Reflect government guidance - amend this paragraph to reflect that "states that substantial weight should be given to the value of using suitable brownfield land".

Brentwood Local Plan
Pre-Submission Document

CONTENTS
1 Introduction 2
1.1 Introduction 2
1.2 Context 2
2 National Planning Policy 3
2.1 National Planning Policy Framework 3
2.2 Planning Practice Guidance 4
3 Legal Requirements 7
3.1 Duty to Cooperate 7
3.2 Sustainability Appraisal 8
4 Spatial Strategy 9
4.1 Vision and Strategic Objectives 9
5 Managing Growth 10
5.1 Policy SP02: Managing Growth 10
5.2 Policy SP04: Developer Contributions 11
6 Resilient Built Environment 12
6.1 Policy BE02: Sustainable Construction and Resource Efficiency 12
7 Housing Provision 13
7.1 Policy HP01: Housing Mix 13
7.2 Policy HP06: Standards for New Housing 13
8 Conclusion 15
8.1 Overall Conclusion 15

1 INTRODUCTION
1.1 Introduction
1.1.1 These representations are submitted by Gladman in response to the current consultation on the Brentwood Local Plan Pre-Submission Document. Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure.
1.1.2 Gladman has considerable experience in the development industry across a number of sectors, including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that are needed to ensure that residents have access to a decent home and employment opportunities.
1.1.3 Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many Local Plan public examinations. It is on the basis of that experience that the comments are made in this representation.
1.1.4 Through this submission, Gladman have sought to highlight a number of issues with the Brentwood Local Plan. Gladman submit that the Council will need to carefully consider some of its policy choices and ensure that its evidence base is up-to-date and robust in light of changing circumstances and the changes brought about by the Revised National Planning Policy Framework (2019).
1.2 Context
1.2.1 The Revised Framework (2019) sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order for it to be sound it is fundamental that the Thurrock Local Plan is:
* Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
* Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
* Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
* Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in the Framework.

2 NATIONAL PLANNING POLICY
2.1 National Planning Policy Framework
2.1.1 On 24th July 2018, the Ministry of Housing, Communities and Local Government (MHCLG) published the Revised National Planning Policy Framework which was subsequently updated in February 2019. These publications form the first revisions of the Framework since 2012 and implement changes that have been informed through the Housing White Paper, The Planning for the Right Homes in the Right Places consultation and the draft Revised Framework consultation.
2.1.2 The Revised Framework (2019) introduces a number of major changes to national policy and provides further clarification to national planning policy as well as new measures on a range of matters. Crucially, the changes to national policy reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for to address the housing, economic, social and environmental priorities to help shape future local communities for future generations. In particular, paragraph 16 of the Revised Framework (2019) states that Plans should:
a) Be prepared with the objective of contributing to the achievement of sustainable development;
b) Be prepared positively, in a way that is aspirational but deliverable;
c) Be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
e) Be accessible through the use of digital tools to assist public involvement and policy presentation; and
f) Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).
2.1.3 To support the Government's continued objective of significantly boosting the supply of homes, it is important that the Local Plan provides a sufficient amount and variety of land that can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay .
2.1.4 In determining the minimum number of homes needed, strategic plans should be based upon a local housing need assessment, conducted using the standard method as set out in the PPG unless exceptional circumstances justify an alternative approach. It is imperative that the emerging Local Plan is formulated on the basis of meeting this requirement as a minimum.
2.1.5 Once the minimum number of homes that is required is identified, the planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 67 sets out specific guidance that local planning authorities should take into account when identifying and meeting their housing need. It states:
"Strategic policy-making authorities should have a clear understanding of the land available in their areas through the preparation of a strategic housing land availability assessment. From this planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Strategic plans should identify a supply of:
a) specific, deliverable sites for years one to five of the plan , and
b) specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan.
2.1.6 Once a local planning authority has identified its housing needs, these needs should be met in full, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so . Local planning authorities should seek to achieve each of the economic, social and environmental dimensions of sustainable development, resulting in net gains across all three. Adverse impacts on any of these dimensions should be avoided, where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed or, where this is not possible, compensatory measures should be considered.
2.1.7 To be considered sound at Examination the emerging Local Plan will need to meet all four of the soundness tests set out in paragraph 35 of the Revised Framework (2019).
2.2 Planning Practice Guidance
2.2.1 The Government published updates to its Planning Practice Guidance (PPG) on 13th September 2018. The updated PPG provides further clarity on how specific elements of the Revised Framework should be interpreted when preparing Local Plans. In particular, the updated Housing Needs Assessment chapter of the PPG confirms that the Revised Framework expects local planning authorities to follow the standard method for assessing local housing needs, and that the standard method identifies the minimum housing need figure and not a final housing requirement .
2.2.2 The calculation of objectively assessed needs (OAN) for housing has been a subject of much debate as part of Local Plan Examinations and s.78 appeals since its initial introduction through the Framework in 2012 with interested parties grappling with the issue of OAN with varying outcomes depending on local circumstances. To simplify the assessment the Government, through the Revised Framework has introduced the standardised method which should be undertaken through the 3-stage process outlined at paragraph 005 of the PPG .
2.2.3 Notwithstanding the above, it is important to note that whilst the standard methodology to assessing housing needs has been introduced, it is likely that this will be subject to further change. In this regard, it is currently anticipated that the standard method will be adjusted to ensure that the starting point in the plan-making process is consistent with the Government's proposals in Planning for the Right Homes in the Right Places consultation, to ensure that 300,000 homes are built per annum by the mid-2020s. This follows the release of the 2016 based household projections in September 2018, which forecast a lower level of household growth than previously envisaged.
2.2.4 It is therefore important that future iterations of the Local Plan take account of any changes to the standard method for calculating housing needs during the course of their preparation.
2.2.5 Whilst the PPG advises that the standard method is not mandatory, there is a possibility that other methods can be used in exceptional circumstances based on robust evidence in order to deviate from the standard method. Indeed, the PPG is clear that the standard method only identifies the minimum number of homes required to meet population needs and does not take into account the variety of factors which may influence the housing required in local areas such as changing economic circumstances or other factors which may change demographic behaviour. Where additional growth above historic trends are likely to occur, then local planning authorities should include an appropriate uplift to the housing numbers to meet the need in full. It is important that this uplift is undertaken prior to and separate from the consideration of the demographic baseline assessment of need and how much of this need can be accommodated in a housing requirement figure. Circumstances where the need to apply an uplift may be appropriate include, but are not limited to:
- Where growth strategies are in place, particularly where those growth strategies identify that additional housing above historic trends is needed to support growth or funding is in place to promote and facilitate growth (e.g. housing deals);
- Where strategic infrastructure improvements are planned that would support new homes;
- Where an authority has agreed to take on unmet need, calculated using the standard method from neighbouring authorities, as set out in a statement of common ground;
- Historic delivery levels where previous delivery has exceeded the minimum need identified it should be considered whether the level of delivery is indicative of greater housing need; and
- Where recent assessments such as Strategic Housing Market Assessments suggest higher levels of need than those proposed by a strategic policy making authority, an assessment of lower need should be justified.
2.2.6 In addition, it is important for local planning authorities to consider the implications of the standard method on delivering affordable housing need in full. The PPG is clear that the total affordable housing need should be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the probable percentage of affordable housing to be delivered by open market housing development. If it becomes clear that affordable housing need will not be delivered in full, then an increase to the total housing figures included in the plan should be considered where it could help to deliver the required number of the affordable homes.
2.2.7 In the event that an alternative approach is used it should only be considered sound if it exceeds the minimum starting point. The PPG is clear that any alternative approach with results in lower housing need figure than the standard method should be considered unsound as it does not meet the minimum housing need required.  
3 LEGAL REQUIREMENTS
3.1 Duty to Cooperate
3.1.1 The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration.
3.1.2 The Revised Framework (2019) has introduced a number of significant changes for how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SOCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. The Revised Framework (2019) sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SOCG), throughout the plan making process . The SOCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with e.g. unmet housing needs.
3.1.3 As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans examinations, if a Council fails to satisfactorily discharge its DtC a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications.
3.1.4 Gladman welcome the South Essex Authorities' commitment to the preparation of a Joint Strategic Plan (JSP) covering Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea and Thurrock. All of these authorities have significant strategic issues to contend with not least, the delivery of substantial housing and economic growth and the need to review Green Belt boundaries at a strategic scale.
3.1.5 It is however disappointing, that the JSP will not allocate specific sites which will be left for the individual Local Plans to take forward. The level of housing need in South Essex is significant and delivery has fallen substantially behind need for a long period of time. There is therefore an immediate need to address this situation; and for Local Plans to have to await the adoption of the JSP before sites are taken through the Local Plan process and finally released from the Green Belt, is simply going to result in inevitable further delay.
3.1.6 The JSP could release the strategic sites for development in partnership with the constituent authorities leaving a certain proportion of housing need to be addressed by the Local Plans on non-strategic sites. This would allow the release of Green Belt for development as early in the process as possible, thus meeting urgent need in an expedient manner.
3.1.7 The JSP also needs to follow a statutory plan preparation process with requisite consultation and examination to ensure that it has full weight in the planning process and to guide the preparation of the Local Plans on a formal basis. If the JSP is simply a non-statutory document, then there is the potential for changes over time in the other authorities to cause significant issues.
3.1.8 Beyond this commitment, there is very little evidence available setting out how Brentwood has discharged its Duty to Cooperate and what outcomes have been achieved through this process. This is especially pertinent because of the need to address unmet housing needs across the HMA.
3.2 Sustainability Appraisal
3.2.1 In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA), and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
3.2.2 The SA/SEA is a systematic process that should be undertaken at each stage of the Plan's preparation, assessing the effects of the emerging Local Plan Review proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed, and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council's decision-making and scoring should be robust, justified and transparent.
 
