites. The Site at land at rear of Mill House Farm is available and suitable. The location is a well contained urban extension. The green belt assessment shows it is suitable - is well contained, would not reduce significant gaps, has no specific countryside function and has no relationship with a historical town.

Change suggested by respondent:

Add land rear of Mill House Farm to plan

Full text:

1. Introduction & Background
Introduction

1.1 This Regulation 19 Local Plan representation has been prepared by Phase 2 Planning and Development Ltd on behalf of Mr Terry Haynes, on behalf of the freehold owner of the subject site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX as outlined by the Site Location Plan included at Appendix 1.

1.2 This submission is made under the Provisions of Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations (2012) and relates to the following sections of the Council's Pre-Submission Draft Local Plan:
- Section 4: Managing Growth
Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Representation summary
1.3 In summary, the landowner wishes to highlight the sustainability of the proposed site on land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality. Please see the remainder of this supporting statement for further consideration in support of the subject site's inclusion in this emerging Local Plan strategy.

2. Soundness & Modifications
2.1 As the attached representation form confirms the landowners representations relate specifically and solely to the soundness of the draft Submission Local Plan in respect of being positively prepared, justified, effective, and consistent with national policy in relation to the following sections of the emerging Local Plan:

- Section 4: Managing Growth

Specifically Policy SP02: Managing Growth
- Section 9: Site Allocations

Soundness
Section 4: Managing Growth
Draft Policy SP02: Managing Growth
2.2 Although on the whole it is generally considered that the Council's Pre-Submission Local Plan is sound there is some concern that the Council's Housing Requirement is not fully robust.

2.3 Planning Practice Guidance (PPG) on 'Housing and economic needs assessment', which was updated on the 20th 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.

2.4 Paragraph 4.13 of the Council's Pre-Submission Draft 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.

2.5 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) with this assessment confirming 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 fully sound on this basis.

2.6 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.

2.7 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.

2.8 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.

2.9 With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan-Pre-Submission Document can be considered to be robustly sound as, in accordance with paragraph 35 of NPPF3, the Plan is not fully 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 in full as it will not, as a minimum, meet its objectively assessed needs.

Section 9: Site Allocations
2.10 The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Pre-Submission draft 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).

2.11 Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not fully sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation.
1.4 The following section of this representation provides support for land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX, to be allocated for new residential development.
1.5 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 fully agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears ambitious.
1.6 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.
1.7 This level of growth from such a strategic allocation does not appear realistic and no evidence has been put forward to date to support this forecast. For example, it is unlikely that the Local Plan will be adopted until 2020 at the earliest (the Council's Local Development Scheme
Page 4 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


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).
1.8 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 up to two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission.
1.9 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.
1.10 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.
1.11 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.
1.12 Furthermore, it is considered that the Local Plan is not entirely sound as it does not comply fully with paragraph 68 of the National Planning Policy Framework (NPPF3) (February 2019).
1.13 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.
1.14 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.
1.15 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,
Page 5 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


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.
1.16 Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX) should be identified for allocation.

1.17 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.

Necessary modifications to make the Pre-Submission Draft Local Plan sound
1.18 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
1.19 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 agrees 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.
1.20 Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3.
1.21 It is considered that land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX is an appropriate site for residential development and should be allocated for appropriate new residential development.
1.22 The site itself includes land directly east of Hook End and north of Wyatts Green which would continue the existing pattern of development in this location as well as extend north comprising a logical and well-contained urban extension to the village with existing residential development already neighbouring the site to the south and west. Despite this the subject site still remains of a greenfield nature situated within the Metropolitan Green Belt.

1.23 Although noted that Hook End/Wyatts Green are proposed to be classified as smaller villages within the Borough's Settlement Hierarchy the importance of allocating appropriate growth throughout the Borough cannot be underestimated. The subject site itself would be well-placed to assist in enhancing the vitality of these rural communities allowing these villages to grow and thrive, especially where there are groups of smaller settlements, with development
Page 6 C19049: Land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX


in one village able to support services in villages nearby as advocated by para 78 of NPPF3. This is particularly relevant in this instance given Hook End/Wyatt Green's physical relationship to the nearby villages of Stondon Massey and Doddinghurst as well as the village of Blackmore which itself includes some planned growth under the current Local Plan strategy.

1.24 Importantly NPPF3 also highlights at para 84 that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. It adds at para 103 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-making.

