Paragraphs 1.1 - 1.5 of the PSLP and all references throughout the PSLP including supporting text and Policies should be amended to refer to a period of at least 15yrs from date of adoption. It is suggested that this be at least 2016 - 2035. Policies SP02; HP07; and PC02 should be amended to refer to a minimum of 15yrs from date of adoption with all housing and land requirements adjusted accordingly.

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

Paragraphs 1.1 - 1.5 of the PSLP and all references throughout the PSLP including supporting text and Policies should be amended to refer to a period of at least 15yrs from date of adoption. It is suggested that this be at least 2016 - 2035. Policies SP02; HP07; and PC02 should be amended to refer to a minimum of 15yrs from date of adoption with all housing and land requirements adjusted accordingly.

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

All references throughout the Plan including supporting text and Policies should be amended to refer to a period of at least 15yrs from date of adoption. It is suggested that this be at least 2016 - 2035.

1.0 Introduction and Background
1.1 This representation for the Brentwood Pre-Submission Local Plan (PSLP) 2019 is submitted by Strutt & Parker of behalf of BPM Investments Ltd, who hold a Promotion Agreement for Salmonds Grove, Ingrave. The site has been promoted to the Council through the previous Local Plan consultations and has been assessed by the Council. The site is identified by the attached location plan (Appendix 1). Representations were submitted in March 2016 for the Draft Local Plan and the site has been considered by the Council through its Strategic Housing Land Availability Assessment (SHLAA) 2011, the Site Specific Sustainability Appraisal (SA), and the January 2018 Site Assessment Methodology, Site Ref. 067a and 067b. Representations to the Regulation 18 consultation were also submitted highlighting many of the same concerns.
1.2 The site is on land currently allocated as Green Belt in the Brentwood Replacement Local Plan (2005), but is situated immediately adjacent to the settlement boundary of Ingrave and Herongate. It is recognised that the settlement boundaries contained within the Brentwood Replacement Local Plan 2005 were predicated on the need to accommodate significantly less development than currently required, and this site is located in a sustainable position on the eastern boundary of Ingrave, in an area of residential character.
1.3 The specifics of the site, and its sustainability for allocation for residential development, has not been recognised in the PSLP. We have raised a number of concerns in respect of the proposed approach in the Brentwood Borough Council Preferred Site Allocations (PSA) Consultation, and set out that should the Council proceed in the current direction it will result in a plan that is unsound. Our concerns do not appear to have been addressed satisfactorily and it is considered that the PSLP, without modifications, is unsound for the following reasons: a. It fails to meet housing need over the entire plan period and is reliant on strategic allocations that will not deliver as promptly as set out in the PSLP Trajectory; b. The PSLP fails to meet the housing needs in full, as there is no accounting for underdelivery in neighbouring authorities; c. The PSLP provides only a very narrow margin compared to the calculation of housing need under the Standard Method, and is therefore inflexible; and d. The Spatial Strategy fails to meet the housing needs of settlements such as Ingrave.
1.4 It is considered that land at Salmonds Farm, Ingrave, should be removed from the Green Belt and allocated for residential development in order to assist with the soundness of the Plan. An illustrative development for the site, which would be sustainable and in keeping with Ingrave, is provided at Appendix 2 to assist in understanding the nature of the proposal. The site represents a modest extension to an existing residential area, within a sustainable location. It represents a deliverable site to assist in meeting the Borough's housing need in the short term with negligible impact on the Green Belt and surrounding landscape. Plan Period
1.5 The proposed plan period runs until 2033. Assuming adoption in 2019, this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (Paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption.
1.6 This deficiency in the PSLP is of particular relevance given that the Borough is predominately Green Belt, and failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt; its permanence (NPPF, Paragraph 133).
2.0 Housing Need
2.1. There is an acute housing shortage at both the national and the local level. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.2. The National Planning Policy Framework (NPPF) attaches great importance to the need for Local Plans to meet objectively assessed housing needs. It is a requirement of a sound Local Plan. Furthermore, the NPPF calls for a significant boost to the supply of land for housing, and requires Local Planning Authorities to ensure a sufficient supply of sites to provide five years worth of land for housing against housing.
2.3. At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12 it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying PPG).
2.4. However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.
2.5. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum, not 350.
2.6. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years).
2.7. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need.
2.8. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum.
2.9. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.10. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities.
2.11. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional years' worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for.
2.12. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period.
Five-year housing land supply and housing trajectory
2.13. The Council is required to demonstrate a five-year housing land supply at any point in the plan period.
2.14. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.15. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied.
2.16. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years.
2.17. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.18. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a fiveyear requirement of 2,712 dwellings.
2.19. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises just 653 dwellings. It is unclear how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply.
2.21. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward.
2.22. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.23. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.24. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to deliver housing completions from 2022/23, i.e. falling within the first five years of the plan.
2.25. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
2.26. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this is required before development has even begun.
2.27. The ability of larger sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin review (2018) and issues with their complexity have been ably set out in the Lichfield Study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematic due to a range of factors, including establishing the required infrastructure, and the timings of housing delivery associated with those requirements as well as the prolonged or protracted nature of the planning process. The Litchfield's report confirms that the planning process takes on average 2.5yrs for the planning application determination period for schemes of up to 500 units, but that this can double for sites over 1,000 units.
2.28. BPM Investments Ltd is a company owned by housing specialists Arebray Development Consultancy, DAP Architecture and Silverstone Lane and they all deliver schemes consistently within Essex. They are able to provide detailed evidence on the delivery rates of minor and major developments. Two such hypothetical scenarios are provided with this representations (Appendix 3 and 4)
2.29. Scenario 1 provides a 50 Unit Brownfield site. This has outline planning consent and is to be marketed. It contains existing buildings that will require demolition and there is limited contamination. Access can be gained directly from the highway and all mains services are available to the edge of the site without any works required outside the site boundary.
2.30. Scenario 2 is a 200 unit Greenfield site at the edge of an existing settlement. The site is to have outline planning consent and is to be marketed. It is assumed there will be no significant delays due to Archaeology and Ecological constraints but recognise this could be greater depending upon the time of year the programme starts. It is assumed that the site is available for immediate development. Time is allowed for local infrastructure upgrades and new junction arrangements to provide access into the site.
2.31. These scenarios both assume that there are no delays and therefore represent a best case situation for two current projects. We have presumed that workflows will overlap where there are no commercial risks by doing so.
2.32. The scenarios confirm that large scale development can take up to 3yrs to provide the first dwellings after outline planning permission is approved, while smaller schemes are predicted to require two years for delivery of the first units. The timeframe is compounded by the scale of development, as recognized by the other reviews into delivery rates. For the strategic allocations in Brentwood, it is noted that the masterplanning stages are likely to add significantly to these timeframes, which follow from outline planning permission.
2.33. For the above reasons it is unrealistic to project that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound.
2.34. The strategic sites are expected to deliver 1,555 dwellings within 5yrs of adoption. Given the matters set out above, this is unrealistic and it would not be justified to rely on these sites to meet short term housing delivery. This emphasises the need to review sites such as ref. 067a and 067b to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is sound.
3.0 Spatial Strategy for Growth
3.1. Ingrave is identified as a Category 3 settlement -Villages in sparse rural locations that provide day to day needs for local residents. Ingrave has an established community, with services commensurate with its population. This is highlighted in the Council's own report of November 2017, paragraph 103, which confirmed that Ingrave and other Large Villages provide opportunities for small edge of settlement release to support housing growth. It is important that the Local Plan manages the growth of the settlement to ensure the vitality of its communities is sustained or enhanced.
3.2. Notwithstanding the above, the PSLP proposes to direct no additional growth to Ingrave. This contrasts with the approach to Blackmore, but otherwise the Council's preferred approach for Category 3 and 4 villages is to direct no growth over the plan period. This approach is considered to be unsustainable for these settlements. These views were raised at previous consultation stages. The spatial strategy fails to ensure the sustainable growth of Ingrave. The proposal to direct none of the Borough's housing need to Ingrave is unjustified, and inconsistent with national policy.
3.3. To ensure the Local Plan is sound, the special strategy should be amended to direct a proportionate level of growth to Ingrave. Housing Delivery
3.4. Paragraph 41 of the PSLP states that affordability ratios in Brentwood require an upward adjustment to the housing supply to be made.
3.5. It is recognised that the Council is deficient in providing a five year supply of housing land. It is therefore important to balance the strategic allocations with smaller sites, as these will generally have fewer constraints and can be delivered quickly to assist with meeting the persistent undersupply of housing in Brentwood. Such sites include land at Salmonds Grove, which can be delivered within the first five years of the plan.
3.6. The NPPF expects LPAs to identify the scale and mix of housing the local population is likely to need over the plan period which, among other matters, meets household and population projections, taking account of migration and demographic change; caters for housing demand and the scale of housing supply necessary to meet this demand.
3.7. The proposed plan does not account for migration from London, as identified in the PBA OAN report. This is contrary to the NPPF.