4 SPATIAL STRATEGY
4.1 Vision and Strategic Objectives
4.1.1 Gladman has concerns with certain elements of the Spatial Strategy that is being pursued through the Brentwood Local Plan (BLP).
4.1.2 The Plan sets out that one of the overarching driving factors behind the BLP is meeting the housing needs of the borough. However, the Council are using the 2016 Household Projections to calculate the housing needs of the borough which the Government have now confirmed is the incorrect data set to rely upon. Use of the 2014 Household Projections is likely to yield a higher housing requirement and therefore, the Council will need to address this issue before the Plan gets to Examination.
4.1.3 They also set out within the Settlement Hierarchy in Table 2.3 that the development of brownfield land will be prioritised. This requirement has no support in National Policy as Para 117 of the Revised Framework (2019) simply states that substantial weight should be given to the value of using suitable brownfield land. This requirement should therefore be changed to reflect Government guidance.
4.1.4 The prioritisation of brownfield land is also repeated in the Spatial Development Principles section under Paragraph 3.23 which similarly needs amending.
4.1.5 It is also disappointing that in the Vision and the Strategic Objectives, no mention is made of providing housing to meet the needs of the local population or of addressing one of the key challenges facing Brentwood, that of tackling housing affordability. It is therefore suggested that given the emphasis being placed by the Government on fixing the broken housing market, a further Strategic Objective is added to the Plan that specifically relates to the delivery of housing.
 
5 MANAGING GROWTH
5.1 Policy SP02: Managing Growth
5.1.1 The Council sets out in the pre-amble to Policy SP02 that they consider the housing need figure using the Standard Methodology is 350 dwellings per annum using the 2016 Household Projections published by ONS.
5.1.2 However, since the Local Plan was published, the Government has clearly set out that the 2016 Household Projections should not be used for the purposes of establishing the housing need figure under the standard methodology and that the 2014 Household Projections should be used instead.
5.1.3 The Council therefore needs to recalculate the housing need figure using the correct set of data so that it accords with the Framework and is not immediately found unsound on this basis.
5.1.4 It must also be recognised that the standard method only identifies the minimum number of homes required to meet population needs and does not take into account the variety of factors which may influence the housing required in a local area such as changing economic circumstances or other factors which may change demographic behaviour. Where additional growth above historic trends is likely to occur, then local planning authorities should include an appropriate uplift to the housing numbers to meet the need in full. It is important that this uplift is undertaken prior to and separate from, the consideration of how much of this need can be accommodated in the housing requirement.
5.1.5 The Council are seeking to provide an uplift to the base level of housing needs established through the Standard Method but this is intended to provide a buffer in the housing supply to ensure that the housing requirement is met or surpassed. It is not an uplift to take account of the circumstances listed in the PPG (see paragraph 3.1.5 above).
5.1.6 Gladman support the Council's inclusion of a 20% buffer in order to provide flexibility in supply as this will allow the Local Plan to adapt to changes in circumstances such as stalled sites, delay in delivery and sites which do not come forward as envisaged. This is especially important where Local Plans are predicated on the delivery of a small number of large-scale strategic sites.
5.1.7 However, we also consider that the housing requirement included within the Local Plan is not representative of the full housing needs of the area and that factors such as the high housing affordability ratio (11.23 in 2017), continuing economic growth and proximity to London should lead the Council to uplift the housing requirement figure above the minimum identified through the Standard Method. The Council would then still need to include a 20% buffer above this figure, in order to provide the flexibility needed to ensure the housing requirement is met or surpassed.
5.1.8 Gladman also has concerns regarding the Sequential Land Use approach which is set out in Paragraph 4.22 of the Local Plan. This is intended to be used as a Development Management tool to appraise proposals against a sequential land use hierarchy. However, we consider that this goes beyond the guidance set out in National Policy which seeks to maximise the use of brownfield land where possible and where it does not conflict with other policies in the Framework. It is also difficult to see how this approach would work in a Development Management context as applicants would have to demonstrate that there are no other suitable alternative sites which could accommodate the proposed development.
5.1.9 Policy SP02 also sets out a stepped approach to housing delivery within Brentwood which would equate to 310 dwellings per annum 2016-2023 and 584 dwellings per annum from 2023 onwards. Given that Brentwood has struggled to deliver homes over recent years and has in fact, failed to meet the requirements of the recently published Housing Delivery Test, resulting in the need for a 20% buffer to be applied, coupled with the fact that housing affordability in the borough is severe, must lead the Council to the conclusion that it has to address the backlog of housing needs as quickly as possible.
5.1.10 Implementing a stepped approach to the housing requirement will only lead to people having to wait longer for their housing needs to be met which, in the face of the Government's push to address the housing crisis, must be unacceptable.
5.1.11 The Council point to the fact that given the level of Green Belt constraint facing the borough, it is extremely difficult to achieve a five-year housing land supply. However, if the Council allocate a sufficient range and type of site in various locations across the borough, including small scale Green Belt releases, then there is no reason why housing needs cannot be met quicker thus maintaining a 5-year housing land supply.
5.1.12 Gladman do not consider that the Council has sufficient evidence to justify the implementation of a stepped approach to housing delivery and therefore consider the Local Plan to be unsound in this respect.
5.2 Policy SP04: Developer Contributions
5.2.1 Whilst Gladman has no specific comments on the content of Policy SP04, we would wish to voice concern over the myriad of policies contained in the Local Plan which may have implications for development viability. Many of the policies such as Policy SP05, BE01, BE02, BE03, BE09, BE10 etc have requirements within them that will impact on the viability of development schemes. It is unclear from the evidence provided whether the cumulative impact of all of these requirements has been considered through the Viability Study, which is a requirement set out at Paragraph 34 of the Framework to ensure that such policies do not undermine the deliverability of the Plan. This gap in evidence needs to be addressed by the Council to ensure that these policies are justified.
 
6 RESILIENT BUILT ENVIRONMENT
6.1 Policy BE02: Sustainable Construction and Resource Efficiency
6.1.1 Gladman are concerned with part (f) of Policy BE02 as it is too onerous and goes beyond National Policy. Part (f) requires all proposals to include commercial and domestic scale renewable energy and decentralised energy as part of new development. This is an extremely onerous requirement, particularly for small schemes where it may not be technically feasible. It could also have a huge impact on development viability.
6.1.2 Paragraph 153 of the Framework allows for planning policies to require development to include decentralised energy supply. However, it also provides a caveat that this is only where it is viable and feasible. Part (f) of Policy BE02 should therefore be amended to reflect this guidance.
 
7 HOUSING PROVISION
7.1 Policy HP01: Housing Mix
7.1.1 Policy HP01 contains a number of development requirements which would be applied to all new development including housing mix, accessible and adaptable dwellings and self and custom build homes.
7.1.2 If the Council wishes to adopt the discretionary accessible and adaptable homes standards as a policy requirement, then this should only be done in accordance with the Revised Framework footnote 46 i.e. where this would address an identified need for such properties and where the standards can be justified. The Written Ministerial Statement (WMS) dated 25th March 2015 stated that "the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG".
7.1.3 All new homes are built to Building Regulations Part M Category 1 Standards which include such adaptions as level approach routes, accessible front doors and wider internal doors and corridors. If the Government had intended that evidence of an aging population alone justified the adoption of the higher Part M Category 2 or 3 optional standard, then these would have been incorporated as mandatory into the Building Regulations.
7.1.4 We have been unable to locate where the evidence of a need for these standards is contained within the evidence base. Without this evidence, these requirements should be removed from the Local Plan.
7.1.5 Whilst the concept of Self Build and Custom Build Housing is supported, the inclusion of plots on large scale sites does not add to the supply of houses overall (it merely changes the housing mix from one product to another). It is also difficult to assess how it will be implemented given issues around working hours, site access, health and safety etc. that are associated with large scale development sites. The percentage of provision on sites should also be determined on detailed evidence of need and the provision of these plots should also be subject to viability testing.
7.2 Policy HP06: Standards for New Housing
7.2.1 Policy HP06 requires all residential development to have to comply with the Nationally Described Space Standards (NDDS).
7.2.2 If the Council wishes to adopt the NDSS as a policy requirement, then this should only be done in accordance with the Revised Framework footnote 46 i.e. where this would address an identified need for such properties and where the standards can be justified. The WMS dated 25th March 2015 stated that "the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG".
7.2.3 We have been unable to locate where the evidence of a need for these standards is contained within the evidence base. Without this evidence, these requirements should be removed from the Local Plan.

 
8 CONCLUSION
8.1 Overall Conclusion
8.1.1 Critical to the success of the South Essex area will be the timely production of the JSP which will define the major growth areas to meet the housing and employment needs across the area and will inform the preparation of the individual Local Plans.
8.1.2 It is essential that through this process, the full needs for housing and employment are met in the areas that people want to live. It is also imperative that the major policy constraint of Green Belt is reviewed in a strategic manner which allows full need to be met and ensures that the new boundaries endure beyond the JSP plan period.
8.1.3 The impact of London will have a heavy influence on the future developments needs of the area and this must also be taken fully into account through the preparation of the JSP.
8.1.4 It is also considered that in order to give the JSP the weight it needs to ensure that the constituent Local Plans deliver its outcomes, the JSP should be a statutory plan which follows the requisite plan preparation process of consultation and subsequent examination.
8.1.5 Gladman have some fundamental concerns with the BLP, particularly with the identification of the level of housing need in the Plan and the implementation of a stepped approach to housing delivery, which would render the BLP unsound if they are not addressed.
8.1.6 Gladman therefore request the right to participate in any forthcoming Local Plan Examination to discuss these concerns orally.