1.25 Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed this part of Hay Green Lane lying on the southern edge of 'Parcel 48 Wyatt's Green East. The report when assessing the parcel as a whole, confirms that it makes a 'high' overall contribution to Green Belt Purposes although it is noted that the majority of this parcel is open to the east of Wyatt's Green with the subject site adjacent to the physical extent of the village to the north and much more likely to play a less substantial role in such purposes.

1.26 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.

1.27 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 rural area of Hook End and is well contained by existing built development and mature trees. Development would be seen as a logical extension to the physical extent of the village 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 Hook End/Wyatts Green and nearby villages. Such countryside separation would be retained.
Purpose 3: to assist in safeguarding the countryside from encroachment: The site has no specific countryside function and would utilise a well-contained parcel of land surrounded by residential development.
Purpose 4: to preserve the setting and special character of historic towns: The site has no physical relationship with any historic town.

1.28 Accordingly, it is considered that the site is suitable to be released from the Green Belt.
1.29 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, 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).
1.30 Those sites listed above are located within villages and the rural area comparable to that of the subject site.

1.31 Accordingly, we would request that the Local Plan be modified to allocate land rear of Mill House Farm, Hay Green Lane, Hook End, Brentwood, Essex, CM15 0NX for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas.

Conclusions
1.32 Based on the information set out above, it is considered that the inclusion of the subject site within the Council's proposed housing growth strategy or as an alternative reserve site would be sustainable and fully deliverable early within the Local Plan period, improving the overall soundness of the emerging Local Plan itself.

1.33 The possible low density nature of the allocation gives scope to provide a sensitively designed scheme which can be designed to integrate within and enhance the existing landscape having appropriate regard to local features and surrounding land uses, including existing neighbouring residential development.

1.34 Subsequently, the landowner contends that the relevant sections of the emerging Local Plan referred to within would be sound but could be improved further with the inclusion of this site ensuring the emerging Plan is positively prepared, effective and justified, and would be fully consistent with national policy including 'boosting significantly' the delivery of new homes within a borough that is heavily constrained by the Metropolitan Green Belt.

Inclusion of a red line boundary map for the site in question.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24077

Received: 20/05/2019

Respondent: LaSalle Land Limited Partnership

Agent: Chilmark Consulting Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to the omission of Honeypot Lane from the Brnetwood Pre-Submission Local Plan. Honeypot Lane is a sustainable development location in close proximity and easy access and integration with new jobs, community facilities, services and greenspace as a principal tier 1 category settlement; it would contribute to the five year housing supply; it has already been tested by the Sustainability Appraisal. Removal is not justified.

Change suggested by respondent:

LLLP conclude that the Plan needs to be modified to identify and allocate Land at Honeypot Lane, Brentwood (ref: 022) for residential development of up to 250 new dwellings with associated transport, community and green infrastructure. The Brentwood Borough Local Plan: Pre-Submission, January 2019. Allocation of Honeypot Lane must include its removal from the Green Belt and the appropriate revision of the boundaries of that designated area. The Plan's proposed Housing Trajectory (Appendix 1), the Key Diagram and the list of proposed allocation sites should be updated to include Land at Honeypot Lane accordingly.

Full text:

Representations for and on LaSalle Land Limited Partnership
Omission Site - Land at Honeypot Lane, Brentwood
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with the omission of LLLP's land interest Land at
Honeypot Lane, Brentwood (ref: 022) from the list of proposed housing allocations
and the Plan Proposals Map in the Pre-Submission Local Plan.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Overview
4. The Honeypot Lane site was included as a proposed residential allocation at the
earlier stages of the plan-making process, including the Draft Local Plan (February
2016). The site was previously allocated for up to 250 new dwellings and LLLP
had supported its inclusion and designation in the Plan as an available, suitable
and achievable residential site.
5. LLLP object to the omission of the site now and its exclusion from the Pre-
Submission Local Plan and set out the grounds for this in greater detail below.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Honeypot Lane, Brentwood: A Sustainable Development Location
6. Land at Honeypot Lane extends to some 10.9 hectares and is situated to the
west/south-west of Brentwood adjacent to the existing built-edge of residential
properties on Honeypot Lane and on Hill Road and South Weald Road to the
south. To the west, the site is bounded by the A12 (with Weald Park beyond) and
Weald Road to the north. Honeypot Lane provides a link between the A1023
London Road to the south and Weald Road to the north.
7. The site is enveloped on three sides by the existing built-form of Brentwood. It is
also contained within the existing landscape and topographical structure of the
western part of Brentwood, the A12 and Weald Lane. The site is situated below
the hill crestlines of Brentwood and South Weald (to the west of the A12).
8. The site is not currently actively used, comprising pasture land and is largely clear
of significant vegetation other than at its boundary edges.
9. The Brentwood Local Plan needs to positively address national policies to boost
housing delivery, economic growth and sustainable development. This should
include supporting the role and function of Brentwood as the highest order
settlement in the Borough and be the focus for future growth through the release of
sites because:
* it is the settlement with the largest existing population in the Borough;
* it contains the main employment areas (Brentwood Town Centre, Brentwood
Station and Warley Business Park);
* it contains the main retail areas (focused on the High Street);
* it has excellent rail accessibility and connectivity (that will be further enhanced
with the Queen Elizabeth rail line development); and
* it is the focus of the main identified public transport routes and services within
the Borough.
10. Given the extensive Green Belt designation covering much of the Borough, new
dwellings have historically been provided by increasingly scarce opportunities from
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
the redevelopment of larger brownfield sites, with the remainder comprising
contributions from a sizeable number of small infill developments within defined
settlement boundaries. For the future, these development opportunities are either
limited (i.e. an increasing shortage in available brownfield sites or under-used
employment land), or have site specific challenges such as being too small to
make a significant contribution to sustainability objectives, particularly where their
development would result in an over-intensive land use pattern.
11. The Plan must, in LLLP's view, support greater levels of development in
sustainable locations in Brentwood where:
* there is close proximity between jobs, homes and open spaces, capable of
being accessed by public transport, on foot or by bicycle;
* sites are readily deliverable;
* development would not damage the distinctive character of Brentwood, or the
overriding contribution of the Green Belt to Brentwood's quality of life,
biodiversity and environment, which are highly valued by the local community,
and which give it its character and distinctiveness;
* the Green Belt boundary can be reviewed and re-aligned using physical
features that are readily recognisable would continue to form a logical longterm
and defensible boundary for the urban extent of the Borough.
12. Land at Honeypot Lane (022) offers a significant opportunity to secure new homes
early in the plan period and to achieve a wholly sustainable form of development
that aligns with the spatial strategy and enhances the role and function of
Brentwood as a Category 1 Settlement with the highest order role and function in
the Borough.
13. Failure to include the site in the Local Plan now represents a failure to plan
positively and is not justified.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
4
Contribution to Five Year Housing Land Supply
14. LLLP has set out its concerns with regard to the failure of the Pre-Submission
Local Plan to effectively identify or meet the Local Housing Need of the Borough
(see LLLP's separate representation for Policy SP02: Managing Growth).
15. A choice and mix of housing sites of different characters, locations and sizes is
critical to enable the Borough to meet identified housing requirements, secure a
continuous five year land supply and to support the Plan's stated Strategic
Objectives (including SO1 in particular).
16. The continued lack of a five year housing land supply in Brentwood has, and will
continue, to lead to acute shortfalls in new housing provision with a very significant
risk that the Borough will continue to fail to meet the requirements of the NPPF at
paragraph 67 and also to fail to meet the Government's Housing Delivery Test
measures.
17. The Borough Council's decision to remove Land at Honeypot Lane as a residential
development allocation in the Local Plan was taken at the Council's Extraordinary
Committee Meeting on 8th November 2019 (purportedly on highway access
grounds despite not being based on any clear, properly presented, tested and
considered transport and highways evidence). Furthermore Officers were
prevented by the Council's standing orders relating to the management of
Extraordinary Full Council Meetings from speaking at the Meeting. If they had they
would have been able to advise Members that the Local Highway Authority (Essex
County Council) had raised no highways objections relating to the site's allocation
for housing development within the Plan at that time.
18. The removal of Honeypot Lane and the re-allocation of the dwellings into the
Dunton Hills Garden Village site (by increasing the quantum of that allocation)
serves to seriously and materially erode the Plan's ability to deliver necessary new
housing, offer a choice and mix of sites in the early part of the plan period, or to
make best use of available, sustainable sites in existing settlements.
19. Land at Honeypot Lane, Brentwood offers a significant opportunity deliver homes