Green Belt
3.8. A detailed Green Belt Appraisal was prepared in respect of the Site by The Landscape Partnership and submitted at the Regulation 18 stage consultation. A copy is provided again here, for completeness (Appendix 5).
3.9. The Green Belt Appraisal considers the contribution of the site in relation to the five purposes of including land in the Green Belt, as per paragraph 134 of the NPPF: * To check the unrestricted sprawl of large built-up areas: * To prevent neighbouring towns merging into one another; * To assist in safeguarding the countryside from encroachment; * To preserve the setting and special character of historic towns; and * To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
3.10. The Green Belt Appraisal provides a thorough review of the site in relation to these purposes, and concludes that: "The initial landscape appraisal fond that developing the site in the manner proposed, e.g. c.24 residential units, would be unlikely to result in any adverse effects on land with a landscape related designation, Conservation Area, or Ancient Woodland. Salmond's Grove Farmhouse to the south of the site is a Grade II Listed Building; however, there is intervening built form between it and the site and it is thus unlikely that development of the type proposed would have a material effect on the farmhouse's landscape setting" (paragraph 5.1.2).
3.11. The Green Belt and Visual Appraisal further concludes that the removal of the site from the Green Belt and its subsequent residential development, would have no significant adverse effect on other landscape features such as topography, hedges, etc.:
3.12. A Part 3 Green Belt Appraisal (dated 31 January 2019) has been published by the Council. This considers specific sites, albeit in limited detail.
3.13. There is no evidence that the findings of the Green Belt Appraisal that was produced in respect of the Site by the Landscape Partnership, and which considered the Site in far greater detail than the Council's Part 3 Green Belt Appraisal, have been taken into account.
3.14. We are concerned with the simplistic approach that appears to have been taken in considering the contribution sites make to the purposes of the Green Belt. Overview
3.15. The Council's own evidence base states that the site is suitable, available and achievable for development. Development of the site is supported by a wealth of technical evidence that confirms its suitability, including in relation to the lack of harm to its development to the purposes of the Green Belt.
3.16. The reasons given for the rejection of the site are spurious and based on erroneous conclusions.
3.17. The rejection of the site is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed over the plan period and the lack of support for any growth at Ingrave.
4.0 Land at Salmonds Grove, Ingrave
4.1. The site was discounted from the Site Considerations as part of the Council's Site Assessment Methodology (January 2018). Larger Villages (Category 3 Settlements) are set out in Appendix 6 of the Methodology and repeated in this representation as Appendix 4. The site was discounted on the basis of 'Green Belt Impact'.
4.2. Discounting Salmonds Grove on this basis is unjustified. The Methodology report states that sites were selected based on initial high-level assessments of the key assessment criteria, being, amongst other matters, flood risk, Green Belt, landscape, highways, historic assets, ecological designations, utilities, education and health facilities. There was, therefore, a reasonably extensive set of criteria analysed for each site (para.3.22- 23 of the Brentwood Draft Local Plan - Preferred Site Allocations Site Selection Methodology and Summary of Outcomes Working Draft). The conclusions for each assessment are summarised in the associated appendices of the Report, with Salmonds Grove in Appendix 6 (sites 067a&b).
4.3. For Salmonds Grove, the Site Assessment simply states that there would be 'Green Belt impact'. We are concerned that the assessment and the reasons for discounting an otherwise suitable, available and sustainable site, are not robust.
4.4. Salmond's Grove has been discounted at Stage 4 of the Site Assessments on the basis of an initial high-level assessment, which found that a site was (presumably) satisfactory and suitable on all criteria with the sole exception of impact on the Green Belt. If the site were unsuitable for other reasons, these would also be listed in Appendix 6 of the BBC Report.
4.5. Salmonds Grove adjoins Ingrave and is within Parcel 15 of the BBC Strategic Green Belt Assessment (SGBA). Parcel 15 is 458.4ha in extent, being a roughly square parcel extending from the east of Ingrave to the Borough Boundary. The Assessment concludes that the parcel is of high value to the purposes of the Green Belt. This is not surprising, given the extent of the parcel. However, this assessment is less helpful when assessing smaller sites that are well associated with the urban area, such as Salmonds Grove. The Assessment actually notes under Purpose 1 that the area is 'Very large parcel relative to Ingrave and Herogate'. This belies the unsatisfactory nature of the assessment when considering smaller sites and acknowledges the limitations of the Assessment for such sites. Tellingly, the Green Belt parcels with the least impact, Low-Moderate as identified through the Assessment, are mostly the smaller sites on the edges of urban areas (parcel Nos. 32; 45; 56; 07a (BBC Green Belt Study Part II: Green Belt Parcel Definition and Review; p.43).
4.6. Accordingly, in order to assist the Council in identifying suitable sites within large GB parcels, it is considered that a more fine-grain assessment of sites should be undertaken. This is particularly important, given that the Council are not able to meet the housing needs of the Borough and would meet the tests set out in Calverton Parish Council v Nottingham City Council & ors. [2015] EWHC 1078 (Admin).
4.7. As set out above, the promotor of the site has prepared a Landscape and Green Belt Assessment, providing a full analysis of how it contributes to the five purposes of including land in the Green Belt (Appendix 5).
4.8. This focused assessment concludes that the site: * would be unlikely to result in any adverse effects on land with a landscape-related designation, Conservation Area, or Ancient Woodland; * there would be no significant adverse effect on other landscape features such as topography, hedges; * the site exerts relatively little influence on the surrounding townscape and landscape beyond its immediate vicinity; * Salmond's Grove site makes a Low contribution to the Green Belt purposes, and it could be developed in the manner proposed without compromising the objectives of the wider Green Belt.
4.9. To ensure the plan is sound, it is considered that additional sites should be identified and allocated. Those sites should include those of less importance to the Green Belt, such as Salmonds Grove, Ingrave. Not to include the site in the Local Plan is unjustified.

Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest the PSLP that even if the plan period is extended until 2035, policies should account for potential development needs beyond this.

This representation on the Brentwood Borough Proposed Submission Local Plan
(February 2019) (PSLP) is submitted by Strutt & Parker on behalf of Barnoaks
Management Ltd. The representation is made in relation to Land south of the B1002,
Ingatestone. The site is referenced as 078 in the Council's plan making process. A location plan showing the site is provided at Appendix A of this representation. The site has previously been submitted through the Council's Call for Sites (2011) and
the Strategic Housing Land Availability Assessment (SHLAA) (Ref: GO20). In the
SHLAA, the site was defined as a 'greenfield parcel with potential'. More recently, the site was submitted through the Housing and Economic Land Availability Assessment (HELAA) (2018) (Ref: 078). The site was defined in the HELAA as a suitable, achievable and available site for residential development, which could come forward within 1 - 5 years. Representations were also submitted to Brentwood Borough Council through the Regulation 18 Consultation (2018). The site measures at approximately 1.8ha and could support the delivery of up to 54 dwellings. The site is located adjacent to the eastern edge of the settlement boundary of Ingatestone, on land, which is currently allocated as Green Belt. Currently, the site is not proposed to be allocated for residential development. The
rejection of the site for allocation is considered unjustified. The allocation of land south of the B1002, Ingatestone, for residential development would represent a sustainable and deliverable proposal to help meet housing needs over the coming plan period. The proposed plan period runs until 2033. Assuming - optimistically - adoption in 2019, this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (Paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption. This deficiency in the PSLP is of particular relevance given that the Borough is predominately Green Belt, and failure to ensure that development needs are planned
for over a sufficient period of time would likely result in an early review of the Green Belt being required - contrary to the NPPF (paragraph 136); and undermining one of the two essential characteristics of the Green Belt; its permanence (NPPF, Paragraph 133). At paragraph 4.13 of the PSLP, it states that the Borough's housing requirement it plans for is 350 dwellings per annum. At paragraph 4.12 it states that this figure has been calculated using the Standard Method (as per the NPPF and accompanying PPG). However, this does not appear to be the case having regard to updated guidance. The PPG now confirms that 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method. The relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this result in a requirement of 452 dwellings per annum, not 350. The Local Plan is required to meet this need as a minimum (NPPF paragraph 35); and with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). In addition, the Local Plan is required to ensure that the revised Green Belt can endure beyond the plan period (NPPF paragraph 136), i.e. in amending the Green Belt boundary, the Local Plan should account for development needs beyond 2033 (or, more appropriately, a revised later end to the plan period, which will ensure strategic policies will cover at least 15 years). A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In this respect, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of Brentwood Borough Council having objected to this approach, but neither is there any indication that the PSLP addresses any of this unmet need. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The PSLP's rationale for this buffer is somewhat unclear: it states at Figure 4.1 that the buffer allows for an additional housing land supply to be maintained in the Borough throughout the plan period; but states at footnote 2 that the housing supply buffer serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'. In any case, the uplift means that the proposed annual housing target in the PSLP is only fractionally above the minimum housing requirement derived from the Standard Method, and does not provide any flexibility to ensure needs are met; does not ensure the Green Belt will endure beyond the plan period; and does not account for unmet need in neighbouring authorities. Further to our comments in respect of the plan period, and the PSLP's failure to ensure strategic policies are in place to cover at least 15 years from adoption, as an absolute minimum the PSLP must be amended to ensure an additional years' worth of housing need can be accommodated. Given likely timescales for adoption of the Local Plan, we suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for. Whilst we suggest 2035 should be the treated as the earliest end to the plan period, it should also be recognised that the authority is predominantly Green Belt. The NPPF requires this Local Plan to ensure the Green Belt will endure beyond the plan period. As such, we suggest the PSLP that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. The Council is required to demonstrate a five-year housing land supply at any point in the plan period. In terms of the five-year housing requirement, the NPPF (paragraph 73) confirms a 20% buffer should be applied to the initial calculation in the event the results of the Housing Delivery Test show that delivery has fallen below 85% of the requirement. The PPG confirms the requirement to apply such a buffer in such circumstances also applies where the Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan. The 2018 Housing Delivery Test measurement for Brentwood Borough shows that only 51% of the Borough's housing requirements were met over the last three years; well below the figure required to avoid a 20% buffer having to be applied. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. However, this is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five year requirement of 2,712 dwellings. In terms of supply, the HLSS includes sites without detailed planning permission and