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its ownership and commercial interests at Eagle Way, Warley, Brentwood (the 'Site') within the administrative area of Brentwood Borough Council ('BBC'). Accordingly, Iceni has been instructed by Ford to prepare and submit written representations to the BBC New Local Plan, Pre-submission Draft consultation (2019) (referred to herein as 'PSD'). On behalf of our Client, we welcome the opportunity to comment on PSD which was published for consultation on the 5th February 2019. This is the final stage of consultation on the new Local Plan, following which the plan will be submitted to the Planning Inspectorate for independent examination. We therefore note that this stage of consultation is inviting comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2018) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy. The PSD consultation follows two previous consultations on the Local Plan, including the Call for Sites in 2016 and Preferred Site Allocations ('PSA') consultation in 2018. As BBC Officers will be aware, Ford have continued to actively engage in the preparation of the local plan with BBC - having submitted representations to all previous stages of consultation; supporting the allocation of the Site for housing. In this regard, Ford's previous representations have demonstrated that the Site represents a highly suitable and available Site for such development early in the plan period (particularly given the recent announcement regarding a change in operational requirements moving forwards) which should be prioritised given its brownfield nature. Within the PSD consultation version of the new Local Plan, our Client is supportive of the principle of the Site's allocation for residential development under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness in the NPPF (2018) - which the PSD consultation is indeed specifically seeking comments on, our Client wishes to object to the designation of 2 hectares ('ha') of employment land on the southern portion of the Ford Site (RO4) as specifically referenced under Draft Figure 7.6 and Draft Policy PCO3 in addition to the provision of specialist accommodation and self-build housing - in the absence of sufficient, supporting evidence to justify this. At this stage, our Client therefore considers the emerging Local Plan to be unsound and unjustified in the absence of a robust strategy, which should be based on proportionate evidence contrary to the NPPF Paragraph 35 and the overarching objective of enabling the delivery of sustainable development. Our Client also wishes to raise comments on other aspects of the PSD and Draft policies (as detailed in Section 3 of this representation submission); respectfully requesting that this is reviewed by BBC ahead of its submission to the Planning Inspector for examination. We would also welcome
discussing this submission in further detail with officers at the earliest possible convenience. In accordance with the requirements of the PSD consultation, and in order to inform this submission, the following documents have been submitted on behalf of our Client: * BBC completed Consultation Form; and * Written representations statement (this report which should be read in tandem with the above). This representation is submitted in line with the consultation deadline of 19th March 2019. The Site Location and Surroundings: The Site comprises 8.51 hectares (21.03 acres) of land located within Warley, forming the southern
edge of the Brentwood settlement boundary. This is a primary location for housing growth within both the adopted and PSD version of the emerging Local Plan - recognising its urbanised location within an existing settlement boundary. The Site is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway. The Site was originally developed for military purposes before being occupied by Ford as their European headquarters in the 1950s. Whilst the head office function has since been relocated to Cologne, Germany, the Site has remained in use by Ford as a central office for its UK services. However, Ford have recently announced that the Site will not continue to have an operational function as offices for the company moving forwards (due to a change in operational requirements). As such, it now represents a pivotal strategic opportunity within the PSD as a highly deliverable and available Site for new housing. Eagle Way runs east-west through the Site, dividing it into two parcels of land, as outlined below: * 'The northern parcel' - 1.37 hectares (3.39 acres) of land to the north of Eagle Way, currently utilised for staff car parking. A bus station is located on The Drive which runs along the western boundary, with Eagle Way running along the southern boundary of the northern parcel. To the north there is BBC owned land which is currently being utilised as additional car parking by Ford (on a lease agreement), as well as the highways depot and auto garage known as 'Council Depot.' 'The southern parcel' - 7.14 hectares (17.64 acres) of land to the south of Eagle Way where the main office building is located. The 6-7 storey office building has a NIA of 43,664 sq.m (470,000 sq.ft.), together with an ancillary data centre building, car parking and landscaping. Notably, the southern parcel includes an area of Green Belt Land along the eastern edge (comprising the Warley Gap) which is not proposed for any development within the PSD. The southern parcel is bounded by woodland, Clive Road to the west, Eagle Way to the north and woodland to the east. The area surrounding Site is predominantly characterised by residential uses, in addition to Marillac nursing home (to the east) and a local centre comprising retail and commercial uses to the west. Existing Planning Policy - Designations: In terms of adopted planning policy, the Site is currently subject to employment land use designations as defined by the BBC Replacement Local Plan (2005). Land to the north of Eagle Way is designated for 'general employment', and the land to the south of Eagle Way is designated as 'office'. A small portion of the southern parcel of the Site also falls within the Green Belt, along its eastern edge - which is not proposed for any form of development within the emerging PSD. In terms of heritage, there are Grade II listed buildings located outside of the site to the west including: The Royal Essex Regiment and Royal Anglian Regiment Headquarters building and Chapel. Site Ownership: Ford is the freehold owner of the Site. Ford also occupy an additional area to the north, which is currently owned by BBC and leased to Ford as car parking (comprising part of Draft allocation RO5 within the PSD). A plan highlighting the ownership boundary is included at Appendix A1. Formal Response to PSD Consultation: The following provides a formal consultation response on behalf of our Client to the PSD consultation. Specifically, this representation relates to the 'soundness' of the PSD - commenting on individual Draft policies within the consultation document on this basis (in accordance with the PSD Consultation Form Section B). Draft Policy R04 and R05: Ford Headquarters and Council Depot: Ford notes that the current PSD includes the Warley Site as a 'Strategic Housing Allocation' with the Council Depot, Warley under Draft policy allocation RO4 and RO5 - Ford Headquarters and Council Depot, which are collectively allocated for residential development for around 473 new homes anticipated to be delivered between 2024/25 and 2032/33 (within years 9-17 of the plan period). Notably, the Draft allocation also states that 'development proposals should consider the following': * The provision of a 60-bed residential care home as part of the overall allocation; * Provision for 5% self-build and custom build across the entire allocation; and * Provision of 2ha of land for employment purposes (specifically allocated on land south of Eagle Way with reference to Figure 7.2). Supporting Appendix 2 (Site Allocations) provides two separate plans for allocation RO4 ('land south of Eagle Way'; comprising the main Ford office building) and RO5 ('land north of Eagle Way; comprising the additional car parking area for Ford and the Council Depot) setting out that the sites have a collective site area of 9.4ha - of which 8ha is considered developable: * RO4 (south of Eagle Way) - 5.34ha of which 4.5ha developable. * RO5 (north of Eagle Way) - 4.06ha of which 3.5ha developable. Ford wishes to voice support in principle for the Draft allocation in the PSD for future residential development - including up to 350 new dwellings on the Ford owned land (as per our Clients previous representations to the PSA consultation and as demonstrated as deliverable within the 'Garden in the Woods' conceptual masterplan; as prepared by Iceni Design). This is highlighted with specific regards to the Site's situation within the Brentwood / Urban Area settlement boundary; comprising of previously developed brownfield land whereby the NPPF (2018) and PSD (2019) acknowledges that housing growth should be directed as a matter of priority in promoting sustainable development (providing a sound policy basis under the test of soundness within the NPPF). The need for BBC to identify additional land for housing is also required in order to address cross-boundary pressures such as London's future housing growth, which has been exemplified within relevant London Plan EiP hearing sessions. In this context, the Mayor of London has confirmed that local planning authorities within the wider south east, where the housing market is influenced by that of London should be working collaboratively with the GLA to significantly boost the supply of housing and ensure that Local Plans meet full objectively assessed needs. The arrival of Crossrail at Brentwood and Shenfield further exemplifies this requirement. This will undoubtedly bring even greater connections to central London, inevitably resulting in an increase in people living in the local area. This places further pressure on land for residential development, with the Site at Warley providing a key brownfield opportunity for much needed new housing. However, and as per our Clients previous formal response to the PSA consultation in May 2017, Ford request that the Draft allocation is revised to reflect the Ford owned land being available and deliverable earlier in the plan period - notably, 1-5 years versus the 9-17 years currently referenced within the PSD under the collective allocation with the Council Depot. This will help to deliver a significant degree of Brentwood's housing requirement in the short term (in line with the key objective of the NPPF with regards to boosting the supply of housing without delay). In this regard, it is assumed that the collective allocation has been put forward later in BBC's housing trajectory - to reflect the timescales anticipated for the Council owned Depot to be relocated. On this basis, our Client contends that the Ford owned land should be treated separately, with the Draft allocation revised to reflect the earlier timescales