now, contributing to the five year housing land supply position and to do so in a
sustainable urban location.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
5
20. The Borough Council has, in previous iterations of the Local Plan, clearly and
explicitly supported the site for release from Green Belt and recognised it as a
suitable, available and achievable location for housing to be delivered in the short
term contributing significantly to the five year land supply position
21. Indeed, the Honeypot Lane was assessed through the Borough's Strategic
Housing Land Availability Assessment (SHLAA) as a clear example of a site that
fulfils all of the criteria for release from Green Belt and has the ability to make a
significant, positive contribution to sustainable development and growth of
Brentwood early in the plan period.
22. Furthermore, the Plan's Sustainability Appraisal (including earlier iterations of the
SA) has identified Honeypot Lane as a preferred development site and a
sustainable location for new residential development. Nothing has changed in this
respect and the site remains a wholly sustainable location for residential
development with wide and positive benefits for Brentwood town and the Borough.
Sustainability Appraisal
23. The Local Plan's Sustainability Appraisal (January 2019) includes a site options
appraisal at Appendix 3.
24. Table C, from page 97) sets out detailed site options appraisal testing for each site
in the Pre-Submission Local Plan. Details of the methodology for appraising
individual sites is set out from page 92 onwards with 17 distinct criteria used in the
assessment using a RAG (Red, Amber Green) scoring model to "aid
differentiation, i.e. to highlight instances of site options performing well/poorly. The
intention is not to indicate whether a 'significant' effect is predicted" according to
footnote 70 on page 93.
25. Page 99 sets out the SA assessment of 022, Honeypot Lane, Brentwood. LLLP
has reviewed the SA assessment of the site and concludes the following:
* 8 criteria are scored as Green or are not covered in the scoring, indicating that
the site performs well against those criteria;
* 9 criteria scored as Amber; and
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
6
* 0 criteria scored Red.
26. The site has no red criterion scores and performs well in comparison with all other
proposed allocations.
27. LLLP has reviewed in more detail those criteria for Honeypot Lane that are scored
Amber in the assessment and comment as follows in relation to the SA findings
and the criteria and their thresholds set out in Table B:
* Air Quality Management Area - the SA notes for this criterion that the impact
thresholds are unknown. The Amber score is for sites that are <1km from an
AQMA. In this case the AQMA is the Town Centre of Brentwood. However
Honeypot Lane is well situated in relation to the town centre to offer access by
cycling and walking rather than use of the private motor vehicle and the site is
not known, from any analysis or evidence available to LLLP, to have any
problematic air quality issue.
* Site of Special Scientific Interest (SSSI) - the Amber score is for sites that
are >800m but <2km from an SSSI. While Honeypot Lane falls within 2km of
a defined SSSI and is therefore within the SSSI Impact Risk Zone, the SSSI in
question is to the south of Brentwood town centre at Thorndon Park (a public
amenity and open space area of Woodland) and well away from Honeypot
Lane. The Opportunity for impact on the SSSI in this area arising from the
site's development is unclear from the SA and there is, in reality, unlikely to be
any material adverse impact arising from development of Honeypot Lane on a
SSSI located some 2.9 km away from the site by road. Any identified adverse
effects arising from Honeypot Lane's development could of course be subject
to appropriate mitigation measures and would not preclude development.
LLLP do not consider that Honeypot Lane should be scored Amber in relation
to the Thorndon Park SSSI on this basis.
* Local Wildlife Site - this criterion scores Amber if the site is <400m from a
designated Local Wildlife Site (LWS). Such sites are considered to have a
relatively low sensitivity according to the SA. In the case of Honeypot Lane,
the LWS in question is located to the north of the A12 at Weald Country Park
an established public country park location intended specifically to
accommodate and provide informal open space and recreation opportunities
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
7
for the local community. It is not clear to LLLP why Honeypot Lane is scored
Amber in this regard as the site is neither within 400m of the Park entrance (it
is some 2.2km by road) nor does residential development of the site
necessarily adversely affect the Park. Any identified adverse effects could of
course be subject to appropriate mitigation measures and would not preclude
development. LLLP do not consider that Honeypot Lane should be scored
Amber in relation to a designated LWS on this basis.
* Woodland - an Amber score is recorded for sites that 'intersect' with
woodland (i.e. have the feature on-site). Such non-designated woodland sites
are of low sensitivity. In this case, Honeypot Lane has some existing trees at
its boundaries but there is not an area of Woodland on-site or adjacent to it. It
is not clear to LLLP why the site is scored Amber in this situation. In any
event, the development of Honeypot Lane would include appropriate survey
and protection for existing trees where possible as well as a landscape
strategy to support the provision and enhancement of trees and other
vegetation offering a positive benefit. The Amber score is not supported for
Honeypot Lane.
* Green Belt - sites score Amber where they intersect with the Green Belt. It is
noted that there is no Red or Green score for this criterion set out in Table B.
Honeypot Lane is within the Green Belt, but extensive analysis of the role and
function of the Green Belt in this location has been undertaken by LLLP which
supported the Borough Council's positive support for release of the site from
the Green Belt to assist with meeting evident housing needs as well as
providing a new, long-term, defensible boundary for the Green Belt along the
A12 road corridor in this location. The Amber score is correct but should not
be viewed as a significant determinative factor in the ability of the site to be
sustainably developed.
* Special Landscape Area - the criterion is listed as scoring Amber if the site
intersects with such areas. It is noted that there is no Red or Green score for
this criterion set out in Table B. It is not clear to LLLP what landscape
designation is considered under this criterion. There is no defined landscape
quality designation applicable to Honeypot Lane. Change to the existing
landscape character is a factor of development and Honeypot Lane's
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
8
development would be subject to a detailed masterplan and landscape