without evidence such sites will be delivered within five years. As per the NPPF, such
sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises just 653 dwellings. It is unclear how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. The acute housing land supply shortage underlines the importance of allocating sites through the Local Plan which can deliver early in the plan period, and the need to avoid over reliance on large strategic sites which inevitably take a considerable time to bring forward. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings). Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing. Furthermore, and in respect of the projected supply, we are concerned to note that
Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan. Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders. The site has yet to even be allocated. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations. All of this before development has even begun. The ability of larger sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin review (2018) and issues with their complexity have been ably set out in the Lichfield Study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematic due to a range of factors, including establishing the required infrastructure, and the timings of housing delivery associated with those requirements as well as the prolonged or protracted nature of the planning process. The Litchfield's report confirms that the planning process takes on average 2.5yrs for the planning application determination period for schemes of up to 500 units, but that this can double for sites over 1,000 units. For the above reasons it is unrealistic to project that 100 homes will be completed at
Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that
Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it
does mean that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound. The strategic sites are expected to deliver 1555 dwellings within 5yrs of adoption. Given the matters set out above, this is unrealistic and it would not be justified to rely on these sites to meet short term housing delivery. This emphasises the need to review sites such as ref. 078 to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is Sound. Ingatestone is defined as a Category 2 Settlement. The Borough defines Category 2
settlements as larger villages in a rural setting, with high levels of accessibility and public transport provision, including rail services. These settlements provide a range of services and facilities to the immediate residential areas and nearby settlements. The PSLP states that appropriate urban extension and brownfield development
opportunities will be encouraged to meet local needs. In 2011, Ingatestone had a population of 4,812 (Census; 2011). It is the Borough's largest village, with a modest level of facilities, including a secondary school. Furthermore, Ingatestone Railway Station is located within the village, and provides frequent railway services to London Liverpool Street, Stratford (London), Chelmsford, Colchester and other surrounding settlements. The PSLP confirms that although Ingatestone has relatively good facilities, a modest level of development is envisaged, due to infrastructure constraints and a lack of suitable sites. As such, only two sites have been allocated for residential development in the PSLP -R21 and R22. This results in a total of 218 dwellings for Ingatestone over the plan period. Site 078 has previously been defined in the HELAA (2018) as suitable, available and achievable site for residential development. The PSLP in this case is flawed, as it doesn't appropriately consider Site 078 as a suitable site for residential development. It is considered that the PSLP fails to support the sustainable growth of Ingatestone. The
failure to thoroughly consider Site 078 for residential development is unjustified. To ensure the Local Plan is sound, further suitable sites within Ingatestone should be
allocated to ensure the sustainable growth of Ingatestone. The site measures at approximately 1.8ha and could support the development of up to 54 dwellings. The site is located adjacent to the eastern edge of the settlement boundary, on land,
which is currently allocated as Green Belt. The site is bounded by existing residential development to the north and south and the B1002 to the west. To the eastern boundary of the site are agricultural fields. A considerable amount of technical work has been undertaken in respect of land south of the B1002 and has previously been submitted to the Council through previous stages of the plan-making process. The technical work undertaken demonstrates that the site is sustainable, suitable, available and achievable and its development would help meet the Borough's housing need. Work undertaken, and previously provided is included in this representation for completeness: * Proposed Site Plan prepared by Grafik (Appendix B); * Landscape and Visual Issues Scoping Report prepared by Nigel Cowlin (Appendix C); * Landscape Advisory Plan prepared by Nigel Cowlin (Appendix D); * Access Appraisal by Ardent Engineers (Appendix E). In previous representations submitted to the Council, we have commented specifically on the proposals for layout and landscaping, providing that the site would be allocated for residential development by the Council. A Feasibility Layout prepared by Graffik Architecture has previously been submitted to the Council and is included within this representation for completeness. The feasibility study demonstrates how 54 dwellings could be accommodated on the site. The layout illustrates how the site could provide infill development to the already existing settlement of Ingatestone, without adversely harming the landscape character of the area or the character of Ingatestone itself. The Feasibility Layout also shows the potential proposals for landscaping on site. These proposals have been formed through careful consideration of the existing landscape character of Ingatestone and in line with the Landscape and Visual Issues Scoping Report and Landscape Advisory Plan which has been prepared by Nigel Cowlin. The report and plan also accompany this representation. As set out above, a Landscape and Visual Issues Scoping Report and Landscaping Advisory Plan has been prepared by Nigel Cowlin and accompanies this representation. It is proposed that there is to be retained and enhanced landscaping on site, specifically to the eastern and southern boundaries. This landscaping proposal takes into account the Grade II Listed Building - Rays - which is located beyond the eastern boundary of the site. By proposing dense planting at this boundary, it will ensure that the development proposal has no adverse effect on the nearby listed building. The Feasibility Layout also illustrates that planting will be retained at the western boundary of the site at the High Street, where access to the site is proposed. Furthermore, it is illustrated that the existing oak tree at the western part of the site will be retained to provide a substantial area of open space on the site. The Scoping Report suggests that these simple design controls and landscape mitigation measures, such as the protection of existing field boundary hedgerows, along with retaining an open space around the mature Oak Tree at the front of the site, would help to ensure that the proposed development would be as successful as possible in landscape and visual terms. The Scoping Report found that the visual influence of the site to surrounding locations was found to be limited due to the built up nature of the surrounding area, for example the ribbon development to the north and the settlement edge of Ingatestone to the south. The report states that development of the site should be considered as a logical area for infill development along the B1002. The Environmental Assessment of Plans and Programmes Regulations (2004) requires SA/SEAs to inter alia set out the reasons for the selection of preferred alternatives, and the rejections of others, be made set out. In addition, the Planning Practice Guidance4 makes clear that the strategic
environmental assessment should outline the reasons the alternatives were selected,
the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. Sustainability Appraisal of the PSLP has been published: the Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA). Paragraph 5.5.31 of the SA confirms that Site 078 is listed as 1 of 5 omission sites in the HELAA as it is "deliverable or developable". The SA confirms that the two sites with the greatest potential for allocation are the adjacent "Parklands" Sites (Ref: 078 and Ref: 243), at the northern boundary of the village. The SA states that the accompanying Green Belt Review found that both sites contribute to the purposes of the Green Belt to a 'moderate' extent, however neither site is fully contained in the landscape. The SA concludes that the option of adding one or more omission sites was determined as "unreasonable", for the purposes of establishing reasonable spatial alternatives. No details are provided to explain in what way Site 078 is considered not to be fully contained in the landscape. Furthermore, as per Section 3 of this representation, the accompanying Landscape and Visual Issues Scoping Report confirms that further planting can be provided on site at all boundaries, thus ensuring it is a contained site. The proposed planting would be effective in appropriately screening the proposed development and ensuring the village character of Ingatestone is retained. In short, the SA does not provide a justified reason for the rejection of the site. Turning to the specifics of the SA assessment of the site, these are set out in Table C of the SA. This provides a 'traffic light' assessment of sites' sustainability. Green indicates sites perform well; amber - poorly; red- particularly poorly; against specific criteria. Our first point in relation to the approach taken is that it is very simplistic - the assessment of site appears to be based purely on physical distance to various features / facilities / designations. For example, in relation to criteria 10 (Conservation Area), our site is considered to score 'poorly'. Part of Ingatestone High Street is defined as a Conservation Area, however site 078 is not within this designation and is located at least 400m from the defined Conservation Area. As such, it is considered that the proposed development of the site would not unacceptably impact the Conservation Area. Furthermore, in relation to criteria 1 (Air Quality Management Area (AQMA)), the site is considered to score 'poorly'. The site is located approximately 1 mile from AQMA BRW6 at the A12/Fryerning Lane. It is considered that the AQMA will not be adversely impacted by the site, given the distance between the two. In relation to criteria 8 (Primary School), the site is considered to score 'poorly'. The site is located 0.5 miles from both an infant and junior school. It is considered that the primary school provisions within Ingatestone are within walking distance to the site and the site should not be scored as 'poorly' in relation to this criterion. As per the reasons above, we therefore consider the SA's assessment to be flawed. A Green Belt Study and Assessment has been undertaken by Crestwood Environmental