for housing delivery (which has indeed been evidenced to BBC through Ford's original Call for Sites submission in addition to ongoing, open dialogue with officers following Ford's announcement regarding the rationalisation of the business and subsequent vacation of the Site later this year). In this context, we wish to emphasise that the Ford Warley Site is a highly deliverable and available site for housing development, with realistic prospects that this will be delivered within the early phases of the plan period. Conversely, the Depot site is currently unavailable with an existing occupier, whereby we understand that BBC as the landowner have made no decisions regarding the site in terms of alternative provision. The approach to separating the sites within the Plan, will ensure that the early delivery of the Ford land for much needed housing is not unduly jeopardised (in accordance with the HELAA 2018, which indicated that new housing in the Borough would be brought forward on brownfield sites within the early years of the Plan). Please also see detailed comments made to Draft Policy SP02. Ford also wishes to object to the retention of 2ha of employment floorspace specifically at the land south of Eagle Way (i.e. the main Ford site; as referenced in Draft Figure 7.2 and Appendix 2) - in the absence of robust evidence to justify this, in tandem with acknowledging that the Site is no longer suitable for such uses (with the Ford site arguably being bespoke and an anomaly within the Borough; whereby the site's location would not be an attractive location for modern commercial investment). It is also apparent that BBC actually have a surplus of employment supply over the plan period, including at other more suitable sites across the Borough, whereby there is no logical or sound reasoning for the retention of 2ha of employment floorspace at the main Ford site (please also see comments made under Draft Policy PC03 'Employment Allocations' for full details / response on this matter). In a similar context, Ford also wishes to challenge the inclusion of a 60-bed care home and 5% custom build housing across the wider RO4 and RO5 Draft allocation - in the absence of any sound justification for this (contrary to the NPPF with regards to the requirement for planning policies to be underpinned by proportionate evidence) (please also see comments made under Draft Policy HP01 'Housing Mix' and HP04 'Specialist Accommodation' for full details / response on this matter). Whilst Ford welcomes the update to the PSD with regards to the correct site areas for Draft allocations RO4 and RO5 (under Appendix 2), as per our Client's comments to the PSA consultation (enclosed at Appendix A3 for reference), Ford wish to highlight that it is not possible to feasibility accommodate the amount of development currently included across the collective allocation - in the form which the market demands, whereby the provision of a care home and 2ha of employment floorspace significantly reduces the net developable area and ability to deliver up to 350 news homes on the Ford owned land (taking account of open space and infrastructure requirements; as demonstrated within the Garden in the Woods Conceptual Masterplan). This would result in a potential dwelling density that is wholly inappropriate for this type of location and would not respond at all well to the market demand for a housing-led development. As such, and for the reasons specifically raised under Draft Policy PCO3 and HP04 Ford wishes to object to the inclusion of these additional land uses in the interests of ensuring that the Site can be maximised for much needed housing development. To insist on retaining these alternative uses would significantly impact upon the ability and rate at which new housing could be delivered on this site, which would work against other objectives and policies in the Plan which are seeking early years delivery of housing on PDL. Draft Policy SP01: Sustainable Development: Ford wishes to voice support for the stated positive approach to the presumption in favour of sustainable development under Draft Policy SP01, in line with the NPPF (2018). In this regard, it is noted that the purpose of the planning system is to act positively to contribute to the achievement of this overarching objective. Draft Policy SP01 also provides a commitment from BBC to always work 'proactively with applicants to find solutions which mean that proposals for sustainable development can be approved wherever appropriate, and to secure development that improves the economic, social and environmental conditions in the area.' Again, this is welcomed by our Client and is considered a sound approach to plan and decision making (in accordance with NPPF Paragraph 12) which we would strongly urge BBC to ensure is underpinned by all other aspects of the new Local Plan in order for it to be sound. Spatial Development Strategy - Draft Paragraph 3.23: Ford wishes to voice support for the spatial strategy set out within the PSD, under Draft Paragraph 3.23, which seeks to prioritise brownfield sites wherever suitable, making efficient use of land in urban areas. In this regard, Ford wishes to highlight the suitability of the land at Eagle Way for residential development in supporting this endeavour - which is located within the established urban neighbourhood of Warley (recognised as being the priority settlement for housing growth). As such, the delivery of housing at the Ford site should be viewed as a vital, and priority opportunity for BBC in recognising that the Borough is heavily constrained by Green Belt (which makes up 89% of the Borough area), whereby this has made it challenging for BBC to fully meet its development needs. Our Client therefore contends that this approach is sound but should be consistently reflected in other aspects of the Plan (including the Draft allocation for the Ford site as discussed at Paragraph 3.2 of these representations). Draft Policy SP02: Managing Growth - The Government has introduced a new standardised methodology for calculating local housing need in line with the NPPF (2018). This is based on 2014 household projections published by the ONS. The NPPF (2018) places a much greater emphasis on seeking to meet objectively assessed needs than previous national policy - recognising that there are several significant negative socio-economic consequences that result from a failure to meet housing needs. This includes reducing access to housing, increasing inequality and housing market instability. One of the most significant impacts of a lack of housing supply is to reduce affordability, thereby increasing the number of concealed households and increasing the proportion of income required to rent. It is noted that the current PSD (Draft Policy SP02) makes provision for 7,752 new residential dwellings (net) to be built in the Borough over the plan period 2016-2033 at an annual rate of 310 dwellings per year to 2022/23, followed by 584 dwellings per year from 2023/24-2033. This approach adopts a stepped trajectory; resulting in the backloading of housing delivery beyond 2023 which we understand is in part due to a high proportion of Draft designated GB edge of settlement sites not being available for development until later in the plan period. Whilst our Client supports BBC's ascertain to direct housing growth to allocated sites in highly accessible locations along the transit/growth corridor (including the Ford Site) (as referenced under Draft Policy SP02 B), our Client considers that the starting point for examination of the Plan should be that a straight, rather than stepped trajectory should be used - to avert a significant, historic under-delivery of housing to persist (acknowledging that BBC are continuing to under-supply against its housing requirement until at least 2022/3). Whilst we do not consider that the principle of a stepped trajectory is justified, if this is accepted, we consider that a higher annual rate of housing delivery over the five-year period to 2023 should be tested. Iceni note that the current requirement for 310 dpa would fall below even the projected level of household growth. Indeed, the SHMA (2018) sets out that BBC has an uncapped need of 365 homes per year, reduced to 350 once a 40% cap is applied. The SHMA has pragmatically advised that BBC still needs to plan for at least 380 dpa as a minimum. Accordingly, we believe that BBC should take a rational position on this and plan for a higher annual housing target leading up to 2023 to ensure that a robust strategy is adopted (in line with the test of soundness). Notwithstanding, Ford encourages BBC to review the OAN figure as the Local Plan progresses towards examination to ensure that the housing target is adequately reflected. Housing Trajectory: In light of comments raised above (in addition to our Client's comments to Draft Policy RO4 and RO5), we contend that the housing trajectory referenced within Appendix 1 of the PSD should be reviewed and adjusted to recognise that the Ford Warley site (both the northern and southern parcel) can be delivered earlier in the plan period (1-5 years versus the 9-17 years as currently drafted), irrespective and in isolation of the Council Depot - which our Client has indeed raised in both previous rounds of consultation on the local plan (including the Call for Sites and PSA). Indeed, and as BBC officers are aware, Ford will be vacating the Warley Site in 2019, with Conceptual masterplanning already undertaken and submitted to BBC; demonstrating the deliverability and suitability of the Site for a significant quantum of residential development on the Site (please refer to 'Garden in the Woods' Conceptual Masterplan at Appendix A2; as submitted to BBC in May 2017 as part of the Call for Sites consultation). Further to ongoing dialogue with BBC, our Client also understands that the timescales for bringing forward the Council Depot for housing (which is still operational) are currently unknown at this stage, whereby the early delivery of the Ford site for housing should not be precluded on this basis. As such, our Client contends that the PSD as currently drafted, is contrary to the Governments ambitions to deliver 300,000 new homes by the mid-2020s nationally - ignoring the availability and deliverability of a significant proportion of housing at the Ford site, early in the plan period in providing for much needed housing for the Borough as soon as possible, at a sustainable brownfield location. In this regard, it is considered that the PSD is unsound on this basis and should be revised prior to being submitted for examination by BBC. Draft Policy SP06: Effective Delivery of Development: Our Client notes that Draft Policy SP06 is designed to ensure that a collaborative and participatory approach is taken when working up proposals. Ford are broadly supportive of this policy position, understanding the importance of comprehensive masterplanning to inform strategic site delivery. However, our Client wishes to note that such exercises should not inhibit the ability of individually owned sites to come forward for development. This is specifically referenced with regards to the Council Depot currently being included under the wider allocation for the Ford site, which we understand is not anticipated to be available for redevelopment until later in the plan period. As such, whilst Ford welcomes open and collaborative discussions regarding the wider allocation, and indeed the masterplan works to date have shown how future connections could be made to the Depot site; in tandem with how development could be proposed so as not to prejudice the development of either site, the early delivery of housing on the Ford owned land should not be prejudiced by delays in the decision-making process with regards to the Depot (see also comments under Draft Policy RO4 and RO5). It is considered that this would go against the premise of the overarching objective of the emerging Local Plan and the NPPF (2018) Paragraph 59 in terms of the delivery of sustainable development and ensuring the supply of homes without unnecessary delay. Draft Policy HP01 Housing Mix (varied types and tenures): Ford supports the intentions of Draft Policy HP01 in seeking to ensure that residential development proposals deliver housing in a way that contributes to the rebalancing of the housing stock; ensuring it reflects the recognised needs of existing and future communities. This includes providing a mix of dwelling types, sizes and tenures, relevant to the context of each site. Self-Build and Specialist Accommodation Threshold: Notwithstanding the above, our Client notes that the threshold for requiring a minimum of 5% self-build homes (which can include custom housebuilding and provision for specialist accommodation; see comments also made to Draft Policy HP04) is set at 500 or more dwellings. However, this threshold does not appear to have been applied to Draft allocations RO4 and RO5, which includes a requirement for both custom build housing and specialist accommodation across the wider allocation, despite having a total housing yield of 473 units across the Draft allocation - i.e. under the 500-unit threshold. Accordingly, our Client urges BBC to review this and requests that Draft allocation RO4 and RO5 is revised to remove this requirement based on the threshold set under Draft Policy HP01. At present, it is considered that there is a lack of evidence to justify this policy position, rendering the PSD unsound on this basis. Draft Policy HP03 - Residential Density: Ford welcomes Draft Policy HP03, which aims to ensure efficient use of the boroughs land whilst promoting a design-led approach to density which ensures schemes are sympathetic to local character and context. The supporting text states efficient land use is essential in a borough like Brentwood where land is scarce and enables new homes to be provided without encroaching on the countryside. This stresses the importance of delivering new housing on previously developed sites. Draft Policy HP05 - Affordable Housing: We fully appreciate that there is a significant need for affordable housing in Brentwood Borough, with 35% affordable applied to major residential schemes. Ford are aware that this level of affordable housing will likely be applied as part of any future planning application for the site, however this will be subject to scheme viability. BBC have recognised this approach, outlining that they will consider this where robust viability evidence demonstrates that the full amount of affordable housing cannot be delivered. This approach is welcomed by our Client and is considered to form a sound basis for negotiating affordable housing on a site-by-site basis (in line with NPPF Paragraph 62). Draft Policy PC03 - Employment Allocations: Ford notes that Draft Figure 7.6 and Appendix 2 of the PSD includes Part of allocation RO4 - 'Ford offices Eagle Way' (southern parcel of the Ford owned land) as an Existing Employment Site, whereby 2ha of land is proposed to be retained for employment purposes. However, there is no further evidence and/or explanation provided for this designation, which our Client indeed questioned and requested within our previous representations to the PSA consultation. Further, Draft Figure 7.5 'Employment Land Need' of the PSD outlines an employment land requirement of between 33.76ha and 45.96ha (taking account of four growth scenarios referenced under Draft Figure 7.4; as derived from the supporting Economic Future Report ['EFR'] January 2018). The EFR states that there is a pipeline supply of employment space in the Borough totalling 111.3ha. This includes 47.4ha of new employment allocations, 41.0ha of existing employment allocations, and 22.9 ha of existing employment sites previously unallocated. When subtracting the employment land requirements from BBC's new employment land supply there is a surplus in the range of between 21.4 ha and 33.7 ha (which is indeed recognised by BBC under Draft Paragraph 7.20 'exceeding requirements'). As such, it is highlighted that with the new employment allocations alone, BBC appear to have more than supply of employment land to meet its overall forecast needs over the plan period - questioning the requirement to retain 2ha of employment floorspace at the Ford site (whereby there appears to be very limited, or indeed no market demand for such space with no real planning basis for the 2ha figure referenced). Accordingly, it is anticipated that the new supply through the 'Proposed Allocations' should sufficiently compensate for the full release of the Ford site for residential with the Draft allocation for the Site revised accordingly including the removal for the requirement for 2ha of employment land. Ford also wishes to emphasise that the existing offices at Eagle Way were designed specifically for Ford and are bespoke for the operational and commercial requirements of Ford. It is therefore very unlikely that the Site could continue to support large-scale, modern employment uses of such a scale. It is also considered that the distance from Brentwood and Shenfield town centres and train stations would not be an attractive location for commercial investment - acknowledging that typically businesses requiring commercial properties of this size today, would pursue sites within close proximity of strategic infrastructure, trunk roads and more extensive local facilities and services. As such, and in light of current national policy parameters which specifically seek to promote sustainable forms of development, Ford wishes to object to the retention of employment uses at the Site - acknowledging that such a use is not considered an appropriate, or viable use of the Site in the future (contrary to the NPPF 2018). Ford further acknowledges that whilst there will be a requirement for commercial space in the Borough, land for residential development is critical in order to relieve any additional pressures on the Borough's Green Belt - with the Site representing an ideal opportunity for maximising residential development (including much needed family accommodation) which should be recognised under the Draft site allocation versus being restricted. In light of the above, and in the absence of robust evidence, Ford wishes to object to the provision of any level of employment use at the Site - rendering the PSD, Draft Policy PC03 and allocation RO4 and RO5 unsound on these grounds. Our Client therefore respectfully requests that the Site is removed from the listed 'Existing Employment Allocations' under Draft Figure 7.6. We also note that no reference is made to the re-provision of the Council Depot which we understand is likely to be retained for employment purposes into the early years of the plan period (given its current operational status). Draft Policy HP04 - Specialist Accommodation: Ford acknowledges that BBC are encouraging proposals to contribute to the delivery of Specialist Accommodation and are broadly supporting of Draft Policy HP04 in terms of providing such facilities where there is a 'demonstratable established local community need'. Ford recognises that the SHMA Part 2 (2016) identifies that there is likely to be an additional need for 494 specialist units over the next 20 years, including 466 units as sheltered housing and 28 extra-care units (albeit no distinction is made between them within the Draft policy wording, with no further assessment having been undertaken in recent years with regards to local requirements). Whilst Ford is supportive of BBC seeking to accommodate such facilities across the Borough, we note that there is currently a lack of evidence (including a detailed assessment of local community need) to fully justify accommodating such a use under Draft allocation RO4 and RO5, alongside residential. Indeed, we understand that that this requirement has only been included in response to a likely strategic-need for age friendly housing, but with no local analysis and/or basis to support this. Accordingly, and similarly to Ford's comments regarding the retention of employment uses at the Site, Ford wishes to highlight that due to the Site's location on the edge of Warley, it is considered that the Site does not represent the most suitable location for specialist care accommodation, with no analysis having been undertaken by BBC to demonstrate how the site is best placed to serve older people and their specialist needs. This goes to the heart of the NPPF (2018) test of soundness, in terms of the requirement for policies within local plans to be based on proportionate evidence. Further, Ford's commercial advisors CBRE have undertaken a recent analysis of local demand and supply within the surrounding Site area (Pulse Report) whereby this has identified that there is an oversupply of bed spaces across a variety of care spectrums (including a c.200 bed space oversupply within a 5-mile radius and c.1,000 within a 3 mile radius) - signifying a lack of need within the local area; whereby the Draft allocation would likely result in an un-viable future use (contrary to the parameters of sustainable development set out within the NPPF). As such, we would strongly urge BBC to revise the Draft allocation for the Site accordingly - recognising that it is most suitable for residential use only. Summary: On behalf of Ford, thank you for providing the opportunity to comment on the BBC PSD consultation document. As noted above, Ford is broadly supportive of the Draft allocation of its Site for housing, subject to further discussions with BBC Officers regarding the proposed additional land uses and development capacity - with sufficient evidence requested to justify the former, prior to the Local Plan being submitted for examination (to ensure that it is sound and legally compliant, in accordance with the NPPF 2018). We trust that the enclosed is clear, but please do not hesitate to contact Andrew Gale or Lucy Howes should you require any additional information. We would welcome discussing these representations with BBC at the earliest possible opportunity and to be kept informed of progress to the next stages of local plan preparation.

Redrow Homes propose: 1- A new policy to follow on from Policy SP02, in Chapter 4 (Managing Growth): Alteration of Green Belt Boundaries The areas of land covered by the following policies are removed from the Green Belt: RO3, (and all others concerned) The Council has arrived at these alterations on the basis of a sequential examination of brownfield and other sites not in the Green Belt, of a review of densities of development and of discussions with neighbouring local authorities to test the scope for them meeting some of the need for housing arising in Brentwood. The exceptional circumstances that justify the alterations are the severe shortage of land not within the Green Belt and suitable for development, making it impossible for the Council to meet its housing need other than through limited alterations of Green Belt boundaries. The Council has selected sites for boundary alterations where there will be least harm to the purposes of the Green Belt. 2- A new line to be added in the sequential test set out in para 3.23 Using Land Sequentially and the table revised to focus on land types: - Brownfield land within urban areas - Greenfield land within urban areas - Brownfield land within the Green Belt - Greenfield land within the Green Belt 3- Policy NE13 (Site Allocations in the Green Belt) is altered as follows: These sites will be are de-allocated from the Green Belt to allow development to take place... 4- Para 8.117 is deleted.

Site RO3, Land North of Shenfield, is allocated for development in Policy RO3 (Chapter 9), having been signposted in Policy SP02: Managing Growth. The site is currently in the Green Belt and the allocation anticipates the development of around 825 homes and associated infrastructure and facilities. The land to the east of the Chelmsford Road is in two ownerships, and both land promoters have agreed the principles of an overall master plan with Brentwood Borough Council. The Draft Local Plan anticipates that the homes will be delivered between 2023/24 and 2030/31; Redrow Homes is intending to see its portion of the new housing completed prior to this period, enabling it to contribute to the 5-Year Housing Land Supply. Redrow Homes, concerned to see its part of the Draft Plan implemented as quickly as possible, which requires the Draft Plan to be adopted equally soon, has considered the case made in the Draft Plan for the release of land from the Green Belt. However, Redrow Homes equally reserves the right to submit a planning application prior to adoption of the Local Plan given that the local authority can make a decision based on the planning merit and robust evidence base of a planning application prior to adoption of the emerging policy. In response to the Regulation 19 submission draft consideration of the Draft Plan follows in the next paragraphs. The NPPF 2018 has two main stipulations relating to alterations of Green Belt boundaries: "136. (part) Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries..." "137 (part) Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.." Examined fully all other reasonable options. The second requirement (examined fully all other reasonable options) should be conducted before the first. The Council's overall approach to site selection is described in the "Preferred Site Allocations, Site Selection Methodology and Summary of Outcomes, Working Draft, January 2018" and the approach is summarised in Figure 7 of that document and in para 3.23 of the Draft Plan. This sequential approach includes brownfield sites in the Green Belt but not greenfield sites in the Green Belt. Furthermore para 3.23 confuses a number of site selection criteria, for example proximity to transport facilities, as well as the key quality of the sites. At several points in the Draft Plan the Council has described how it went through this examination, most notably at paras 4.22-4.23 and the associated Figure 4.2, which shows that some 20% of the total new housing proposed will be located on Green Belt land. It would be helpful if this Figure could be explicitly labelled as illustrating the sequential examination. The examination is also described in paras 8.81-8.84 under the Green Belt and Rural Development heading; this passage also refers to the examination of all other reasonable options in the Sustainability Appraisal. The Council also commissioned a Green Belt Study, which assessed the contribution of potential development sites in the Green Belt to the purposes of the Green Belt; whilst there is an allusion to the results of the study in para 8.84 ("areas where the purposes of the Green Belt can still be demonstrated as being intact thereby maintaining the essential characteristics of 'openness'."), there is no direct reference to the study. Immediately after this the Draft Plan goes on to say "These exceptional circumstances have resulted in a 1% release of land from the Green Belt and have defined the need for Green Belt boundary changes in Policy SP02 Managing Growth and depicted in Figure 3.2 Growth Areas." The exceptional circumstances quoted here refer to the sequential examination of sites and to the assessment of the contribution that sites make to the purposes of the Green Belt. But the NPPF makes clear that exceptional circumstances and examination of all other reasonable options are distinct tests and exceptional circumstances won't normally be demonstrated through the sequential test alone. Equally, the issue of the impact on the purposes of the Green Belt is one of harm, not simply whether the lack of harm helps in the exceptional circumstances argument. Exceptional Circumstances The text at para 8.84 points to Policy SP02 Managing Growth as the policy that introduces the boundary changes. Policy SP02 sets out the number of dwellings for which land will be provided in the plan period and states that new development within the Borough will be directed towards (a) the site allocations in Chapter 9 and (b) highly accessible locations along transit/growth corridors. The policy makes no reference to Green Belt boundary changes. The text leading up to Policy SP02 explains how the Green Belt prevents the Council from identifying a five-year housing land supply, but not why land in the Green Belt is needed in order to deliver the required supply of additional housing. In Chapter 9 neither the text nor the individual allocations, for example RO3, Land north of Shenfield, a Green Belt site, make any reference to Green Belt boundary changes and their justification. Policy NE13, Site Allocations in the Green Belt, provides firstly for such sites to provide significant community benefits and secondly that: "These sites will be de-allocated from the Green Belt to allow development to take place and provide new defensible boundaries to protect the open countryside for future generations. Site boundaries to form the new Green Belt boundaries are set out on relevant sites in Appendix 2." The supporting text to this policy offers no justification in terms of exceptional circumstances. A short para (8.117) provides some explanation for the quoted section of the policy: "This policy also sets out the principles of removing allocated Green Belt development sites from the Green Belt. This de-allocation will allow for planning applications to be considered within the context of policies within this Plan as well as national policy and guidance." The term "will be" in the policy and the references to setting out the principles and planning applications in the supporting text make it unclear whether the Green Belt boundary changes are affected in the Draft Plan or they need to be justified by subsequent planning applications. Conclusions: Redrow Homes believe that the Draft Local Plan is not sound as it is not fully compliant with the NPPF. Comparing the Draft Local Plan with the requirements of the NPPF 2018 we conclude that: 1- The Draft Plan does not include a policy expressly changing Green Belt boundaries and justifying those changes in terms of exceptional circumstances. 2- The sequential approach adopted by the Council does not expressly include greenfield sites in the Green Belt. 3- The use of the future tense ("will be") in Policy NE13 creates a doubt as to whether Green Belt changes are introduced by the Draft Plan, when adopted, or at some later date. 4- The Draft Plan is unclear as to whether Green Belt boundary changes are being affected by the Draft Plan or they need to be justified in planning applications.

Need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound.

These representations are submitted by Strutt & Parker on behalf of Stonebond Properties Ltd. in relation to the Brentwood Borough Council (BBC) Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our client's land interests at Stocks Lane, Kelvedon Hatch. This is proposed for allocation under Policy R24 of the PSLP. Plans showing the site are included within the Vision Document at Appendix A to this representation. As the Council will be aware, representations have previously been made on behalf of the landowner, W H Norris & Sons, in respect of the land at Stocks Lane, most recently as part of the Regulation 18 Local Plan Consultation in March 2018. Since then the site has come into the control of Stonebond Properties Ltd, a local housing developer with considerable experience of bringing forward high quality homes on small and medium sites. As a result of the previous representations and discussions with officers at Brentwood Borough Council alongside the Local Plan process, this site and land at Blackmore Road (Site R23, Brize's Corner Field, also now under Stonebond Properties' control) have been proposed as sites for future residential development within PSLP. Stonebond's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to certain elements of the Policy R24 in relation to the amount of development, the expected time for delivery in the Plan period and certain elements of the PSLP's Development Management Policies. Where such concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist in BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. Stonebond Properties request the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the Examination of the submitted Local Plan. Settlement Hierarchy: Kelvedon Hatch is confirmed as a Category 3 Larger Village as set out in the Settlement Hierarchy shown at figure 2.3 of PSLP. It states that these villages are characterised by the amount of amenities and services able to cater for residents' day to day needs. Kelvedon Hatch has a local centre with a range of services, facilities, access to public transport, and education services. The PSLP sets out that Category 3 settlements should seek to make the most of brownfield redevelopment opportunities, while limited urban extensions will be encouraged to meet local needs where appropriate. The population is stated as 2,124, making Kelvedon Hatch the second largest Category 3 Settlement behind Doddinghurst. Due to the proximity of Doddinghurst (around 1km to the east), there is a reciprocal relationship between the two villages in terms of the availability and access to services and other facilities. As a result, development at Kelvedon Hatch 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 provides for the growth of the settlement to ensure the vitality of the community is sustained or enhanced. In line with Paragraph 78 of the NPPF, growth in one village may have the added benefit of further supporting opportunities and growth in nearby surrounding villages. The two sites for additional housing in Kelvedon Hatch identified in the PSLP at Land at Stocks Lane (R24) and west at Blackmore Road (R23) are fully supported. The proposed allocation of these two sites is considered to be justified, consistent with national policy and necessary to ensure the sustainable growth of Kelvedon Hatch and the Borough for reasons set out elsewhere in these representations. Spatial Strategy - Vision and Strategic Objectives: Vision for the Borough: The Vision for the Borough set out at Section 3 of the PSLP is supported. For the reasons set out in these representations, carefully planned development at Kelvedon Hatch as provided for at Policies R23 and R24 will make an important contribution to BBC's housing needs to meet the Local Plan objectives. Indeed, these representations and those relating to R24 make the case that a modest and justified increase in the sites' ability to accommodate more homes will assist meet those aims and provide for greater flexibility in meeting housing needs. Stonebond Properties have undertaken detailed site assessments. These confirm that there are no barriers to delivery of development. As a consequence, the expressed objectives of development in the Vision to be landscape-led responding to a "design and build with nature approach firmly embedding high quality green infrastructure through public realm to create a seamless transition to our surrounding countryside" can all be achieved and delivered in the allocation of sites R23 and R24. This is demonstrated in the accompanying Vision Documents to this representation for R24. Managing Growth - Policy SP02: Managing Growth: Policy SP02 proposes a total of 7,752 dwellings be provided in the Borough between 2011 and 2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. This matter is dealt with further at Section 8 below. Furthermore, and notwithstanding the stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. BBC are effectively placing most of its "eggs in one basket." in the range of sites that are proposed in the PSLP. It is important to note that, of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at Dunton Hills Garden Village and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at Dunton Hills. The ability of larger strategic 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's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. It therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound. Sequential Land Use: Paragraph 4.22 and 4.23 of the PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP. SP04 - Developer Contributions: There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted. Resilient Built Environment: We are generally supportive of the Council's objectives to achieve a resilient built environment. Nevertheless, there are concerns that the policies set out in the PSLP and as drafted may have an impact on viability, deliverability and affordability for housing development generally. We are aware of the representations made by the House Builders Federation (HBF) referring to sustainable construction (BE020), allotments (BE20), Green and Blue Infrastructure (BE18), access to nature (BE19), digital infrastructure (BE10), open space (BE22), electrical vehicle charging (BE15), housing quality (HP06). The implications of the requirements set out do not appear to have been fully considered as part of the viability assessment. As a consequence, we would suggest that the viability assessment for the PSLP is revisited to reflect on these requirements to better inform or provide clarity on the proposed policies. Policy BE01 - Future Proofing: Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. As a consequence, it is suggested that Policy BE01 should be set out as supporting text rather than a specific policy. Policy BE02 - Sustainable Construction and Resource Efficiency: Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments. Policy BE20 - Allotments and Community Food Growing Space: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations. Policy BE22 - Open Space in New Development: The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes. Housing Provision: Policy HP01 - Housing Mix: The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. As a consequence, it is suggested that para 6.5 should provide greater clarity and a minor change confirming that the final mix will be subject to negotiation "as part of a planning application" rather than "with the applicant". We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations. Policy HP03 - Residential Density: We support the PSLP's approach to residential density as set out in Policy HP03. This is considered to be justified based on the evidence and consistent with the national policy. As far as our client's land interests are concerned at R23 and R24, both sites are capable of providing an increased density to that expressed for the relevant policies R23 and R24. However, part B of the policy quite properly acknowledges that a chosen density should take into account the character of the surrounding area and other site constraints. This is supported. A further explanation of suggested density or yield for R24 is set out at Section 8 below. Policy HP05 - Affordable Housing: We note that the SHMA provides justification for the affordable housing requirements. However, it is questionable whether the precise tenure/mix should be set out at B(a) of the Policy, given that requirements can change relatively quickly over time and the prescriptive approach may not take into account precise local needs. As a consequence, it is recommended that the criteria under B(a) should omit the reference to 86% and 14% proportions. It is suggested, in the alternative, that "the mix, size, type and cost of affordable homes will meet the identified housing needs of the Council's area and local needs as appropriate, established by housing need assessments including the SHMA". Design and Place-making: The approach set out in the PSLP for design and place-making is broadly supported. However, we note that there are effectively seven policies (HP12 - HP18) which provide the requirements against these matters. We also note that there are some areas of repetition on some of the objectives against those policies. We consider that those commenting on and determining applications should preferably have one or two identified policies to refer to and/or applicable thresholds to more succinctly set out requirements. This would ensure that planning applications can be more effectively judged against context, design and place-shaping criteria. Natural Environment: We generally support the Council's approach to Green Belt and the identification of suitable sites to meet the Council's housing and other needs. Accompanying these representations is an overview of the Green Belt and Landscape Sensitivity considerations relating to Stonebond's land interests at R23 and R24 to confirm the suitability of removing those sites from the Green Belt and limited impact on the landscape. Policy NE13 - Site Allocations in the Green Belt: We welcome the PSLP's intentions to remove sites R23 and R24 from the Green Belt. This calls into question the need for Policy NE13. The requirements set out by criterion A and B are dealt with by other policies in the Plan. If there are site specific requirements relating to sites, these should be covered within the specific policies relating to those sites. Site Allocations: Policy R24 - Land off Stocks Lane: The proposed allocation of Land off Stocks Lane as Policy R24 and its removal from the Green Belt is considered sound and is fully supported. It has been established through the evidence base supporting the PSLP that Kelvedon Hatch is a sustainable location to accommodate a modest amount of new houses to contribute to the Borough's housing needs. Indeed, as recognised by para 68 of the NPPF and as a medium sized site, such sites make an important contribution to "meeting the housing requirement of an area and are often built out quickly". We do however have some concerns with the amount of development set out at A of the Policy and the indicative yield at page 340 and the suggested trajectory for the site at Appendix 1. These matters are dealt with below. Supporting these representations is a Vision Document at Appendix A, a review of Green Belt and Landscape Sensitivity at Appendix B and a Summary Drainage and Utility Appraisal at Appendix C. These all confirm that the development at the site is both justified and fully deliverable within the terms of para 67a) of the NPPF. The Vision Document demonstrates that careful consideration has been given to the emerging policies set out at BE01, BE08, BE22, as well as those relating to Design and Place-making at HP12, HP13, HP14, HP15 and HP18 of the PSLP to confirm that a scheme can meet the PSLP objectives in this regard. The Summary Drainage and Utility Appraisal at Appendix B confirms that there are no constraints to delivery. In addition, Stonebond Properties commissioned a transport appraisal from Ardent Consulting Engineers. This has confirmed that the location of the access shown in the Vision Document meets normal highway requirements in terms of safety and visability. This has been confirmed in speed surveys undertaken in Stocks Lane. The Green Belt and Landscape Sensitivity Assessment at Appendix B confirms that the release of the site from the Green Belt is justified. It also confirms that there would be no significant impact on the surrounding landscape. Part A of Policy R24 suggests that there be provision for around 30 new homes on the site. Part A Policy HP03 of the PSLP requires proposals to take a design led approach to density to ensure schemes are sympathetic to local character and make efficient use of land. Part B expects development to achieve a net density of at least 35dph unless the special character of the surrounding area suggests that such densities would be inappropriate. The suggested amount of 30 homes set out for Policy R24 does not currently reflect these requirements or provide an accurate representation of what is achievable on site. 30 homes represent 18.6dph which clearly does not represent an efficient or effective use of the land contrary to the objectives of HP03 and the supporting text set out at 6.18 to 6.20 and 6.22. The Vision Document confirms that around 45 homes can actually be provided on the site representing a far more efficient and effective dwelling yield. 45 homes would represent a density of approximately 28dph. Whilst this does not achieve 35dph, the Vision Document demonstrates that full account has been taken of the objectives of HP03 to ensure that a scheme would be sympathetic to local character. Critically, the illustrative scheme shows provision for open space within the site to meet the objectives of Policies HP13 and BE22. These policies provide for functional on-site open space. As such, achieving a greater density would be problematical. In addition, it is important to note that the site is on the edge of the settlement where there is a need for sensitivity, having regard to the countryside to the east and south. Para 6.22 of the PSLP confirms that efficient land use is critical to the delivery of this Plan for the reasons set out at Sections 4 and 6 above against this background, it is recommended that amendments are made as follows: Policy R24A - substitute 30 new homes with 45 new homes; Page R24 - indicative dwelling yield substitute 30 with 45. At para 9.195 the PSLP suggests the development would take its access from Blackmore Road. This is an error. The paragraph should be amended to refer to Stocks Lane. The site is within the control of Stonebond Properties, a local house builder with considerable experience in the development of medium sized sites, quick delivery and achieving high design and layout standards. Upon removal from the Green Belt and grant of a planning permission, it would be expected that development at the site could commence 2020/21 and be completed within two years of the Plan. As a consequence, it is recommended that the Local Development Plan Housing Trajectory at Appendix 1 is amended to provide for the following based on an increased number of homes as set out in these representations: Year 5 - 2020/21 = 10; Year 6 - 2021/22 = 35. These comments on Policy R24 provide greater certainty on delivery of the site. In addition, the changes suggested would contribute to the issues we have identified elsewhere with the PSLP specifically in relation to the supply and delivery of homes generally. As a result, we trust that the Council will be able to agree modifications/changes accordingly.

Need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound.

These representations are submitted by Strutt & Parker on behalf of Stonebond Properties Ltd. in relation to the Brentwood Borough Council (BBC) Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our client's land interests at Stocks Lane, Kelvedon Hatch. This is proposed for allocation under Policy R24 of the PSLP. Plans showing the site are included within the Vision Document at Appendix A to this representation. As the Council will be aware, representations have previously been made on behalf of the landowner, W H Norris & Sons, in respect of the land at Stocks Lane, most recently as part of the Regulation 18 Local Plan Consultation in March 2018. Since then the site has come into the control of Stonebond Properties Ltd, a local housing developer with considerable experience of bringing forward high quality homes on small and medium sites. As a result of the previous representations and discussions with officers at Brentwood Borough Council alongside the Local Plan process, this site and land at Blackmore Road (Site R23, Brize's Corner Field, also now under Stonebond Properties' control) have been proposed as sites for future residential development within PSLP. Stonebond's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to certain elements of the Policy R24 in relation to the amount of development, the expected time for delivery in the Plan period and certain elements of the PSLP's Development Management Policies. Where such concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist in BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. Stonebond Properties request the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the Examination of the submitted Local Plan. Settlement Hierarchy: Kelvedon Hatch is confirmed as a Category 3 Larger Village as set out in the Settlement Hierarchy shown at figure 2.3 of PSLP. It states that these villages are characterised by the amount of amenities and services able to cater for residents' day to day needs. Kelvedon Hatch has a local centre with a range of services, facilities, access to public transport, and education services. The PSLP sets out that Category 3 settlements should seek to make the most of brownfield redevelopment opportunities, while limited urban extensions will be encouraged to meet local needs where appropriate. The population is stated as 2,124, making Kelvedon Hatch the second largest Category 3 Settlement behind Doddinghurst. Due to the proximity of Doddinghurst (around 1km to the east), there is a reciprocal relationship between the two villages in terms of the availability and access to services and other facilities. As a result, development at Kelvedon Hatch 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 provides for the growth of the settlement to ensure the vitality of the community is sustained or enhanced. In line with Paragraph 78 of the NPPF, growth in one village may have the added benefit of further supporting opportunities and growth in nearby surrounding villages. The two sites for additional housing in Kelvedon Hatch identified in the PSLP at Land at Stocks Lane (R24) and west at Blackmore Road (R23) are fully supported. The proposed allocation of these two sites is considered to be justified, consistent with national policy and necessary to ensure the sustainable growth of Kelvedon Hatch and the Borough for reasons set out elsewhere in these representations. Spatial Strategy - Vision and Strategic Objectives: Vision for the Borough: The Vision for the Borough set out at Section 3 of the PSLP is supported. For the reasons set out in these representations, carefully planned development at Kelvedon Hatch as provided for at Policies R23 and R24 will make an important contribution to BBC's housing needs to meet the Local Plan objectives. Indeed, these representations and those relating to R24 make the case that a modest and justified increase in the sites' ability to accommodate more homes will assist meet those aims and provide for greater flexibility in meeting housing needs. Stonebond Properties have undertaken detailed site assessments. These confirm that there are no barriers to delivery of development. As a consequence, the expressed objectives of development in the Vision to be landscape-led responding to a "design and build with nature approach firmly embedding high quality green infrastructure through public realm to create a seamless transition to our surrounding countryside" can all be achieved and delivered in the allocation of sites R23 and R24. This is demonstrated in the accompanying Vision Documents to this representation for R24. Managing Growth - Policy SP02: Managing Growth: Policy SP02 proposes a total of 7,752 dwellings be provided in the Borough between 2011 and 2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. This matter is dealt with further at Section 8 below. Furthermore, and notwithstanding the stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. BBC are effectively placing most of its "eggs in one basket." in the range of sites that are proposed in the PSLP. It is important to note that, of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at Dunton Hills Garden Village and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at Dunton Hills. The ability of larger strategic 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's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. It therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound. Sequential Land Use: Paragraph 4.22 and 4.23 of the PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP. SP04 - Developer Contributions: There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted. Resilient Built Environment: We are generally supportive of the Council's objectives to achieve a resilient built environment. Nevertheless, there are concerns that the policies set out in the PSLP and as drafted may have an impact on viability, deliverability and affordability for housing development generally. We are aware of the representations made by the House Builders Federation (HBF) referring to sustainable construction (BE020), allotments (BE20), Green and Blue Infrastructure (BE18), access to nature (BE19), digital infrastructure (BE10), open space (BE22), electrical vehicle charging (BE15), housing quality (HP06). The implications of the requirements set out do not appear to have been fully considered as part of the viability assessment. As a consequence, we would suggest that the viability assessment for the PSLP is revisited to reflect on these requirements to better inform or provide clarity on the proposed policies. Policy BE01 - Future Proofing: Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. As a consequence, it is suggested that Policy BE01 should be set out as supporting text rather than a specific policy. Policy BE02 - Sustainable Construction and Resource Efficiency: Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments. Policy BE20 - Allotments and Community Food Growing Space: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations. Policy BE22 - Open Space in New Development: The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes. Housing Provision: Policy HP01 - Housing Mix: The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. As a consequence, it is suggested that para 6.5 should provide greater clarity and a minor change confirming that the final mix will be subject to negotiation "as part of a planning application" rather than "with the applicant". We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations. Policy HP03 - Residential Density: We support the PSLP's approach to residential density as set out in Policy HP03. This is considered to be justified based on the evidence and consistent with the national policy. As far as our client's land interests are concerned at R23 and R24, both sites are capable of providing an increased density to that expressed for the relevant policies R23 and R24. However, part B of the policy quite properly acknowledges that a chosen density should take into account the character of the surrounding area and other site constraints. This is supported. A further explanation of suggested density or yield for R24 is set out at Section 8 below. Policy HP05 - Affordable Housing: We note that the SHMA provides justification for the affordable housing requirements. However, it is questionable whether the precise tenure/mix should be set out at B(a) of the Policy, given that requirements can change relatively quickly over time and the prescriptive approach may not take into account precise local needs. As a consequence, it is recommended that the criteria under B(a) should omit the reference to 86% and 14% proportions. It is suggested, in the alternative, that "the mix, size, type and cost of affordable homes will meet the identified housing needs of the Council's area and local needs as appropriate, established by housing need assessments including the SHMA". Design and Place-making: The approach set out in the PSLP for design and place-making is broadly supported. However, we note that there are effectively seven policies (HP12 - HP18) which provide the requirements against these matters. We also note that there are some areas of repetition on some of the objectives against those policies. We consider that those commenting on and determining applications should preferably have one or two identified policies to refer to and/or applicable thresholds to more succinctly set out requirements. This would ensure that planning applications can be more effectively judged against context, design and place-shaping criteria. Natural Environment: We generally support the Council's approach to Green Belt and the identification of suitable sites to meet the Council's housing and other needs. Accompanying these representations is an overview of the Green Belt and Landscape Sensitivity considerations relating to Stonebond's land interests at R23 and R24 to confirm the suitability of removing those sites from the Green Belt and limited impact on the landscape. Policy NE13 - Site Allocations in the Green Belt: We welcome the PSLP's intentions to remove sites R23 and R24 from the Green Belt. This calls into question the need for Policy NE13. The requirements set out by criterion A and B are dealt with by other policies in the Plan. If there are site specific requirements relating to sites, these should be covered within the specific policies relating to those sites. Policy R23 - Brizes Corner Field, Blackmore Road: The proposed allocation of Land off Blackmore Road as Policy R23 and its removal from the Green Belt is considered sound and is fully supported. It has been established through the evidence base supporting the PSLP that Kelvedon Hatch is a sustainable location to accommodate a modest amount of new houses to contribute to the Borough's housing needs. Indeed, as recognised by para 68 of the NPPF and as a medium sized site, such sites make an important contribution to "meeting the housing requirement of an area and are often built out quickly". We do however have some concerns with the amount of development set out at A of the Policy, the indicative yield at page 339 and the suggested trajectory for the site at Appendix 1. These representations provide for a modest increase in the developable area of the site with compensatory open space/structural landscaping. These matters are dealt with further below. Supporting these representations is a Vision Document at Appendix A, a review of Green Belt and Landscape Sensitivity at Appendix B and a Summary Drainage and Utility Appraisal at Appendix C. These all confirm that the development at the site is both justified and fully deliverable within the terms of para 67a) of the NPPF. The Vision Document demonstrates that careful consideration has been given to the emerging policies set out at BE01, BE08, BE22, as well as those relating to Design and Place-making at HP12, HP13, HP14, HP15 and HP18 of the PSLP to confirm that a scheme can meet the PSLP objectives in this regard. The Summary Drainage and Utility Appraisal at Appendix B confirms that there are no constraints to delivery. In addition, Stonebond Properties commissioned a transport appraisal from Ardent Consulting Engineers. This has confirmed that the location of the access shown in the Vision Document meets normal highway requirements in terms of safety and visibility. This has been confirmed in speed surveys undertaken in Blackmore Road. The Green Belt and Landscape Sensitivity Assessment at Appendix B confirms that the release of the site from the Green Belt is justified. It also confirms that there would be no significant impact on the surrounding landscape. Vision Document illustrates a form of development for the proposed allocation area set out in the PSLP to provide for around 28 homes. These representations suggest that the allocated area could increase to provide for a modest addition to the developable area in associate with compensatory open space and structural landscaping. It is considered that the proposals would be in accordance with para 138 of the NPPF. This advises local planning authorities to "set out ways in which the impact of removing land from the Green Belt can be off set through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land". The Vision Document demonstrates how this can be achieved using land that is within their control. The Green Belt and Landscape Sensitivity Assessment confirms that such an approach would not result in demonstrable harm to the Green Belt or landscape. Part A of Policy R23 suggests that there be provision for around 23 new homes on the site. Part A Policy HP03 of the PSLP requires proposals to take a design led approach to density to ensure schemes are sympathetic to local character and make efficient use of land. Part B expects development to achieve a net density of at least 35dph unless the special character of the surrounding area suggests that such densities would be inappropriate. Based on page 339 of the PSLP, the suggested dwelling yield of 23 homes would result in a density of 29dph. The Vision Document confirms that within the allocated area it would be possible to provide around 28 homes at a density of 35dph. The Vision Document sets out an alternative approach to the allocation to increase the area to 2.45ha gross. This would provide for around 45 homes at 29dph on a net developable area of approximately 1.6ha. Critically, the Vision Document provides for a third of the area to be set aside for structural accessible open space in accordance with para 138 of the NPPF. The Vision Document therefore proposes that around 45 homes can be provided on the site representing a far more efficient and effective dwelling yield with benefits for open space and the Green Belt generally in this location by bringing forward a robust and enduring boundary. The Vision Document demonstrates that full account has been taken of the objectives of HP03 to ensure that a scheme would be sympathetic to local character. Critically, the illustrative scheme for the increased area for allocation would meet objectives for open space within the site in accordance with Policies HP13 and BE22 whilst taking into account the need for sensitivity, having regard to the countryside to the west and south. Section 4 of these representations sets out the need for greater flexibility and need for the provision of medium sized sites to aid the Council's housing needs and requirements. Against this background, these proposals to provide a modest increase to the allocated area for R23 are commended to the Council on the basis that the increased area provide for structural and accessible open space. It is therefore recommended that Policy R23 is amended as follows: Policy R23A - substitute 23 new homes with 45 new homes; Policy R23B - additional bullet point b - development shall provide for not less than 0.7ha for accessible public open space and structural landscaping; Page 339 R23 - indicative dwelling yield substitute 23 with 45. The site is within the control of Stonebond Properties, a local house builder with considerable experience in the development of medium sized sites, quick delivery and achieving high design and layout standards. Upon removal from the Green Belt and grant of a planning permission, it would be expected that development at the site could commence 2020/21 and be completed within two years of the Plan. As a consequence, and based on these representations for an increased allocation, it is recommended that the Local Development Plan Housing Trajectory at Appendix 1 is amended to provide for the following based on an increased number of homes as set out in these representations: Year 5 2020/21 = 10 and Year 6 - 2021/22 = 35. These comments on Policy R23 provide an ability for a modest increase in the amount of houses for the allocated site with significant local benefits for accessible open space and structural landscaping. This would result in compensatory improvements to the environmental quality and accessibility of Green Belt land in accordance with para 139 of the NPPF. In addition, the recommended changes would contribute to the issues we have identified elsewhere with the PSLP specifically in relation to the supply and delivery of homes generally. As a result, we trust that the Council will be able to agree modifications/changes accordingly.