strategy and supported by a Landscape and Visual Impact Assessment setting
out any residual effects and a mitigation strategy. LLLP do not agree that
Honeypot Lane should be scored Amber in relation to the Special Landscape
Area criteria.
* Agricultural Land - the SA classifies Grade 2 Agricultural Land (the Best and
Most Versatile) as Red, while Grade 3 land is scored Amber. Honeypot Lane
is a large site but has no agricultural land of Grade 1 or 2. The site is Grade
3b or below and it is noted that the SA criterion makes no distinction between
Grade 3a and Grade 3b, with the deficiency that Grade 3b is not usually
considered to be good quality agricultural land. The criterion is considered to
be crude in its assessment and fails to allow, for larger sites in particular, such
as Honeypot Lane, that there may be distinct areas of better and poorer
quality agricultural land. Agricultural land classification is not, in LLLP's view a
significant determinative factor in whether a site is capable of sustainable
development.
* General Practice Surgery, Primary School and Secondary School - these
three criteria are all based on walkable distances for those accessing
schooling or general practice surgery healthcare. Amber scores for GP
Surgery and Primary School are given for sites between 800m and 1.5km
walking distance to the nearest facility. For Secondary schools, the Amber
score is for sites of between 1.5km and 3km walking distance. This analysis is
far too simplistic as it fails to recognise: the potential for sites to bring forward
contributions to the development of school or GP surgery facilities either on or
near to the site; the level of capacity now and in future for existing nearby
facilities; or the ability of such existing facilities to expand in future. For
Honeypot Lane, there is an evident opportunity to contribute to the provision of
expanded school or GP surgery facilities to be located off-site as appropriate
in accordance with the CIL Regulations. In this respect, LLLP conclude that
the Site should be scored Green rather than Amber to the extent that this
criterion is capable of offering a meaningful assessment of sustainability in
relation to primary healthcare or schooling. A simplistic distance measure is
insufficient and it is LLLP's view that this indicator should not be weighed as
having the same importance as others in the SA site assessment.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
9
28. In conclusion, LLLP recognise that the SA sites assessment testing is intended to
offer a relatively high level analysis of the potential sustainability of individual sites.
However, from closer and more detailed review it is clear that there are significant
flaws in the individual scoring criteria and obvious mis-application of the scoring
methodology to LLLP's Honeypot Lane site such that the scoring is misleading.
29. As demonstrated throughout this representation, Honeypot Lane is a sustainable
site and compares well, if not better than other potential and proposed housing
allocation sites including the long term development of Dunton Hills Garden
Village.
30. Indeed, the SA itself concludes in Appendix IV (page 114) that Honeypot Lane
makes only a "low-moderate contribution to the Green Belt purposes" which was "a
key reason why this site was a preferred allocation".
31. Setting aside the fundamental problems identified with the SA's site assessment, it
is clear that LLLP's land at Honeypot Lane, is a sustainable site for development
and that this position is further enhanced when full regard is had to the identified
Local Housing Needs of the Borough and the ability to bring forward new sites to
support residential development in the short term.
Conclusions
32. Land at Honeypot Lane, Brentwood (022) should be included once again within the
Local Plan as a residential allocation as it offers, inter alia:
* a sustainable site that is readily deliverable for high quality new homes now
and which can contribute significantly early in the plan (within the immediate
five year period) offering an improved choice of residential development sites;
* the ability to deliver a significant level of new homes for Brentwood in order to
help meet housing needs and is not reliant on the provision of extensive new
transport or other infrastructure;
* close proximity and easy access and integration of the new homes with jobs,
community facilities, services and greenspaces in Brentwood as a principal
Tier 1 Category settlement;
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
10
* support for the distinctive character of Brentwood and the contribution of the
wider Green Belt to Brentwood's quality of life, biodiversity and environment;
* a contribution to community and green infrastructure proposals for Brentwood
town in keeping with the landscape character of the area;
* capability to be easily accessed by a range of means including by bus, foot,
cycle as well as by road as supported by discussions with Essex County
Council as the Highway who have raised no objection as to the transport
sustainability of the site or any highway effects arising;
* easy connection to utilities and site services;
* a development opportunity that will support and contribute to Brentwood's
quality of life, biodiversity and environmental character;
* the opportunity to refine and re-align the Green Belt boundary forming a long
term, logical and defensible Belt boundary for Brentwood's urban area that is
contiguous with the A12 road and relates to recognisable physical features.
33. LLLP object to Pre-Submission Local Plan because of the omission of the
Honeypot Lane site. The Plan is unsound as it is not positively prepared. The
removal of Honeypot Lane as an allocated site is not justified in the context of the
Borough's pressing housing needs and the sustainable pattern of development
sought.
34. The Plan is not effective due to its failure to maintain the allocation of Honeypot
Lane and to exclude it from the proposed residential development allocations. It
does not represent the most effective or sustainable use of land and fails to reflect
the site's inherent sustainability and ability to contribute significantly to the acute
and persistent lack of housing land supply.
Modifications Required
35. LLLP conclude that the Plan needs to be modified to identify and allocate Land at
Honeypot Lane, Brentwood (ref: 022) for residential development of up to 250 new
dwellings with associated transport, community and green infrastructure. The
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
11
allocation of Honeypot Lane must include its removal from the Green Belt and the
appropriate revision of the boundaries of that designated area.
36. The Plan's proposed Housing Trajectory (Appendix 1), the Key Diagram and the
list of proposed allocation sites should be updated to include Land at Honeypot
Lane accordingly.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24749