Ltd as part of the Regulation 19 Consultation. The Assessment looks to assess specific green belt parcels in relation to the 4 purposes of the Green Belt. These are: Purpose 1 - To check the unrestricted sprawl of large built-up areas; Purpose 2 - To prevent neighbouring towns merging in to one another; Purpose 3 - To assist in safeguarding the countryside from encroachment; Purpose 4 - To preserve the setting and special character of historic towns. Following this assessment, the parcel is given an overall assessment rating. The ratings are; Low; Low-Moderate; Moderate; Moderate - High; High. Site 078 is within Parcel 9A of the Green Belt Assessment. Parcel 9a includes land to the northeast of Ingatestone. The parcel size is 41.94ha. Purpose 1: Parcel 9a is defined by the Council as 'Partly Contained', as it abuts a large built up area. The assessment states that the 'Partly Contained' sites have weak/degraded/unclear boundaries. This is an overall assessment of the parcel and not specifically of Site 078. Site 078 has clear natural boundaries at the east and to the south. Furthermore, as detailed at Section 3, further planting is proposed at the site in order to contain the proposed development. Purpose 2: Parcel 9a has been assessed as an 'Important Countryside Gap'. The Assessment
states that the parcel forms either a large proportion of countryside gaps between towns or the development of the site would result in the physical narrowing of the gap and potential visual coalescence. As per the accompanying Landscape and Visual Issues Scoping Report, it is considered that the site would result in a coherent infill development between two existing areas of developed land. The Scoping Report also confirms that the proposed development of the site wold not result in the coalescence of Margaretting and Ingatestone. Purpose 3: Parcel 9a has been assessed as 'Functional Countryside' (FC). This again, is an overall assessment of the parcel and not specifically of Site 078. As such, we do not agree that Site 078 can be defined as Functional Countryside. The site is between existing development and can therefore be considered as an infill site. Purpose 4: The assessment states that Parcel 9A has a 'limited relationship with Historic Town'. We agree with this assessment. Overall Brentwood Borough Council have assessed Parcel 9a, as having a 'moderate' contribution to the 4 purposes of Green Belt. The above review of Parcel 9a recognises that this assessment is not necessarily reflective of the qualities of every site within the parcel. In respect of this, we wish to highlight the findings of the Inspector in the Welwyn Hatfield Local Plan Examination, which we consider helpful in the consideration of the PSLP. Following the Stage 1 and 2 hearing sessions at Welwyn Hatfield, the Inspector provided a note to the Council in December 2017 on its approach to review of the Green Belt (EX39 of the Welywn Hatfield Local Plan Examination). Within this note, the Inspector stated: "The Council has suggested that it is unable to meet its housing need because of
Green Belt restrictions among other concerns. In my concluding remarks ... I pointed
out that I did not consider the development strategy put forward in the plan to be sound, in part because there was insufficient justification for the failure to identify sufficient developable sites within the Green Belt. That is largely because the phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas." "Additionally, the phase 2 Green Belt Review, which did look at a finer grain of sites,
does not appear to have examined all of the potential development sites adjacent to
the urban areas..." "The actual development strategy finally arrived at is a matter for the Council... However, if that strategy fails to meet the FOAHN and assuming that all realistic development opportunities outside of the Green Belt have been put forward in the plan, then it is effectively saying that there are no exceptional circumstances justifying a further release of additional land from the Green Belt and that presumably means for as long as current national green belt policy and its interpretation prevails. That may be the case but unless all of the Green Belt has been forensically analysed in some detail then it is difficult to prove." Having regard to all of the above, key issues to consider include: * Whether all potential sites' impact on the Green Belt has been assessed; * Whether such assessment was undertaken at a sufficiently fine grain to properly consider individual sites' impact on the Green Belt.In respect of the PSLP, it is clear that not all potential development sites were subject to a sufficiently detailed analysis which could enable BBC to justifiably conclude it has identified a reasonable strategy to meet its housing needs, particularly where the plan is not meeting those needs in full. At the very least, there was one site that was not properly assessed: Land to the South of the B1002, Ingatestone. The Council's own evidence base states that Site 078 is suitable, available and achievable for residential development. Development of the site is supported by technical evidence that confirms its suitability, including in relation to the lack of harm to the landscape and Green Belt. The reasons given for the rejection of the Site are based on erroneous conclusions in the evidence base and should be re-examined. The rejection of Site 078 is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed in Ingatestone. The allocation of Site 078 for development will assist in curing defects in respect of the
Local Plan, enabling it to be a sound plan.

1. Introduction
1.1 These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Pre-Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients' land at 030A, Land at Bayley's Mead, Hutton, Brentwood. A plan showing the site is provided as Appendix A to this representation.
1.2 Countryside was founded in Essex 60 years ago by Alan Cherry and has since established a reputation for delivering high quality developments. With the ethos 'creating places people love', Countryside's achievements are exemplified through having won more Housing Design Awards than any other house builder.
1.3 Countryside is a major development and place-maker, having secured planning permission and building out developments in varying scales: from smaller 30 dwelling schemes on the edge of village's through to large urban extensions of 3,500 new homes plus associated community facilities. Countryside has a proven track record of delivery. The company is headquartered in Brentwood and has a proud legacy of local sites such as Clements Park and the Square on Hart Street.
1.4 As the Council will be aware, representations have previously been made on behalf of Countryside Properties and in respect of both sites 030A on the Preferred Options Consultation in October 2013 and the Strategic Growth Options Consultation February 2015, and the Regulation 18 Local Plan in March 2018.
1.5 Site 030A measures approximately 2.36 hectares. The Council have previously confirmed the net developable area of the site as 1.66 hectares, with the ability to provide an estimated 30 dwellings on site. The site is situated within the Green Belt.
1.6 Whilst the Plan is considered effective in meeting the minimum housing requirements through the proposed allocations, an unjustified lack of housing provision to exceed the minimum requirements, and to provide an appropriate buffer and flexibility for the future, does prevent the Plan from being considered sound as a whole.
1.7 Site 030A has been discounted as a site for residential development through the Local Plan process, for reasons which are considered in more detail later within this representation. We consider the rejection of the site to be unjustified, and to result in a PSLP which does not promote sustainable development and as such is unsound.
1.8 The allocation of the site, at Bayley's Mead, Hutton, for residential development would represent a sustainable and deliverable proposal to help meet housing need over the coming plan period and ensure the soundness of the Local Plan.
1.9 As a minimum, the site should be safeguarded for potential future release from the Green Belt to ensure that the Green Belt remains protected throughout the entire plan period, in accordance with Paragraph 139 of the NPPF.
1.10 This representation set out comments on the Regulation 19 Draft Local Plan, as well as providing detail on the sustainability and deliverability of the site with regards to technical considerations and latest assessment work.
2. Brentwood Local Plan Regulation 19 Consultation
Plan Period
2.1. The Draft Local Plan is proposed to guide development in the Borough of Brentwood until 2033. The National Planning Policy Framework (NPPF, 2019) makes clear at Paragraph 22 that strategic policies within Local Plans should look ahead over a minimum of 15 years.
2.2. At this stage it would be optimistic to assume that adoption of the Draft Plan, which forms the subject of this representation, will happen within 2019 and therefore the plan will only address development needs in the area for a maximum of 14 years.
2.3. This shortfall is particularly relevant in respect of Green Belt, whereby a failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of Green Belt being required. This review ahead of a new Local Plan would be contrary to the NPPF (paragraph 136), and also undermine one of the two essential characteristics of the Green Belt: its permanence (NPPF, Paragraph 133).
Total Housing Requirement
2.4. Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 dwellings per annum. Paragraph 4.12 confirms that this figure is calculated using the Standard Method (as per the NPPF and respective Planning Practice Guidance(PPG)). We note that the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).
2.5. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures, the result is a requirement of 452 dwellings per annum.
2.6. The NPPF requires for Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.
2.7. As mentioned previously, the Plan should also ensure that any revised Green Belt boundary should be robust enough to be maintained beyond the Plan period and therefore account for development needs beyond 2033 (or a revised later end date to the Plan period to ensure strategic policies will cover at least 15 years).
2.8. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). Councils have a duty to cooperate with one another on strategic matters, including on unmet housing needs (paragraphs 24 to 27 of the NPPF). The PSLP does not make an allowance for any unmet needs from neighbouring authorities.
2.9. Whilst the South Essex authorities are working together on a joint strategic plan, the Local Plans for each authority must still demonstrate joint working and a consideration of unmet needs where required. A number of nearby authorities have identified difficulties in meeting their own housing needs, including Castle Point, Rochford and Southend. We also not that Epping Forest District Council in particualr is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 2011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum.
2.10. Furthermore, the Borough is located within close proximity of London, with the emerging Local Plan identifying high housing delivery on outer London Boroughs and that London will fall short of meeting its housing needs by 10,000 homes over the next ten years. Unmet need from London could therefore be required to be met by nearby authorities, including Brentwood.
2.11. Whilst no authority has formally approached Brentwood in relation to unmet need, it is not inconceivable that an authority will do. Under the current PSLP there is no flexibility to meet any unmet needs from neighbouring authorities, requiring a plan review should a request to meet unmet needs be received once the plan is adopted.
2.12. Allocating additional sites would provide greater flexibility should a request to meet unmet needs be forthcoming, avoiding the need for an early plan review. This flexibility should also be provided in accordance with paragraph 11 of the NPPF and to accommodate additional need arising from extending the plan period.
2.13. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to be maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.14. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement. The plan is therefore considered ineffective in its current form and has not been positively prepared to provide an appropriate level of contingency in terms of housing delivery, or to comply with national planning policies. As such we consider the PSLP to be unsound.
2.15. As a minimum, we consider that the PSLP's housing need should be amended to at least ensure that an additional year's worth of housing need can be accommodated, and so that the relevant strategic policies of the Plan cover at 15 years from adoption. Realistically, we expect that an additional 2 years' worth of housing may be required to support a plan period up to 2035. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. The allocation of sites for housing in Hutton, including that at Bayleys Mead, would provide for additional housing delivery in a sustainable location and help to ensure that the Plan can be found sound.
Five-year Housing Land Supply and Housing Trajectory
2.16. The Council is required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).
2.17. The NPPF (Paragraph 73) confirms that a 20% buffer should be applied to the initial calculation for a five year housing land supply requirement, in the event that the results of the Housing Delivery Test show that there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. From November 2018 significant under delivery indicates that delivery was below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037-20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.18. The results of the 2018 Housing Delivery Test confirmed that Brentwood have delivered just 50% of the housing requirement over the last three years and this is therefore well below the threshold for the 20% buffer requirement.
2.19. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018)) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.20. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
2.21. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be considered deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.22. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can be delivered early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.
2.23. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.24. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.25. Furthermore, Dunton Hills Garden Village is a proposed major strategic development, intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure, and new community and health infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders.
2.26. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared. Following this, an outline application will need to be prepared, submitted, and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations.
2.27. As such, we question the likelihood of 100 homes being completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does demonstrate the unsuitability of relying on large strategic sites for short term housing delivery, and means that additional smaller sites capable of providing homes in the early years of the plan period also need to be allocated in order to ensure the Local Plan is sound.
2.28. It is evident that whilst the Plan can demonstrate housing delivery appropriate to meet minimum recognised requirements, the suggested inability of the Plan to ensure a consistent five-year supply is inconsistent with national policy, which requires that local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years' worth of housing against their housing requirement set out in adopted strategic policies. The PSLP should therefore support this requirement through the allocation of smaller scale sites that can be delivered over short timescales to be found sound. Land at Bayleys Mead is a site that would cater to this need, with its deliverability discussed in greater detail later on in this representation.
Proposed Approach to Hutton
2.29. Within the PSLP, the Borough's settlement hierarchy identifies Hutton as Category 1 - an 'urban neighbourhood'. A Category 1 settlement is defined as having a wide range of services, and are typically highly accessible and well served by public transport provision. Hutton has an established local centre which benefits from a range of services, facilities, access to public transport, and employment opportunities.
2.30. The town is situated approximately 30km from Central London, 12km from Chelmsford and well-connected in respect of regional and national infrastructure. Brentwood and Shenfield are accessible along the A12 corridor.
2.31. Hutton is a highly sustainable location, and therefore well-placed to accommodate a proportion of the Borough's housing need. In addition, the Local Plan should manage growth of such settlements to sustain and enhance their vitality.
2.32. Irrespective of the above, the PSLP proposes no growth for Hutton, in contrast to the level of growth afforded to other settlements identified as Category 1 settlements, or also those below Hutton, within the Borough's settlement hierarchy. We have concerns therefore that the PSLP fails to support the sustainable growth of Hutton and that this omission is unjustified and inconsistent with national policy.
2.33. To ensure the soundness of the Local Plan, land should be allocated in Hutton to protect the future of this settlement and ensure sustainable growth.
Green Belt
2.34. A Green Belt Study (November 2018) supports the PSLP. This study provides an assessment of Green Belt parcels against the five purposes of the Green Belt, as set out within the NPPF.
2.35. The study includes an 'assessment of Housing Sites (being considered as part of the SHLAA) within the Green Belt and their relative contribution to the purposes of the Green Belt designation'.
2.36. The site has been assessed against the five purposes of the Green Belt, as part of the Green Belt Study methodology as follows:
Purpose 1: To check the unrestricted sprawl of large built up areas
Parcel 14 is defined by the Council as 'partly contained', and recognises that it abuts a large built up area. This categorisation does however advise that the boundary is 'weak/degraded/unclear'. The site 030A is contained on two out of four boundaries by built form however and on remaining boundaries by established vegetation and hedgerows that could be incorporated and enhanced as part of a landscaping scheme that would support the redevelopment of the site. We consider that the site boundaries are clearly defined and the site is therefore well-contained. A conclusion of containment should not consider built form exclusively.
Purpose 2: To prevent neighbouring towns from merging into one another
The site is adjacent the eastern limit of Hutton Mount and the Green Belt Study correctly recognises that its development would retain separation from neighbouring towns. The next settlement to the east is Billericay and this is some distance away with a large green gap between the two. Other parts of Hutton already extend closer to Billericay without posing any risk of merging.
Purpose 3: To assist in safeguarding the countryside from encroachment
The site is defined by the Council as 'Functional Countryside' (FC). The assessment defines Functional Countryside as "access land, public area (park), high number of PRoW and important routes e.g. National Trail'. The site itself is overgrown, in private ownership, covered in dense vegetation, and not suitable for public access. It is not agricultural and is therefore not functional and this assessment of the site is incorrect.
Purpose 4: To preserve the setting and special character of historic towns
Brentwood Borough Council have recognised that site 030A has no physical of visual relationship with the Historic Town. It is some distance from the town centre with no direct relationship. It is directly associated with contemporary housing developments at Bayley's Mead and surrounding roads, which present limited historic character.
Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
Brentwood Borough Council have not provided an analysis for Purpose 5.
2.37. Overall, Brentwood Borough Council have assessed the site as having a moderate overall contribution to the Green Belt, despite the favourable assessment of the site. Where the site was assessed to have an important role on the Green Belt, we have outlined above that these elements of the assessment are incorrect and not reflective of the sites true characteristics.
2.38. The development of this Green Belt site, which has limited environmental value and offers a minimal contribution to the Green Belt when assessed against its five intended purposes, would help to support housing delivery in a sustainable location in the Brentwood Borough, whilst protecting other Green Belt sites of much higher environmental value.
2.39. The weaknesses and inconsistencies recognised in the individual site assessments made demonstrate a potential flaw in the evidence base for the Local Plan and could result in the unjustified omission of Green Belt sites from consideration for allocation as part of the new Local Plan.
2.40. The above analysis of land at Bayleys Mead, Hutton demonstrates that there remains small scale opportunities for sustainable development within the Green Belt and that the Local Plan should give consideration to the allocation of such sites alongside larger scale areas of release.
Strategic Environmental Assessment/Sustainability Appraisal (SEA/SA)
2.41. The PSLP is supported by a range of technical work, including the Sustainability Appraisal (SA) January 2019. The SA presents a number of sustainability issues/objectives which have been established through SA scoping. Together, these sustainability topics and objectives provide a methodological framework for the appraisal of potential allocation sites - including site 030A.
2.42. The SA indicates that the allocation of site 030A would have positive effects in relation to the SA objectives. The SA analysis states that site 030A is in good proximity to a secondary school (less than 1.5km), but in 'red' proximity from a GP surgery and a primary school. Willowbrook Primary School is located within 1 mile of the site, which is considered to be within walking distance to the site. The nearest GP Surgery, Mount Avenue Surgery is located 1.5 miles from the site. Mount Avenue Surgery is defined in the Regulation 18 document to be 1 of 3 surgeries within the District which has an average of 0.58 GPs per 1,000 patients, which is the national average. Furthermore, Mount Avenue Surgery has a large catchment area, therefore it is considered that it would provide service to those living at the site. Furthermore, Brentwood Community Hospital is located less than 3 miles from the site.
2.43. The SA, through its analysis also states that the site at Bayley's Mead is in an area that 'performs poorly' in respect of its proximity to Ancient Woodland, Local Wildlife Site, Woodland and Green Belt. The proposed development of the site will not unacceptably impact on Ancient Woodland, Woodland or a Local Wildlife Site. This scoring is considered to be highly assumptive and rules out the potential of sites being landscaping led and providing opportunities for the enhancement such features and local biodiversity. Being within 400m of a local wildlife site does not necessarily mean that there will be direct impacts on the site.
2.44. In relation to Green Belt, the assessment is binary in it's approach - if a potential site falls within the defined Green Belt, it will be given an 'Amber' score. Whilst the methodology notes that the Green Belt is not specifically a landscape designation, and as such potential effects on the setting have not been appraised, a blanket 'amber' score on anything seems arbitrary.
2.45. A Green Belt Review of the Borough, and the contribution that each individual site makes to the Green Belt has been undertaken and this is discussed in more detail in the following section of this representation. This recognition of differing value across individual sites should have influenced scoring for this element of the SA, and replaced the non-conducive binary approach taken.
2.46. In general, we consider that the SA Report is simplistic in its approach to individual site assessment. The SA has used a predominantly spatial or 'GIS' (use of Geographical Information Systems) approach to the assessment of each criteria, using the distance between the site and various factors to judge the extent to which it either achieves or opposes certain objectives. It has had no consideration for the positive contribution that the development of sites can make to the natural environment and local facilities.
2.47. The assumption made within the Sustainability Appraisal that sites will only negatively impact the Green Belt and other landscape and natural environment designations has contributed to the unjustified omission of sites from allocation as part of the Local Plan which has subsequently resulted in the plan being unsound.
3. Site Deliverability
3.1. The site represents a deliverable, sustainable and achievable site for residential development. There have been technical reports and associated documents completed which demonstrate this. The below section provides a summary of these documents.
Access & Connectivity
3.2. The site is considered to have good access and connectivity to the surrounding area. The vehicular and pedestrian access to the site is proposed to be from Bayley's Mead. The access arrangement was considered as satisfactory through the 2013 Draft Site Assessment.
3.3. The site is approximately 1.3 miles from Shenfield Station (approximately a 25 minute walk / 8 minute cycle). Shenfield Station provides frequent services to London Liverpool Street, Chelmsford, Colchester and Ipswich and settlements between. These destinations also provide connections to the wider national transport network. Shenfield Station is also the terminus for the new Elizabeth Line which is part of Crossrail. Crossrail provides frequent services into Central London.
3.4. A public bus stop is located approximately 200m from the site. This bus stop provides frequent services to Basildon Town Centre, Brentwood High Street, Billericay and Shenfield Rail Station, amongst services to smaller neighbouring settlements.
3.5. The site is well connected to the surrounding road network. The site is located approximately 2.5 miles from the A12. The A12 provides efficient access to settlements across Essex and East Anglia such as Chelmsford, Colchester and Ipswich, as well as a direct connection to the M25.
3.6. The site is immediately adjacent St Martin's School, a large seconday school and sixth form. There are also a number of primary schools in the area, including Willowbrook Primary School and Hutton All Saints Primary School which are both less than a mile from the site.
3.7. Given the high access and connectivity levels of the site, it is evident that Site 030A is within a sustainable location and should therefore be considered as a site for residential development.
Ecology
3.8. An ecological appraisal was undertaken by Green Environmental Consultants Ltd. In September 2013.
3.9. The ecological appraisal states that the site is abandoned farmland which is being colonised by scrub and tree species from woody boundary habitats. There are mature trees, mostly on two of the boundaries which may be used by bats of nesting birds. Otherwise the potential of the site is poor.
3.10. The ecological appraisal recommends further bat survey work to be undertaken on site and for the mature boundary trees to be protected and enhanced.
3.11. The ecological appraisal concludes that there are no significant or major impacts on a significant resource to be expected through the development of the site, but recognises that loss of scrub and some trees is likely to occur. This could be easily mitigated and enhanced through a landscaping scheme to support any future development on the site.
Geo-Environmental/Engineering
3.12. A preliminary engineering appraisal was undertaken in February 2013. This appraisal includes details on foundations, highways, drainage and contamination.
3.13. The geo-environmental appraisal concludes that there are no significant physical geo-environmental constraints to development on the site.
Drainage
3.14. The preliminary engineering appraisal states that foul water from the proposed development would discharge to the existing pumping facility and thereafter to the sewer in Hanging Hill Lane.
3.15. The appraisal states that storm run-off from the developed site would discharge at the ditch.
3.16. The existing surface water catchment for the local residential area drains into a 600mm diameter pipe which discharges via a headwall into the western end of the northernmost ditch within the site. This ditch runs across the site and continues eastwards beyond. The Environment Agency map indicates that an interconnecting ditch system eventually outfalls to the River Can. The appraisal states that drainage storage is likely to be provided through the design of a sustainable urban drainage system which may include a combination of contributing elements, swales, ponds and underground cellular storage.
Contamination
3.17. The preliminary engineering appraisal states that an intrusive soil investigation will be required to confirm whether the soil on site is contaminated. The appraisal states that in view of the perceived history of the land, this is unlikely to be the case.
Highways
3.18. The preliminary engineering appraisal states that the current width of Bayley's Mead is 5.5m which could support a development of 30 dwellings.
3.19. The appraisal states that the sight line visibility from Bayley's Mead onto Hanging Hill Lane is about 2.4m x 65m to the right hand side with the 'y' distance being much greater to the left. The requirement for a 30mph road is 2.4 x 43m. Even if measured vehicle speeds in Hanging Hill Lane are greater, for example up to 37mph, then the visibility requirement for that speed (2.4 x 59m) is still achieved.
3.20. The appraisal concludes that there is no objective reason as to why the existing access road could not support the development of Site 030A.
4. Summary
4.1. Whilst the current proposed allocations and strategic policies of the PSLP appropriately address the minimum requirement of housing recognised for the Plan period, we have reason to query the appropriate length of the Plan period, and a lack of flexibility in the housing provision and such consider the Plan unsound due to its inability to comply with national planning policy, the unjustified omission of a housing supply which exceeds minimum requirements, and given that the Plan has not been positively prepared to account for potential changes to the market and housing requirements beyond those forecast.
4.2. There is evidently a case for Site 030A to be further considered as a sustainable opportunity in respect of Brentwood Borough Council needing to further increase their housing delivery over the plan period. The development of this site would not impact the function of the Green Belt in this location and is immediately adjacent to Hutton, a 'main town' with facilities and services that could support sustainable growth. Development here would also accord with the Brentwood Borough Council Spatial Strategy which directs growth towards the A12 transport corridor.
4.3. The analysis and content within the accompanying studies evidence the deliverability, achievability and suitability of the site for development and why it should therefore be allocated by Brentwood Borough Council as a site for residential development to aid the Plan in being sound. We consider there to be outstanding opportunities for the plan to identify sustainable sites that are suitable for delivering housing over short timescales to ensure that the Plan is flexible and robust, and well-prepared to meet housing needs over the entirety of the plan period.
4.4. Development of the site is supported by a wealth of technical evidence that confirms its suitability, including in relation to the lack of harm to its development to the purposes of the Green Belt. The reasons given for the rejection of the Site are therefore based on a number of assumptions and simplistic conclusions.
4.5. The exclusion of Site 030A is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton. The allocation of Site 030A for development will assist in correcting shortfalls in respect of the Local Plan, enabling it to be a sound plan.
4.6. We note the requirements set out under Paragraph 139 which confirms that when defining Green Belt boundaries and where sites may not be allocated for development at the present time, plans should "identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period".
4.7. As a minimum therefore, land at Bayleys Mead should be safeguarded for future Green Belt release as and when a need may arise given its highly sustainable location and suitability to be developed without incurring encroachment between Hutton and the main Brentwood urban area.

The Plan's housing need should be amended to cover at 15 years from adoption. Realistically, we expect that an additional 2 years' worth of housing may be required to support a plan period up to 2035. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Allocating further sites for housing, like sites at Hanging Hill Lane, would provide for additional housing delivery.

1. Introduction
1.1 These representations are submitted by Strutt & Parker on behalf of Marden Homes Ltd in relation to the Brentwood Borough Council Consultation Draft Local Plan (Regulation 19), and in particular with regards to our client's land adjacent to 7 Hanging Hill Lane, Hutton, Brentwood (ref. 284). A plan showing the site is provided at Appendix 1 of this representation.
1.2 Representations have previously been made on behalf of Marden Homes Ltd and in respect of Site 284 land adjacent to 7 Hanging Hill Lane on the Brentwood Borough Council Preferred Site Allocation Consultation Document (Regulation 18) in March 2018.
1.3 Site 284 lies to the south of Hutton and is adjacent to existing development. It measures approximately 0.9ha and it is proposed that the majority of the site is suitable for development. The front of the site is made up of a number of derelict sheds and structures which are single storey in height, along with dense vegetation. The majority of the site comprises grassland. The site is situated within the Green Belt.
1.4 Site 284 has been discounted as a site for residential development through the Local Plan process, for reasons which are considered in further detail later within this representation. We consider the rejection of the site to be unjustified, and to result in a Pre-Submission Local Plan (PSLP) which does not promote sustainable development.
1.5 The allocation of the site at Hanging Hill Lane, Hutton, would represent a sustainable and deliverable proposal for residential development to help meet housing need over the coming plan period. This representation sets out comments on the Regulation 19 Draft Local Plan, as well as providing detail on the sustainability and deliverability of the site with regards to technical considerations and the latest assessment work.
2. Brentwood Local Plan Regulation 19 Consultation
Plan Period
2.1. The Draft Local Plan is proposed to guide development in the Brentwood Borough until 2033. The National Planning Policy Framework (NPPF, 2019) clearly states at Paragraph 22 that strategic policies within Local Plans should look ahead over a minimum of 15 years.
2.2. At this stage it would be optimistic to assume that the adoption of the Draft Plan which forms the subject of this representation will happen within 2019 and therefore the plan will only address development needs in the area for a maximum of 14 years.
2.3. This shortfall is particularly relevant in respect of Green Belt, whereby a failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of Green Belt being required. This review ahead of a new Local Plan would be contrary to the NPPF (paragraph 136), and also undermines one of the two essential characteristics of the Green Belt: its permanence (NPPF, Paragraph 133).
Total Housing Requirement
2.4. The required housing need figures as calculated through the Borough's SHMA, follows national guidance using the Standard Method (as per the NPPF and respective Planning Practice Guidance (PPG) 2018). Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 new homes per year.
2.5. However, the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).
2.6. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum.
2.7. The NPPF requires for Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.
2.8. As mentioned previously, the Plan should also ensure that the revised Green Belt boundary should be robust enough to be maintained beyond the Plan period and therefore account for development needs beyond 2033 (or a revised later end to the Plan period to ensure strategic policies will cover at least 15 years).
2.9. A further factor is the need to consider unmet needs of neighbouring authorities (NPPF paragraph 35). In respect of this, we note in particular that Epping Forest District Council is at an advanced stage in the preparation of a Local Plan (at the time of writing it is currently being examined) which proposes to deliver 11,400 dwellings between 011 and 2033 (518 dwellings per annum), against a requirement (based on the Standard Method) of 944 dwellings per annum. We are not aware of any objection to this approach from Brentwood Borough Council, but neither is there any indication that the PSLP addresses any of this unmet need.
2.10. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to be maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.
2.11. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement. We consider that the Plan in its current form is ineffective. It has not been positively prepared to provide for the appropriate level of contingency for housing delivery, nor does it comply with national planning policies in this regard. As such we consider the PSLP to be unsound.
2.12. We therefore consider that the housing need within the PSLP should be amended to at least ensure that an additional year's worth of housing can be accommodated for, and so that the relevant strategic policies of the Plan can cover 15 years from adoption. Realistically, we consider that the Council may actually need an additional 2 years worth of housing in order to support a plan which runs to 2035. Therefore one additional year should be regarded as the minimum.
2.13. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Allocating further sites for housing, like sites at Hanging Hill Lane, would provide additional housing delivery in a sustainable location, and would therefore help to ensure that the Draft Local Plan can be found sound.
Five-year Housing Land Supply and Housing Trajectory
2.14. Councils are required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).
2.15. At paragraph 73 of the NPPF it confirms that a 20% buffer should be applied to the initial calculation for a five year housing land supply requirement, in the event that the results of the Housing Delivery Test show for delivery to have fallen below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037- 20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.
2.16. The results of the 2018 Housing Delivery Test showed that Brentwood Borough Council delivered just 50% of its housing requirements over the last three years. This is well below the threshold of 20% as required by national guidance.
2.17. The Borough's most recent five-year housing land supply figure, as reported in their' Five Year Housing Land Supply Statement as at 31 March 2018' (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is considerably less.
2.18. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
2.19. The HLSS includes sites without detailed planning permission within their supply and without evidence such sites will be delivered within five years. As per the NPPF, such sites cannot be considered deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. These sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
2.20. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can deliver early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.
2.21. The housing trajectory provided at Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.
2.22. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.
2.23. Furthermore, Dunton Hills Garden Village is a proposed major strategic development that is intended to provide 4,000 dwellings, 5.5 hectares of employment land, two new primary schools, secondary school, new village shopping centre, new transport infrastructure and new community and health infrastructure. The delivery of Dunston Hills will be dependent on the coordination and input of multiple landowners, developers, infrastructure providers and other relevant stakeholders.
2.24. Once allocated, the PSLP proposed that a masterplan and design guidance will be required. Following this, an outline application will need to be prepared, submitted and determined; followed by reserved matters. It will also be necessary to discharge all planning conditions and S106 obligations.
2.25. We therefore question how likely the 100 homes at Dunton Hills will be completed by 2022/23. Of course, Dunton Hills can still form part of a sound Local Plan, however this does demonstrate that the reliance on large strategic sites for shorter term housing delivery is not appropriate. Additional smaller sites are capable of providing homes through the early years of a plan period and should be allocated through the PSLP to ensure the Local Plan is sound.
2.26. Whilst the plan can demonstrate housing delivery appropriate to meet minimum recognised requirements, it is evident that the suggested inability of the plan to ensure a consistent five-year supply is not consistent with national policy. National Policy requires that local planning authorities should identify and update a supply of specific deliverable sites sufficient to provide a minimum of five years' worth of housing against their housing requirement set out in the adopted strategic policies, on an annual basis.
The PSLP should support this requirement through the allocation of smaller scale sites that can be delivered over a shorter time period, in order to be found sound. Land at Hanging Hill Lane, could cater to this need. Its deliverability is discussed in greater detail in subsequent sections.
Proposed Approach to Hutton
2.27. Hutton is recognised as Category 1 - 'a main town' within the PLSP's settlement hierarchy. Hutton is the second largest settlement in the Borough, with an approximate population 15,578 (according to the 2011 Census). It has an established local centre which benefits, from a range of services, facilities, access to public transport, and employment opportunities.
2.28. Hutton is well-connected in respect of regional and national infrastructure, situated approximately 30km from Central London, 12km from Chelmsford, accessible from the A12 or national rail services.
2.29. Hutton is therefore a highly sustainable location, and makes it an ideal location to accommodate a proportion of Brentwood's housing need. The Local Plan should manage growth of such settlements to sustain and enhance their vitality.
2.30. The PSLP proposes no growth for Hutton, despite its identification as a Category 1 settlement. This is in direct contrast to the level of growth afforded to other settlements which are also identified as Category 1 or are below Hutton within the Borough's settlement hierarchy. We therefore have concerns that the PSLP is failing to support the sustainable growth of Hutton and this omission is unjustified and inconsistent with national policy.
2.31. Land at Hanging Hill Lane should be allocated in Hutton to ensure the sustainable growth of the settlement, and to ensure the soundness of the Local Plan.
Green Belt
2.32. A Green Belt Study (November 2018) supports the PSLP. This study provides an assessment of Green Belt parcels against the five purposes of the Green Belt, as set ut within the NPPF.
2.33. The study includes an 'assessment of Housing Sites (being considered as part of the SHLAA) within the Green Belt and their relative contribution to the purposes of the Green Belt designation'.
2.34. The site has been assessed against the five purposes of the Green Belt, as part of the Green Belt Study methodology as follows:
Purpose 1: To check the unrestricted sprawl of large built up areas
Parcel 14 is defined by the Council as 'partly contained', and recognises that it abuts a large built up area. This categorisation does however advise that the boundary is 'weak/degraded/unclear'. Site 284 abuts a large built-up area on two out of four boundaries, the remaining boundaries are bounded by established vegetation that could be incorporated and enhanced as part of a landscaping scheme. We consider that the site boundaries are clearly defined and the site is well contained. A conclusion of containment should not consider built form exclusively.
Purpose 2: To prevent neighbouring towns from merging into one another The site is adjacent to the eastern/south-eastern limit of Hutton Mount. The Green Belt Study correctly recognises that its development will retain separation between towns. The site sits at the eastern/south-eastern limit of Hutton mount, the nearest settlement to the east of the site is Billericay which is approximately 3 miles away. The green gap etween the two settlements is considerable. The rest of the settlement at Hutton Mount extends significantly further east than Site 284 in this regard and should be considered very low risk in terms of purpose 2, especially in the context of the other sites that have been assigned the 'Separation Retained' designation.
Purpose 3: To assist in safeguarding the countryside from encroachment Site 284 is defined within the Green Belt Study as being 'Functional Countryside'. The assessment defines Functional Countryside as 'High degree or important public access'. Access is defined as 'access land, public right of ways and important routes'. The site itself, is in private ownership and does not provide access to the public. It is not used for agricultural purposes and therefore should not be considered 'functional countryside'. We therefore consider this assessment to be incorrect.
Purpose 4: To preserve the setting and special character of historic towns Brentwood Borough Council have recognised that site 284 has no physical or visual relationship with the Historic Town. The site is located some distance from the Town Centre with no direct relationship. The site is directly associated with the contemporary developments of the surrounding roads, which have limited historic character.
Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land Brentwood Borough Council have not provided an analysis for Purpose 5.
2.35. Overall, Brentwood Borough Council have assessed the site as having a moderate overall contribution to the Green Belt, despite the favourable assessment of the site.
2.36. We have outlined above that where the site was assessed to have important role in the Green belt, that certain elements of the assessment are incorrect and are not a true reflection of the site's characteristics.
2.37. The development of this Green Belt site, which has limited environmental value and offers a minimal contribution to the Green Belt when assessed against its five intended purposes, would help to support housing delivery in a sustainable location in the Brentwood Borough, whilst protecting other Green Belt sites of much higher environmental value.
2.38. The weaknesses and inconsistencies recognised in the individual site assessments made, again demonstrate a flaw in the evidence base for the Local Plan and could again result in the unjustified omission of Green Belt sites from consideration for allocation as part of the new Local Plan.
2.39. The above analysis of Hanging Hill Lane, Hutton demonstrates that there remains small scale opportunities for sustainable development within the Green Belt and that the Local Plan should give consideration to the allocation of such sites alongside larger scale areas of release.
Strategic Environmental Assessment/Sustainability Appraisal (SEA/SA)
2.40. The PSLP is supported by a range of technical work, including the Sustainability Appraisal (SA) January 2019. The SA presents a number of sustainability issues/objectives which have been established through SA scoping. Together, these sustainability topics and objectives provide a methodological framework for the appraisal of potential allocation sites - including site 284.
2.41. The SA indicates that the allocation of Site 284 would have a positive effect in relation to one of the SA objectives. The SA analysis states that Site 284 is in good proximity to a secondary school (less than 1.5km), but in 'red' proximity from a GP surgery and a primary school. Willowbrook Primary School is located within 1.3 miles of the site, whilst Hogarth Primary School is also 1.5 miles from the site, both considered to be within walking distance from site. The nearest GP Surgery, Mount Avenue Surgery is located less than 1.5 miles away. Mount Avenue is defined in the Regulation 18 document to be 1 of 3 surgeries which has an average of 0.58 GPs per 1,000 patients, which is the national average. Furthermore, Mount Avenue Surgery has a large catchment area, therefore it is considered that it would provide service to those living at the site. Brentwood Community Hospital is also located less than 3 miles away.
2.42. The SA, through its analysis also states that the site at Hanging Hill Lane is an area that 'performs poorly' in respect of its proximity to an Ancient Woodland, SSSI, Local Wildlife Site, Listed Buildings and Agricultural Land. This scoring metric is considered to be highly assumptive and does not consider the potential opportunities for biological enhancement or mitigative measures of impact through landscape led schemes. The proximity of the site near these designations as referenced above, does not necessarily mean that there will be any direct impact to them from the development of the site.
2.43. In relation to Green Belt, the assessment is binary in its approach - if a potential site falls within the defined Green Belt, it will be given an 'Amber score'. The methodology notes that Green Belt is not a specific a landscape designation, as such the effects on the setting have not been appraised. Without appraising the effects on the setting, assigning a blanket 'amber' score to Green Belt sites, seem arbitrary.
2.44. As discussed above, a Green Belt Review of the Borough, and the contribution that each individual site makes to the Green Belt has been undertaken. This recognition that each individual site has differing values should have an influence on the scoring for the Green Belt element within the SA, rather than the binary approach taken.
2.45. In general, we consider that the SA Report is simplistic in its approach to individual site assessment. The SA has used a predominantly spatial or 'GIS' (use of Geographical Information Systems) approach to the assessment of each criteria, using the distance between the site and various factors to judge the extent to which it either achieves or opposes certain objectives. It has had no consideration for the positive contribution that the development of sites can make to the natural environment and local facilities.
2.46. The assumption made within the Sustainability Appraisal that sites will only negatively impact the Green Belt and other landscape and natural environment designations leading to the unjustified omission of sites from allocation, has resulted in the Local Plan being unsound.
3. Site Deliverability
3.1. Site 284 represents a deliverable, sustainable and achievable site for residential development. The below section provides overview of its deliverability and some of the technical reports that have been undertaken which help to demonstrate this.
Access & Connectivity
3.2. The site is considered to have a good access and connectivity to the surrounding area. The vehicular and pedestrian access to the site is proposed to be taken directly from Hanging Hill Lane, as existing.
3.3. The site is approximately 1.5 miles from Shenfield Station (less than a 30 minute walk). Shenfield Station provides frequent services to London Liverpool Street, Chelmsford, Colchester and Ipswich and settlements between. These destinations also provide connections to wider national transport network.
3.4. A public bus stop is located less than 13m from the site. This bus stop provides frequent services to Brentwood High Street, Basildon Town Centre, Billericay and Shenfield Rail Station, amongst other neighbouring settlements and the wider area.
3.5. The site is well-connected to the surrounding road network, and is approximately 2.5 miles from the A12. The A12 provides efficient access to settlements across Essex and East Anglia such as Chelmsford, Colchester and Ipswich, as well as direct connection to the M25.
3.6. Given the high access and connectivity levels of the site, it is evident that land at Hanging Hill Lane is within a sustainable location and should therefore be considered as one of a number of small sites around Hutton that would be suitable for accommodating growth that would be suitable for accommodating growth that would support the recognised housing needs of Brentwood.
Ecology
3.7. A full ecological appraisal of the site would be undertaken prior to any development. It is anticipated however that the development could easily mitigate potential impacts through retention of existing landscape features and replacement planting where appropriate, whilst also presenting an opportunity for enhancement of the ecological value of the site above the existing.
3.8. Any impacts could be easily mitigated and enhanced through a landscaping scheme to support any future development on the site.
Drainage
3.9. The site is adjacent to existing built development and it is anticipated that connections could therefore be made to the existing sewerage networks.
3.10. A sustainable urban strategy would form part of any design for the site to ensure the surface water run-off rates are maintained at the existing greenfield rates.
Contamination
3.11. The perceived history of the use of the site indicated that the site is unlikely to be contaminated.
Highways
3.12. There is an existing access to the site from Hanging Hill Lane which would be maintained and used to access any new development on the site. We understand that this access has good visibility splays and that it is therefore safe for continued use.
3.13. Any development on the site would be supported by a transport statement which consider the suitability of the local highway network to accommodate increased vehicular movements to and from the site.
3.14. It is however considered that sustainably located sites such as sites at Hanging Hill Lane will help provide new homes in locations where there is a minimal reliance on the use of the private car. There are direct footpath links to local convenience shops and schools in Hutton Mount, as well as further into the centre of Hutton. Other local services and facilities, including Shenfield station are also easily accessible by bike.
3.15. There have been no reasons recognised why existing highways and access arrangements should present a risk to the suitability and deliverability of the site.
Heritage
3.16. Grade II Listed Hare Hall is immediately to the south of the site. A Heritage Statement has been prepared by Architectural Management to assess the significance of this asset in respect of the potential residential development of the site, and accompanies this representation.
3.17. The assessment recognises that Hare Hall has been altered significantly over time and that the current building does not carry the level of significance which the original Hare Hall may have done.
3.18. In considering the setting of the listed building, the report also recognises that historically the Hall enjoyed an open outlook to the east and south and that the existing buildings on the site (subject of this rep), and its established vegetation means that the north of the site of has always been more enclosed with a limited outlook.
3.19. The report includes some specific recommendations towards site layout and design that will ensure that the development of this site will have no detrimental impact on the setting of Hare Hall.
4. Summary
4.1. Whilst the current proposed allocations and strategic polices of the PSLP appropriately address the minimum requirement of housing recognised for the Plan period, we query the length of the Plan period, and a lack of flexibility in the housing provision. As such we consider the Plan to be unsound due to its inability to comply with national policy, the unjustified omission of a housing supply which exceeds minimum requirements, and failure to positively prepare for potential changes to markets and housing requirements beyond these forecasts.
4.2. There is clearly a case for Site 284 to be further considered as a sustainable opportunity in respect of Brentwood Borough Council needing to further increase their housing delivery over the plan period. The development of the site would not impact the function of the Green belt in this location as it is immediately adjacent to Hutton, a 'main town' with the facilities and services that could support sustainable growth in Brentwood Borough. Development here would also accord with the Brentwood Borough Council Spatial Strategy which directs growth towards the A12 transport
corridor.
4.3. The accompanying studies evidence the deliverability, achievability and suitability of the site. It is anticipated that any impact on historical sites and settings, landscapes, ecology and ecological designations could be mitigated through appropriate measures. We therefore consider that the site should be allocated by Brentwood Borough Council as a site for residential development. There is an opportunity to identify sustainable sites that are suitable for delivering housing over short term timescales, and to ensure that the Plan is flexible and robust, and well prepared to meeting housing needs over the entirety of the Plan period.
4.4. Development of the site is supported by technical evidence that confirms its suitability, including in relation to the lack of harm the development would have to the purposes of the Green Belt. The reasons given for the rejection of the Site are therefore based on a number of assumptions and simplistic conclusions.
4.5. The exclusion of Site 284 is unjustified, and overlooks an opportunity to correct soundness deficiencies in respect of the Local plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth at Hutton. The allocation of Site 284 for development will assist in resolving these deficiencies in respect of the Local Plan, enabling it to be found sound.

We suggest a plan period to 2035 should be treated as a minimum, and an additional two years' worth of development needs to that which the PSLP currently seeks to address should be planned for.

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