Received: 19/03/2019

Respondent: Miss Harriet Davis

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Any future development should be led by the local community rather than trying to hit target.

Change suggested by respondent:

To make the Plan sound Blackmore should be removed from the LDP.

Full text:

See attached.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 25396

Received: 19/03/2019

Respondent: Mr & Mrs Michael & Valerie Lamont

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Not sound, not justified.

Full text:

See attached.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 25626

Received: 18/03/2019

Respondent: Blackmore, Hook End and Wyatts Green Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Submission on behalf of Blackmore, Hook End and Wyatts Green Parish council and on behalf of Blackmore Village Heritage Association by Holmes & Hills LLP. 18 March 2019.
Representing 350 households in Blackmore (population 943) and a Parish Population of 2,561 with the BVHA membership of 150. strongly object to the inclusion of R25 and R26 within the local plan. They are contrary to both national and local policies as:
BBC fail to demonstrate that housing need cannot be met on previously developed land sites in existing urban areas or by increasing densities on other proposed allocated sites.
BBC fail to demonstrate that there are no or insufficient previously developed sites outside the existing urban areas.
That there are preferable green field sites available and more sustainable.
R25 and R26 are unsuitable due to inadequate access, flooding, a disproportionate increase in housing stock and the development would not be sustainable.
Disagree that Blackmore is a category 3 settlement and is in fact a "larger village".
Therefore concluding that the plan is unsound as it has not been positively prepared not effective, and is not justified nor consistent with the NPPF.

Change suggested by respondent:

Remove R25 and R26 from the plan.

Full text:

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

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

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

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

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

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

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

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

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

Background

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

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

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

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

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

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

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

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

Issues concerning Consultation and Consistency

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

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

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

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

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

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

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

Evidence Base

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

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

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

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

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

Sustainable Development

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

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

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

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

Green Belt

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

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

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

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

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

A Settlement Category 3 village?

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

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

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

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

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

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

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

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

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

Summary/Conclusion

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

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

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

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

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

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

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

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

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

HOLMES & HILLS LLP
Dated 18 March 2019

Appendix One - Redrose Lane PHOTOS

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

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


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


Appendix Three - Agricultural Land Assessment and Flooding/Flood Risk

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

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

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


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

Above: Redrose Lane - March 2018

Extract from Daily Telegraph re 2011 Flooding:

Extract from Express re 2011 Flooding:

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

Attachments: