There is no clear strategy for Blackmore and other villages in the north of the borough. Brentwood Borough Council does not appear to have taken into consideration the proposals of neighbouring authorities e.g. Epping Forest District Council is proposing to construct 30 dwellings at the top of Fingrith Hall Lane - the residents of these houses will almost certainly use Blackmore as a local shopping place adding both to the traffic along Fingrith Hall Lane and the parking congestion in the centre of Blackmore village. Both policies R25 and R26 are based upon development off Red Rose Lane which according to the plan will be the main vehicular access. In total the plan as it currently stands is to add 70 homes across the two allocations - Red Rose Lane is a narrow lane most of which is not wide enough to allow two cars to pass one another, but given Blackmore's relatively poor public transport connections we can expect an average of at least two additional cars per household and assuming a minimum of two journeys each per day (one in and one out) that is a minimum of 280 extra cars per day along this narrow lane which has no pavements. In addition, Red Rose Lane has signs at each end stating that it is unsuitable for heavy goods vehicles (see photos embedded below) and yet this will be the access route for all the construction traffic for the two sites. Red Rose Lane has drainage ditches running down either side of it which are important for local drainage and widening the road is not a viable option without further increasing the flood risk for the rest of the village. Please also see further comments below concerning the flood risk within the village. Both of these sites are green belt land. Section 2 in paragraph 2.8 of the plan classes Blackmore as Settlement Category 3 which to quote the table under paragraph 2.10 are "Villages in a sparse rural setting that provide day to day needs for local residents. Brownfield redevelopment opportunities and limited urban extensions will be encouraged to meet local needs where appropriate. Development should be appropriate to the rural setting of the area." Adding 70 homes on green belt land in a village with a population of 829 is neither appropriate to the rural setting nor is it brownfield redevelopment. This does not in any way seem to comply with Policy SP01: Sustainable Development which states in paragraph 4.9 "For a scheme to be acceptable, development will be required to make satisfactory arrangements for vehicular, cycle and pedestrian access into the site and for parking and servicing within the site. Any traffic generated by the development should be capable of being satisfactorily accommodated by the transport network and not give rise to unacceptable highway conditions, safety and amenity concerns." The LDP proposes that 1% of the net homes should be on green belt land around "large villages", a total of 123 homes, and yet 70 of these are proposed for this one village - this appears to contradict paragraph 8.101. There is also no justification as to why Blackmore, amongst a number of other settlements should be "excluded from the Green Belt" (paragraph 8.90). In addition the village primary school is already fully subscribed and the local doctor's surgery (which is located in Doddinghurst) is very busy and it can take up to two weeks to obtain an appointment. There is nothing within the development plan to mitigate for this. There is very limited parking in the centre of the village both outside the village shop and the two public houses and tea shops, with cars regularly parked along both sides of Fingrith Hall Lane and around Horse Fayre Green and it can be expected that this only will only spread further into the surrounding residential areas and along to the village green with the additional cars that the proposed developments will bring. There does not appear to have been any housing needs survey to demonstrate why Blackmore requires such extensive development. The proposed sites are liable to flooding and building on these and concreting them over will increase the flood risk to the rest of the village. Blackmore lies in a shallow bowl of land at the top of a gentle valley with the River Wid emerging from the south side of The Moat. So, surface water drains from the west, north and east into the village and then around The Moat to become the River Wid. This is ok in normal conditions but when rainfall is extreme the streams and drainage pipes are overwhelmed with flooding of roads which is common and sometimes with danger to homes. There was flooding of roads in the village in June 2016 after heavy rain and I am aware that the home of one of our near neighbours was flooded by waters rising from the stream that runs underneath their house in Church Street as it could not cope with the volume of rainfall. Having more hard impermeable surfaces such as roofs, drives and roads which increase the speed of run-off of surface water will further increase the risk of overwhelming the drainage systems. This seems to totally contradict policy NE06. There is therefore no indication within the LDP as to how the proposed Policy R25 and R26 developments around Blackmore will be "repaid through significant benefits to the new and existing communities" (paragraph 8.114) - in fact due to the size of the proposals it would seem to be to the detriment of the existing community through the addition traffic, congestion and flood risk that would result from these policies.

It is considered that the Brentwood Local Plan will need to be re-assessed in light of the implications of the Government requirement to use the standard methodology with CLG 2014-based household projections.
The plan will need to be revised make provision for a higher housing target and provision for additional housing sites to provide a contingency buffer.
In light of the revised housing baseline figures the SA will need to be reviewed to take account of this requirement.
Technical evidence and the IDP will need to be reviewed and where necessary amended to take account of revised housing target.
The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a further review of the South Essex SHMA that would incorporate the outcome of changes to projections and methodology referred to above. It is considered that as a partner in the joint working that Brentwood Council should include any review of its OAHN in the South Essex review SHMA.

The Pre-Submission Brentwood Local Plan (Regulation 19) fails to take into account the latest Government approach (as published in February 2019) to housing need assessment and use of the appropriate household and demographic data and is therefore considered unsound. The baseline housing target in the pre-submission plan of 350 dwellings per annum is now considered inappropriate and out of date. The upper end flexible target of 456 dwellings per annum is now just above the baseline requirement of 452pa as set out in the standard methodology approach.

It is noted that the previous Preferred Site Allocations consultation of 2018 had been based on the then January 2018 Strategic Housing Market Assessment of Objectively Assessed Housing Need providing a figure of 380 dwellings per annum and 7600 dwellings over the plan period 2013-2033. The OAHN figure was based upon a demographic derived need of 280 dpa uplifted by 30% to take account of market signals and 6% contingency figures to allow for possibility of increase due to new official population and housing projections. There is no employment uplift to these figures. The objectively assessed need was therefore using an approach set out in Planning Practice that related to the NPPF of 2012. The Government had published in September 2017 draft options for a standard methodology. The draft target for Brentwood using this methodology and based upon the 2014 CLG Household Projections was 454 dwellings.

Due to the uncertainty regarding the proposed Government options for assessment of need and pending new demographic projections Brentwood Council plan housing target numbers slightly above the then assessed objectively assessed housing need to allow some degree of flexibility and to make a contingency. Furthermore it is noted that the Council considered that there was potential to accommodate the housing numbers proposed by the Government proposed standardised methodology at Dunton Hills Garden Village. Thurrock Council had sought further clarification as to the actual level of housing requirement and provision that will be included in the local plan and that this can be accommodated within the Brentwood Borough boundary.

The revised NPPF and Guidance of July 2018 stated the standard methodology should be used for calculating objectively assessed need and use of the most recently published household projections. At the time the 2014 CLG based Household Projection formed the starting point with a OAN figure of 452 homes per annum.


In September 2018, ONS published 2016-based Household Projections. Using the standard methodology these projections show a reduced rate of household growth resulting in a reduced housing requirement for Brentwood of 350 dwellings per annum. It is this figure that have been used to assess the OAN for Brentwood in the revised SHMA of November 2018 and incorporated as the baseline housing target figure in the Pre-Submission Brentwood Local Plan (Regulation 19). The Pre-Submission Plan includes a higher figure of 456 dwellings per annum as an upper range to provide flexibility and act as a contingency figure. The total housing provision in the Brentwood local plan is 7,752 dwellings between 2016-2033 (456 dwellings per annum).

However in February 2019 the Government published a revised NPPF, Planning Guidance and response to its consultation on assessing need. It has made clear that the 2016-based household projections should not be used for the standard methodology calculation and the 2014 CLG household projections used instead.

Therefore the Brentwood Pre-Submission Local Plan (Regulation 19) in making an upper provision for up to 456 homes per annum just meets the OAN for housing in the plan period having regard to the current standard methodology. However the baseline housing target of 350 dwellings is now based upon a methodology that does not comply with Government Policy. This calls into question the soundness of the plan but also means the plan no longer provides for a contingency above the OAN and no buffer requirement to meet any failure of the thresholds of the housing delivery test.

The Government's recently published Housing Delivery Test figure for Brentwood indicate that it is required to provide a 20% buffer. As the Housing requirement for Brentwood is now based upon the higher standard methodology figure of 452 dwellings per annum. It is unclear whether Brentwood is able to meet these figures for its five year supply as the Pre-submission plan housing trajectory was assuming 310 dwellings in the early period of the plan.

Thank you for the opportunity to comment on the Brentwood Local Plan Regulation 19 consultation.

Brentwood is located within a separate Housing Market Area to Southend. I also note that you intend to accommodate your own projected need, primarily at Dunton Hills, and are not seeking for neighbouring authorities to take any of your housing requirements. If this was not the case, all the evidence base work commissioned for the Southend Local Plan Issues and Options indicates that Southend will not be able to meet its housing need in full and will therefore, be unable to contribute to meeting other authorities need.

I understand that work has been undertaken in assessing housing provision, particularly regarding the Dunton Hill Garden Settlement. At a strategic South Essex level it will be important to fully consider how this proposal relates to wider strategic housing proposals in the West Horndon area (affecting other neighbouring authorities).

The A127 and the C2C rail routes are key strategic transport corridors linking Southend to London and beyond through neighbouring authorities, including Brentwood. Both already face capacity issues and it is important that the impacts of development are considered not only on individual junctions but taking into account a "whole route" approach. There is already an A127 Working group comprising all the Highway authorities along the corridor which is considering possible interventions along the route. It is essential that any significant interventions in Brentwood therefore are aligned with this work.

Brentwood and Southend Councils are both active partners in the Association of South Essex Authorities working on the Joint Strategic Plan for South Essex. This will set the overall planning context for South Essex and respective Local Plans will need to align with this or if they are prepared in advance, include appropriate review mechanisms. This is important for fulfilling the Duty to Co-operate requirements set out in legislation.

Please refer to "BVHA neighborhood plan ". [Not supplied].

Section 09 R25 , R26 two fields off of Red Rose Lane

Section 08 -Greenbelt flooding
04- Managing growth
Unsound :
BBC has not demonstrated that there are other brownfield sites that are available and which should take priority over the greenfield land off Red Rose Lane.
There has been no Housing Needs Survey to demonstrate why Blackmore is included in the LDP.
The access off/from Red Rose Lane is entirely unsuitable for the volume of traffic movements if development goes ahead.
Please refer to "BVHA neighbourhood plan " [Not supplied].
I support BVHA representation

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

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

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

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

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

Aditional non-strategic sites are required. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings).Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.

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

Release additional, suitable Green Belt sites in order to assist with the delivery of homes over the Plan period, including to meet the need for specialist housing.

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

Housing requirement number to be recalculated, relevant policies to be amended and additional sites allocated.

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

Aditional non-strategic sites are required.

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

Aditional non-strategic sites are required. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings).Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.

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

the Local Authority reviews its housing supply, and particularly its approach to small sites, and allocate suitable smaller sites which can be brought forward early in the plan period.

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

1.0 Introduction
1.1 These representations have been prepared by Bidwells on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's (hereafter referred to as "BBC") public consultation on the Regulation 19 Pre-Submission Local Plan ("the emerging Plan") in respect of land at Nags Head Lane, Brentwood ("the Site").
1.2 Crest Nicholson Eastern controls the entirety of the Site which is the subject of a proposed allocation in the emerging Plan under Policy R06 for the development of around 125 dwellings. Primarily, the consultation seeks responses regarding the soundness of the emerging Plan as set out in the National Planning Policy Framework (NPPF).
1.3 Our comments on the emerging Plan are made having regard to the NPPF, which at paragraph 35 states "Plans are considered sound if they are:
● 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 crossboundary 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 this Framework."
1.4 Accordingly, these representations:
● Support the principle of the proposed allocation of land at Nags Head Lane, Brentwood under Policy R06 because the allocation of the site for residential development is justified and consistent with national policy; and
● Object to the allocation's indicative dwelling capacity because it would be unnecessarily restrictive of the deliverable quantum of development and is therefore ineffective. 1.5 Our response to the emerging Plan policies is provided within this report and in the enclosed completed Comments Form at Appendix 1. A discussion of the deliverability of the Site drawing upon technical evidence from the accompanying Design Development Framework prepared by Clague Architects (March 2019) is attached at Appendix 2 of these representations. 1.6 We formally request that our recommended amendment is taken into account for the Regulation 22 submission to the Secretary of State and, in accordance with Section 20(6) of the Planning and Compulsory Purchase Act 2004, hereby formally request that Crest Nicholson Eastern is invited to participate at all hearing sessions relevant to Land at Nags Head Lane, Brentwood. Written representations prepared on behalf of Crest Nicholson Easterm In respect of Policy R06: Land at Nags Head Lane, Brentwood
2.0 Support for the Spatial Policies
Chapter 2. A Borough of Villages
Settlement Hierarchy
2.1 Brentwood falls within Settlement Category 1 in the emerging Plan Settlement Hierarchy, the highest-ranking settlement type. Paragraph 2.12 identifies that Brentwood and Shenfield "offer the most scope for development in accordance with sustainable development principles. Urban extensions into the Green Belt are proposed in specific locations with clear physical boundaries and accessible to local services and transport links."
2.2 Description of Category 1 sites appropriately aligns with the characteristics of Brentwood, in that it provides a wide range of services and employment opportunities, is highly accessible and well served by public transport. We consider Brentwood's placement at the top of the Settlement Hierarchy as appropriate.
2.3 Figure 2.3 (Settlement Hierarchy) states that development opportunities in Category 1 settlements including Brentwood "should focus on making the best use of land, with a higher density". We agree with this approach because it would ensure that the development potential of such suitable sites, including Land at Nags Head Lane, is maximised.
Chapter 3. Spatial Strategy - Vision and Strategic
Objectives
Housing Need
2.4 Housing need is discussed at paragraphs 3.7 - 3.9. In planning for residential growth, the emerging Plan states its commitment to planning positively to increase the supply of new homes. The emerging Plan states it will allocate land to exceed the identified local housing need to provide flexibility in the supply and delivery of sites.
2.5 We support the approach to significantly boost the supply of new housing because it demonstrates that the Plan is positively prepared. This should mean that at the site-specific level, allocations for development, including the Land at Nags Head Lane, should seek to deliver the maximum quantum of development possible, taking account of site constraints and masterplans where applicable.
Transit-orientated Growth and the Growth Areas
2.6 Paragraphs 3.11 and 3.21-3.22 recognise the existing pattern of development and the presence of two key infrastructure corridors and that these inform the spatial approach to growth in the emerging Plan. These are the Central Brentwood Growth Corridor, comprised of the A12, the Great Eastern Main Line to London Liverpool Street and the new Elizabeth Line; and the Southern Brentwood Growth Corridor comprised of the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
2.7 Allocating development in these transit corridors ensures that new homes will be sustainably located, linked to existing service centres through proximity and accessibility to strategic transport infrastructure. We consider this an appropriate strategy.
2.8 Allocation of Land at Nags Head Lane fits appropriately with this approach because it falls within the Central Brentwood Growth Corridor. The Bull bus stop is less than 100m from the Site, with routes into Brentwood town centre and Romford. The Site is less than 2 miles from Brentwood town centre and is within 500m of local shops, pubs and a health club. The site is easily accessible from the A12 and M25 and avoids directing vehicular traffic via the town centre of Brentwood. It is therefore a highly suitable site, sustainably located, with accessibility to a wide range of services, facilities and sources of employment reflected in its location within Settlement Category 1 in the emerging Plan Settlement Hierarchy.
Borough Gateways
2.9 In considering spatial development principles, paragraphs 3.25 - 3.26 set out the aspiration for key allocations to deliver gateways that contribute to enhancing a positive impression of the Borough through public art and/or public realm improvements. Figure 3.3 identifies key gateway locations where developments within the local vicinity should enhance the positive impression of Brentwood upon arrival and for those passing by. We note this inclusion, also noting that Land at Nags Head Lane is located close to the east of the identified gateway at Brook Street. We acknowledge this policy intention and Crest Nicholson is prepared to make proportionate and reasonable contributions to enhancements to the Brook Street gateway as part of a planning permission for development of the site.
2.10 Paragraph 3.26 further recognises that sites in key gateway locations offer an opportunity to deliver schemes with higher densities. We support this intention because it would make efficient use of land in accordance with NPPF paragraphs 122 and 123.
Chapter 4. Managing Growth
Policy SP02: Managing Growth
2.11 This policy seeks to direct development to the site allocations set out in the Local Plan and within the highly accessible locations along transit/growth corridors. Land at Nags Head Lane would accord with both of these principles, so we support this policy.
Chapter 6. Housing Provision
Policy HP03: Residential Density
2.12 Pursuant to the above, this policy seeks to define appropriate residential development densities with the caveat that individual schemes should employ a design-led approach to determine an appropriate, site-specific density. Generally, a density of 35 dwellings per hectare or higher will be sought on sites outside of town centres, district shopping centres and local centres. We consider that adopting standards such as this is appropriate, because it would ensure that land is used as efficiently as possible, in accordance with NPPF paragraph 123 which seeks to avoid houses being built at low densities in areas where there is an existing shortage of land for meeting identified housing needs, such as Brentwood.
Chapter 8. Natural Environment
Policy NE13: Site Allocations in Green Belt
2.13 We support the release of sites from the Green Belt for development as a justified approach given the lack of alternatives in the Borough. This is consistent with national policy, namely paragraph 136 of the NPPF, which makes allowance for the alteration of Green Belt boundaries through the preparation or updating of Plans where exceptional circumstances are fully evidenced and justified.
2.14 BBC recognises that exceptional circumstances exist and warrant the release of Green Belt to accommodate the Borough's housing need. As the Borough does not have any non-Green Belt greenfield land that falls outside of existing settlement boundaries, it falls on Green Belt land to accommodate a proportion of the overall housing requirement. BBC does not have sufficient available brownfield land that could deliver the Borough's housing requirements in a manner that would accord with other policy objectives. It would not be possible to develop brownfield sites alone at such high densities in a manner that would not cause detrimental impacts to the Borough's character or compromise the ability to deliver a broad mix of housing in accordance with Strategic
Objectives including SO1 and SO3.
2.15 Land at Nags Head Lane represents an entirely logical development site as an urban extension to development on the south-west of Brentwood. Physically enclosed between Nags Head Lane, the A1023, existing business and residential units and the railway line, the Site makes a "moderate" contribution to the purposes of including land within the Green Belt according to the BBC Green Belt Study (November 2018). It should however be noted that the assessments of alternative sites range predominantly from moderate to high and the Site is therefore among the least sensitive performing Green Belt sites against the purposes of including land in the Green Belt, justifying its release for allocation. Releasing sites such as this takes pressure from other land parcels that perform a more important Green Belt function and minimises the impact on the Green Belt as far as is possible, consistent with national policy.
3.0 Comments on Policy R06: Land at Nags Head
Lane, Brentwood
In Principle Support
3.1 We fully support the principle of allocating this Site for development. Crest Nicholson Eastern is committed to the delivery of the Site in accordance with policy criteria B (Development Principles) and C (Infrastructure Requirements) as discussed in greater detail below.
The Site is strategically well-placed
3.2 The Site is located on the south-western edge of Brentwood, in the south-west of the Borough. Firmly within the Central Brentwood Growth Corridor, the Site is well connected to strategic transport infrastructure comprised of the A12, linking to Chelmsford in the north-east and Romford to the south-west, and the Great Eastern Mainline railway to London Liverpool Street. Brentwood benefits from a station on this railway line, which is approximately 1.7 miles from the Site. The new Elizabeth Line will also serve this corridor with a station in Brentwood, providing further connections across London to Reading and Heathrow to the west. The site accords with the Local Plan's strategic objectives by locating development in the growth areas and main transit corridors.
3.3 The Site is located close to the key gateway location at the junction of the A12 and the M25 as identified in Figure 3.3 of the emerging Plan. Development on the edge of Brentwood would positively contribute to the sense of arrival to the town and this Site would represent an obvious candidate to fulfil BBC's Local Plan aspiration to contribute towards enhancing a positive impression of the Borough. Crest Nicholson Eastern is committed to ensuring this will be achieved at the appropriate stage of developing the proposals.
The Site is suitable
3.4 The site is served by local shops, pubs, restaurants and a health club within a 5-minute walk. There are bus stops located opposite the site with routes into the town centre, less than 2 miles away. Land at Nags Head Lane therefore benefits from excellent sustainability credentials, reflected in BBC's decision to allocate the site for residential development.
3.5 The site is very well enclosed with established permanent boundaries on all sides. It is bounded to the west by Nags Head Lane, the south by a railway cutting, the east by existing dwellings at Mascalls Gardens, and the north by commercial uses and residential plots. The site consists of private fields sub-divided by established trees and hedgerows, making only a "moderate" contribution to the purposes of including land within the Green Belt according to the BBC Green Belt Study (November 2018). It should be noted that the assessments of alternative sites range predominantly from moderate to high and the Site is therefore among the least sensitive performing Green Belt sites against the purposes of including land in the Green Belt Contribution towards the 5-year housing land supply
3.6 We note that the Housing Trajectory contained in Appendix 1 of the emerging Plan anticipates housing delivery of the allocation from the years 2021/22 to 2025/26. As the accompanying Design Development Framework demonstrates that the Site is unencumbered in all respects, we consider that development could be delivered even earlier than this but nevertheless BBC's trajectory still falls within the five-year housing supply timeframe, so we concur with its general assumption and its accordance with NPPF paragraph 73 which seeks local planning authorities to identify an adequate supply of housing in the short term.
Crest Nicholson's credentials
3.7 The Site is controlled in its entirety by Crest Nicholson Eastern and is available and deliverable now to contribute to meeting the local housing need requirements in the emerging Plan and BBC's five-year housing land supply. Crest Nicholson is based locally in Brentwood and has a 50-year heritage of delivering community focused development. Crest prides itself on its focus for high quality design which has been recognised in its awards for National Housebuilder of the Year, twice in the last three years. Other recent accolades include Planning Magazine's Best National Housing Scheme over 500 homes, Evening Standard's Best Small Development and the Sunday Times' winner of the Outstanding Housing and Landscaping category.
Compliance with the draft Policy's Development Principles
3.8 Policy R06 sets out policy criteria to be considered when developing detailed proposals for the Site. These are set out in bold text below and are fully supported, with the exception of criterion A which is not listed here because it is discussed separately from paragraph 3.16 below. Our design response is summarised beneath each criterion:
B. Development Principles
a. Vehicular access via Nags Head Lane.
The accompanying Design Development Framework demonstrates that a suitable vehicular access would be achievable via Nags Head Lane.
b. Provision for pedestrian and cycle connections.
The Design Development Framework shows that a network of pedestrian and cycle connections would be provided.
c. Provision for public open space.
The indicative masterplan shows that a network of high quality public open space ould be provided.
d. Provide for sensitive landscaping along the north and eastern boundaries adjoining existing commercial development and residential dwellings Extensive landscaping is integral to the proposals for the Site, predominantly focused on the boundaries and along strategic green infrastructure corridors within the Site linking the public open spaces. The indicative masterplan shows green buffering along the northern and eastern boundaries adjoining existing commercial and residential development.
C. Infrastructure Requirements
a. The site is located within a Critical Drainage Area. This development may have the potential to impact on the Critical Drainage Area in respect of surface water flooding. As a result of this, the site is likely to require an individually designed mitigation scheme to address this issue.
The proposed drainage strategy for the Site includes Sustainable Drainage Systems (SuDS) such as permeable paving, swales and ponds to alleviate the risk of surface water flooding associated with the Site's location within a Critical Drainage Area.
The allocation is deliverable
3.9 The accompanying indicative masterplan demonstrates that a scheme for approximately 150 new homes could be delivered on the Site. This takes account of specialist evidence in respect of landscape, access, utilities, drainage, noise and heritage as summarised in the accompanying Design Development Framework.
3.10 The masterplan proposes to retain and enhance the existing vegetation structure along the southern boundary of the Site, along Nags Head Lane to provide a robust edge to the development parcel and filter views into the Site, incorporate a sequence of open spaces and SuDS, retain the internal tree and hedgerow structure where appropriate as part of the internal network of green corridors and to plant trees along contours to filter views from the north (across the valley) and to contribute to amenity value within the Site.
3.11 In respect of access, the potential impact of development traffic on the operation of the Brook Street/Nags Head Lane/Wigley Bush Lane signal junction has been assessed. Whilst the forecast increase in traffic through the junction would be imperceptible, consideration has been given to modifications to improve the future operation of this junction. A proposed improvement scheme has been assessed, which comprises an additional short lane for ahead and left traffic on the Wigley Bush Lane approach, increased kerb radius and exit taper for the left turn into Wigley Bush Lane that allows the stop line to be moved closer to the junction, and a pedestrian crossing on the eastern arm of Brook Street. Junction capacity analysis has shown that the proposed improvements would more than mitigate the impact of development traffic, the result being an overall net benefit to junction capacity. The scheme would be compliant with policy guidance on transport and land use planning at both a national and local level and would have a positive impact in terms of junction capacity and pedestrian connectivity.
3.12 National Grid has confirmed a High Pressure (HP) Gas Main runs beneath the south west corner of the Site. The illustrative masterplan shows that a 28m corridor has been provided above the HP Main to allow for future access and maintenance and limit the risk of damage to the main. Following discussions with National Grid, the Health and Safety Executive has confirmed in writing that they would not object to the current indicative layout if submitted seeking planning permission.
3.13 A preliminary noise assessment has been undertaken to assess impacts arising from primary noise sources on the M25, A12, A1023, Nags Head Lane and railway noise from the adjacent Great Eastern Mainline. The preliminary assessment shows that no single noise source is dominant and that with appropriate layout and noise treatment to the most exposed properties, both internal and external ambient noise levels would be within the desirable range and would meet with applicable
standards.
3.14 The above demonstrates that Crest Nicholson has given due consideration to the deliverability of the allocation and proposes a responsive and well-designed masterplan.
3.15 Taking account of the above we fully support the principle of the Site's proposed allocation.
Objection to the amount of development
3.16 Policy criterion A. states that the site will provide "around 125 new homes of mixed size and type". We consider that this underplays the deliverable quantum of development the Site could accommodate and therefore object to this strand of the policy requirement because the Policy is
ineffective.
3.17 The Site has been proposed for allocation in the emerging Plan since the Draft Regulation 18 iteration published for consultation in 2016, but the original draft allocation was for the delivery of around 150 dwellings. Indeed, if the residential density standard of 35 dwellings per hectare from Policy HP03 is applied to the net developable area identified in the draft allocation of 4.35 hectares, the indicative dwelling yield would be 152.25 dwellings per hectare.
3.18 As emerging Policy HP03 requires (as we have discussed at para 2.12 above), a design-led approach to determining the appropriate, site-specific residential development density has been undertaken for the Site. The accompanying Design Development Framework articulates how approximately 150 dwellings could be delivered on the Site in a generously landscaped scheme incorporating a network of public open space incorporating SuDS features and a locally equipped area of play.
3.19 The BBC Sustainability Appraisal (SA) provides justification for the reduction in units onsite. At paragraph 9.7.2 it states:
"Focusing on proposed changes to the spatial strategy since 2016, points to note are -
● The proposal to reduce the number of homes delivered at Land east of Nag's Head
Lane is supported, given proximity to several listed buildings at Brook Street."
3.20 And at 9.10.2 it states:
"Finally, it is noted that a decision was taken to reduce the quantum of homes (C3) delivered at all four of the Green Belt sites proposed by the 2016 Draft Plan, namely Land off Doddinghurst Road, Land east of Nags Head Lane, Land at Honeypot Lane and Officers Meadow. The Landscape Cpacity Study finds three of these sites to have "medium" capacity, such that a decision to reduce the quantum of homes is tentatively supported; however, Land off Doddinghurst Road is identified as having "medium-high" landscape capacity."
3.21 We consider that these statements are not justified. Whilst the Nag's Head Inn is a Grade II listed building, the Built Heritage Assessment previously submitted with our Regulation 18 representations demonstrates that it once stood as a rural building surrounded by fields and outside the tiny hamlet of Brook Street, but today it is experienced as a road-side public house in the vicinity of residential and commercial development. The area to the south of the Inn, where the Site is located, is still characterised by fields subdivided by hedgerows and trees, however the visual relationship between the Inn and the fields that make up the Site is far less apparent since
topographical features, such as thick hedgerow that border Nags Head Lane, obscure the views. Furthermore, the significance of the Inn is considered to lie within its historical and architectural value. The visual relationship between the Inn and the Site is far less than the visual connectionbetween the Inn and the fields to the south-west, which are directly behind the listed building.
3.22 Accordingly, the impact of Crest Nicholson's accompanying development proposals, with mitigation incorporating retained vegetation, contouring and open green space close to the listed building, mean that the visual impact of the setting of the listed building would be minimal, resulting in only a minor level of less than substantial harm. Given the need to promote sustainable patterns of development when Green Belt boundaries are being re-drawn (NPPF para 138), we consider the arbitrary reduction in unit numbers is not properly justified and should be amended to reflect what could reasonably be achieved on the site, taking account of Crest Nicholson's masterplanned approach.
3.23 With landscape considerations at the forefront of the design process, delivery of approximately 150 dwellings on the Site is demonstrated to the fully achievable without significant harm to the landscape in the accompanying Design Development Framework. Contained within the Design Development Framework is a summary of a Landscape Visual Impact Assessment, setting out the key landscape characteristics and the principal considerations for the identification of opportunities and constraints on the Site. This LVIA concludes that the scheme can deliver approximately 150 dwellings whilst mitigating landscape impacts effectively. The detail of the design approach taken to achieve this is discussed further in the section below.
3.24 Having taken the above design-led approach and determined that a quantum of development of approximately 150 dwellings is entirely achievable, the emerging Plan allocation should reflect this in order to ensure best use of land and maximise the development potential. The policies we have commented on above demonstrate a clear intention of BBC to seek to deliver dwellings beyond the local housing need target and this is reflected in national policy, where the NPPF requires the highest density possible on sites, particularly in areas where the land supply is significantly constrained as is the case in the predominantly Green Belt Borough of Brentwood.
3.25 We are aware that since the earlier iterations of the emerging Plan, the quantum of development proposed in the Dunton Hills Garden Village strategic allocation has increased from 2,500 dwellings in the emerging Plan period to 2,700. Other allocations, including this site which is deliverable in the short-term, should similarly seek to maximise delivery in line with the residential density standards and the design-led approach in Policy HP03 as the appropriate method for assessing the deliverable dwelling yield.
3.26 We recommend that Policy R06 reinstates the Draft Local Plan allocation quantum of approximately 150 dwellings. This would ensure that the emerging Plan is positively prepared in its ambition to maximise the delivery of new homes above and beyond the local housing need target, justified in its strategy for ensuring the best use of land for development and consistent with national policy in delivering an optimum residential density, particularly in an area with a significantly constrained land supply.
Changes necessary to make the Plan sound
3.27 Taking account of the above, we recommend that Policy R06 criterion A reinstates the Draft Local Plan's proposed quantum of development for the Site. Accordingly, it should say "provision for approximately 150 new homes of mixed size and type".
4.0 Conclusion
4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in response to BBC's emerging Plan consultation in respect of the Site.
4.2 Crest Nicholson controls the land at Nags Head Lane, Brentwood, which is proposed for allocation under Policy R06.
4.3 We:
● Support the principle of the proposed allocation of Land at Nags Head Lane, Brentwood under Policy R06 because the allocation of the site for residential development is justified and consistent with national policy; and
● Object to the allocation's indicative dwelling capacity because it would be unnecessarily restrictive of the deliverable quantum of development and is therefore ineffective.
4.4 We fully support the principle of the allocation of the Site as a positively prepared and justified policy. Allocating sites to exceed the identified local housing need is consistent with national policy, whereby housing targets are viewed as a minimum and should be exceeded where possible to ensure flexibility in housing delivery. The Site is a logical and sustainable development site to contribute dwellings towards achieving the Local Plan strategy, well related to the settlement of Brentwood and within the Central Brentwood Growth Corridor with excellent links to strategic transport infrastructure.
4.5 We object to the quantum of development quoted in the Site allocation. The Site has been included as an allocation in the emerging Plan since 2016 and the original allocation planned for 150 dwellings, based on our masterplanned approach to development set out in the accompanying Development Framework Document. The reduction to 125 dwellings in the Pre-Submission Local Plan does not align with the technical evidence and design work accompanying these representations, that demonstrates that the Site can appropriately accommodate approximately 150 dwellings taking account of the site-specific constraints and opportunities. In light of emerging Plan Policy HP03, the density of development should be maximised through a design-led approach. The quoted quantum of 125 dwellings also falls short of the standard density figure of 35 dwellings per hectare stated in Policy HP03.
4.6 In order to make the Local Plan sound, we recommend that BBC reinstates the Preferred Options draft Local Plan quantum of the proposed Site allocation to approximately 150 dwellings, to make better use of the land and maximise delivery.
4.7 Subject to the above amendment, we consider the emerging Local Plan satisfies the tests for soundness set out in paragraph 35 of the NPPF.

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Partnership University NHS Foundation Trust ("EPUT") in response to Brentwood Borough Council's ("BBC") public consultation on the Regulation 19 Pre-Submission Local Plan ("the emerging Plan") in respect of land off Warley Hill, Warley ("the Site"). The land the subject of these representations is shown on the accompanying Site Location Plan at Appendix 1.
1.2 EPUT owns the Site which is the subject of a proposed allocation in the emerging Plan for the development of around 43 dwellings. Primarily, the consultation seeks responses regarding the soundness of the emerging Plan as set out in the National Planning Policy Framework (NPPF), published in February 2019.
1.3 Our comments on the emerging Plan are made having regard to the NPPF, which at paragraph 35 states "Plans are considered sound if they are:
● 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 rossboundary 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 this Framework."
1.4 Accordingly, these representations fully support the proposed allocation of land off Warley Hill under Policy R09 because the allocation of the site for residential development is justified, effective and consistent with national policy.
1.5 Our response to the emerging Plan's strategic policies is provided below in the following section, with our comments on the proposed site allocation at Policy R09 thereafter. These representations are supported by:
● A completed version of the Comments Form at Appendix 2 of this report; and
● Urban Design Strategy at Appendix 3 of this report.
2.0 Our Support for the Strategic Policies
Chapter 2. A Borough of Villages
Settlement Hierarchy
2.1 Warley falls within Settlement Category 1 in the emerging Plan Settlement Hierarchy, the highest anking settlement type. Paragraph 2.11 identifies that the Brentwood Urban Area, which includes Warley, and Shenfield offer the most scope for growth in accordance with sustainable development principles. Urban extensions into the Green Belt are proposed in specific locations with clear physical boundaries and accessible to local services and transport links.
2.2 Category 1 sites are described in Figure 2.3 as "providing a wide range of services and opportunities for employment, retail, education, health and leisure facilities to the immediate residential areas as well as to the wider population in the borough. They are typically highly accessible and well served by public transport provision, including rail services, and existing infrastructure."
2.3 This description appropriately aligns with the characteristics of Warley as part of the Brentwood Urban Area, in that it provides a wide range of services and employment opportunities, is highly accessible and well served by public transport - this is demonstrated by being only 800m from Brentwood mainline / Crossrail station. We consider that Brentwood Urban Area's placement at the top of the Settlement Hierarchy, including Warley, is appropriate and justified.
Chapter 3. Spatial Strategy - Vision and Strategic
Objectives
Housing Need
2.4 Housing need is discussed at paragraphs 3.7 - 3.9 of the consultation document. In planning for residential growth, the emerging Plan states its commitment to planning positively to increase the supply of new homes. The emerging Plan states it will allocate land to exceed the identified local housing need to provide flexibility in the supply and delivery of sites. We support the approach to significantly boost the supply of new housing because it demonstrates that the Plan is positively prepared.
2.5 The flexibility benefits of allocating sites to exceed the identified local housing need can only be realised if the supply of those sites is not unduly restricted to arbitrary time periods. The Local Development Plan Housing Trajectory identifies anticipated delivery timescales for allocated sites, but this should not prejudice the early delivery of sites anticipated to be built out later in the emerging Local Plan period. In order to be considered positively prepared, allocated sites should be delivered as soon as they are available.
Transit-orientated Growth and the Growth Areas
2.6 Paragraphs 3.11 and 3.21-3.22 recognise the existing pattern of development and the presence of two key infrastructure corridors and that these inform the spatial approach to growth in the emerging Plan. These are the Central Brentwood Growth Corridor, comprised of the A12, the Great Eastern Main Line to London Liverpool Street and the new Elizabeth Line/Crossrail; and the Southern Brentwood Growth Corridor comprised of the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station.
2.7 Allocating development in these transit corridors ensures that new homes will be sustainably located, linked to existing service centres through proximity and accessibility to strategic transport infrastructure. We consider this an appropriate and justified strategy.
2.8 Allocation of Land off Warley Hill fits appropriately with this approach because it is located within the Central Brentwood Growth Corridor, approximately 800 metres from Brentwood mainline / Elizabeth line/Crossrail station. Warley Hill, Albert Street and Walter Boyce Centre bus stops are all less than 100m from the Site, with routes into Brentwood town centre and Romford. The Site is less than 2 miles from Brentwood town centre, which offers public transport routes to Grays, South Ockendon, Chelmsford city centre, Basildon town centre, Billericay and Shenfield among other destinations. It is within 300m of a local supermarket, petrol station, sandwich bar, GP surgery, primary school and employment opportunities. The site is easily accessible from the A12 and M25.
2.9 Land off Warley Hill is therefore a highly suitable site, sustainably located in the heart of the Central Brentwood Growth Corridor, with accessibility to a wide range of services, facilities and sources of employment reflected in its location within Settlement Category 1 in the emerging Plan Settlement Hierarchy. With such infrastructure already in place around the Site, delivery of dwellings can commence imminently, and the Site should not be held back to latter parts of the emerging Local Plan period in line with the Local Development Plan Housing Trajectory.
Chapter 4. Managing Growth
Policy SP01 Sustainable Development
2.10 This policy advocates a positive approach to considering developments that accord with the presumption in favour of sustainable development as set out in paragraph 11 of the NPPF. Clearly this is consistent with national policy and we support this approach. Paragraph C of the policy aligns with the NPPF requirement for development that accords with the emerging Local Plan to be approved without delay unless material considerations indicate otherwise. Land off Warley Hill is a proposed allocation and a planning application brought forward for the development of the site in accordance with this and should therefore be approved without delay.
Policy SP02: Managing Growth
2.11 This policy seeks to direct development to the site allocations set out in the Local Plan and within the highly accessible locations along transit/growth corridors. Land off Warley Hill would accord with both of these principles, so we support this policy.
Chapter 8. Natural Environment
Policy NE13: Site Allocations in Green Belt (8.113)
2.12 We support the release of sites from the Green Belt for development as a justified approach given the lack of alternatives in the Borough. This is consistent with national policy, namely paragraph 136 of the NPPF, which makes allowance for the alteration of Green Belt boundaries through the preparation or updating of Plans where exceptional circumstances are fully evidenced and justified.
2.13 BBC recognises that Green Belt release is necessary to meet the Borough's housing needs. BBC has insufficient available brownfield land within existing urban areas to deliver this need. It falls on Green Belt land to accommodate a proportion of the overall housing requirement. Within this context it therefore follows that the most suitable available brownfield sites within the Green Belt should be allocated for residential development.
2.14 Land off Warley Hill represents an entirely suitable development site as an urban extension to development on the south of Brentwood Urban Area. With existing residential and commercial development to the south and east, the former Warley Hospital buildings to the north-west and Pastoral Way to the north, the Site is identified as making only a "moderate" contribution to the purposes of including land within the Green Belt according to the BBC Green Belt Study (November 2018). It should be noted that the assessments of alternative sites range predominantly from moderate to high and the Site is therefore among the least sensitive performing Green Belt sites against the purposes of including land in the Green Belt, justifying its release for allocation.
Releasing sites such as this takes pressure from other land parcels that perform a more important Green Belt function and minimises the impact on the Green Belt as far as is possible, consistent with national policy.
3.0 Our Support for Policy R09: Land off Warley Hill
3.1 We fully support the allocation of this Site for residential development and EPUT is committed to the delivery of the Site in accordance with the criteria set out in policy R09. This is for the reasons elow.
The Site is surplus to NHS requirements
3.2 The Site is sustainably located, previously developed, surplus to its former public sector requirements and is currently vacant. It contains 6 buildings with associated outbuildings and structures. These buildings were formerly used to support the provision of NHS services and was formerly part of the wider Warley Hospital site that has now been redeveloped for housing. The Site was originally developed in the 1930s and initially provided staff accommodation but more recently the existing buildings have also been used for various NHS health care-related purposes, including a drop-in service and care for people with learning difficulties. This was the case up until February 2012 when the need for the facility by the NHS ceased and the properties were vacated.
3.3 Essex Partnership University NHS Trust (EPUT) currently maintains the Site but the prolonged vacancy has increased the risk of the following issues occurring:
● Vandalism of the buildings;
● Anti-social behaviour;
● Unauthorised occupation of the buildings;
● Neighbouring amenity being jeopardised;
● Vermin nuisance to local residents; and/or
● Landscaping / trees becoming overgrown.
3.4 These are practical reasons to support the redevelopment of the Site in the short term. In addition, maintaining and securing the current buildings costs the NHS money and these finances may be better used in a positive way to support improved healthcare services. The Site's removal from the Green Belt is fully justified
3.5 We support the Site's removal from the Green Belt because this is consistent with national planning policy. BBC recognises that exceptional circumstances exist and warrant the release of Green Belt to accommodate the Borough's housing need, in accordance with NPPF paragraph 135. Furthermore, development of the site would contribute towards sustainable patterns of development because the site is located within the heart of the Central Brentwood Growth Corridor, consistent with NPPF paragraph 138, and adjacent to the existing development boundary of the Brentwood Urban Area.
3.6 Paragraph 139 of the NPPF states "when defining Green Belt boundaries, plans should...define boundaries clearly, using physical features that are readily recognisable and likely to be permanent." The B186, Warley Hill, along the Site's eastern boundary, currently forms the Green Belt boundary. The Site is bounded to the west by Clement's Wood, designated as an ancient woodland, secondary woodland habitat and a Local Wildlife Site (LoWS) as described in the Brentwood Borough Local Wildlife Site Review (2012). The woodland's designated status on the western boundary of the Site provides certainty that the redefinition of the Green Belt boundary would follow this feature would be strong, recognisable and permanent, in accordance with NPPF paragraph 139. For ease of reference, we have included an extract of the designated site.
Above: Extract from BBC's Local Wildlife Site Review: Bre61 Clement's Wood - the Site is adjacent to eastern boundary of Clement's Wood.
3.7 The Site is controlled in its entirety by EPUT and is available and deliverable now to contribute to meeting the local housing need requirements in the emerging Plan and BBC's five-year housing land supply. The deliverability of the masterplan proposals for the Site is demonstrated further in the section below.
Compliance with Policy R09's Development Principles
3.8 The extract below shows the allocation within the consultation document:
3.9 Policy R09 also sets out specific Development Principles to be considered when developing detailed proposals for the Site. These are set out and underlined below and we fully support them. Our design response is summarised beneath each criterion:
A. Amount and Type of Development
a. provision for around 43 new homes of mixed size and type:
We fully support this quantum of development and the accompanying Urban Design Strategy demonstrates the deliverability of this quantum of development on the Site.
B. Development Principles
a. vehicular access via Pastoral Way:
The accompanying masterplan in the Urban Design Strategy confirms that vehicular access would be provided via Pastoral Way, where there is a current vehicle access into the Site.
b. preserve the setting of nearby listed buildings:
The Heritage Assessment (summarised within the Urban Design Strategy) concludes that The Firs and Lyndhurst buildings are not listed and can be demolished and Shenleigh, Bramley and Beeches buildings are curtilage listed but are relatively ordinary in appearance and can be demolished. Greenwoods is similarly listed and of architectural value, so is proposed for retention within the scheme. The Tower House at Warley Hospital is also a grade II listed structure and the masterplan includes extensive tree belts and open space in its vicinity to preserve the setting.
c. provide for sensitive landscaping throughout the site and consider the need for the retention of some existing trees on site where appropriate:
The masterplan shows a generously landscaped scheme, with existing trees of value retained and the provision of open space and landscaping throughout.
C. Infrastructure Requirements
a. the site is located within a Critical Drainage Area. This development may have the potential to impact on the Critical Drainage Area in respect of surface water flooding. As a result of this, the site is likely to require an individually designed mitigation scheme to address this issue:
The inclusion of significant areas of landscaping and open space provides opportunities o deliver a bespoke drainage strategy on the Site, which would be designed in detail at he appropriate stage of the development of the proposals.
Constraints and Opportunities
3.10 The accompanying Urban Design Strategy provides an assessment of the opportunities and constraints of the Site, summarised by the following key points:
● Green Belt: The Site is currently located within the Green Belt although the emerging Local Plan proposes its removal and allocation for residential development.
● Arboriculture: There are significant existing trees on the Site with related constraints, particularly Category A and B to be retained and the presence of Tree Preservation Order TPO 10/91. Presence of Ancient Woodland within Clement's Wood.
● Heritage: Presence of heritage building 'Greenwoods' and the setting of the Listed Victorian Water Tower, both of which are considered worthy of retention.
● Biodiversity and open space: There are opportunities to enhance the biodiversity offering on the Site and potentially through the retention of existing green open space. Bats, birds and breeding mammals surveys are necessary which may determine further ecological constraints. These surveys would be undertaken at an appropriate stage of the development of the proposals.
● Cyclists and pedestrians: It is necessary to provide adequate circulation routes and provision for cyclists and pedestrians. Pedestrian connections to Warley Hill are necessary for pedestrians to access public transport bus routes.
Our Design Approach
3.11 In responding to the opportunities and constraints, the detailed design for the Site will provide highquality development in a landscape-led scheme, illustratively depicted in the accompanying Urban Design Strategy at Appendix 3 of this report and as shown below:
Above: Indicative Layout contained within the accompanying Urban Design Strategy
3.12 The indicative masterplan contains the following key features:
● Protection of the existing listed building Greenwoods;
● Creating a more appropriate and grander setting for the adjacent Listed Water Tower through the careful placement of buildings and open space;
● Protection and retention of existing trees, introduction of a new planting scheme and biodiversity measures;
● Integration of a mix of dwelling types including detached houses, town houses, and potentially live-work units;
● Creation of a more curvaceous form to the site access road and greater connectivity to the wider area.
3.13 This demonstrates that a high-quality development scheme incorporating substantial areas of landscaping and open space can be delivered alongside approximately 43 dwellings in a highly sustainable location.
Contribution towards the 5-year housing land supply
3.14 EPUT is fully committed to realising the delivery of the allocated development in the short-term and intends to engage in formal pre-application discussions with BBC imminently with the intention of progressing with an outline application as soon as is reasonably possible.
3.15 BBC's delivery assumptions are that the allocation would be completed within years 2023/4 and 2024/5. Whilst we consider this to be pessimistic, it does fall within the first five years from now so we concur with the assessment that the allocation would contribute towards the five-year supply. Securing this allocation would also ensure that BBC would maintain a strong and varied portfolio of sites that can deliver immediately following adoption of the Local Plan and underpin supply pipeline whilst the large strategic sites undergo the requisite lead-in.
3.16 We therefore fully support Policy R09.
4.0 Conclusion
4.1 These representations have been prepared on behalf of Essex Partnership University NHS Foundation Trust in response to BBC's emerging Plan consultation in respect of Land off Warley Hill. EPUT owns the Site.
4.2 We support the proposed allocation of Land off Warley Hill under Policy R09 because the allocation of the site for residential development is justified and consistent with national policy. 4.3 Allocating sites to exceed the identified local housing need is consistent with national policy, whereby housing targets are viewed as a minimum and should be exceeded where possible toensure flexibility in housing delivery. We also support the proposed policies relating to Growth Areas, the Settlement Hierarchy, Managing Growth and the general approach to directing growth to the most sustainable locations. BBC recognises that exceptional circumstances exist and warrant the release of Green Belt to accommodate the Borough's housing need.
4.4 The Land off Warley hill is located within the heart of the Central Brentwood Growth Corridor, 800m from Brentwood Crossrail station, with good accessibility to key services and facilities as well as the strategic road network, train links to London and other public transport. Several primary and secondary schools are within a reasonable distance and the characteristics of the site, with softly undulating land and an abundance of trees and hedgerows in the setting of the Water Tower heritage asset, offer a unique opportunity for high-quality, aesthetically pleasing homes.
4.5 As vacant previously developed, surplus public-sector land, the site represents an excellent opportunity to deliver homes on brownfield land in line with policy direction in the NPPF and would make best use of land currently costing the NHS money in maintenance and upkeep.
4.6 We therefore support BBC in allocating the Site for residential development.
4.7 Taking account of the above, we would seek to support BBC in its defence of Policy R09 at Examination and we therefore consider it appropriate to participate at the oral part of the Examination in Public to enable discussion of the points we have raised.

1. Representations
Introduction
1.1 These representations have been prepared by Savills (UK) Ltd on behalf of Crest Nicholson Eastern (Crest) in response to Brentwood Borough Council's Local Plan Pre Submission Document (February 2019). The Pre-Submission Local Plan presents the Council's vision for how the borough will develop over the next 17 years, from 2016 to 2033.
1.2 We have previously submitted representations on behalf of Crest to earlier consultation versions of the emerging Brentwood Local Development Plan; including the Strategic Growth Options in 2015, the Draft Local Plan in 2016 and the Draft Local Plan Preferred Site Allocations in 2018.
1.3 These representations are made in relation to the Pre Submission Local Plan (February 2019) and specifically relate to proposed site allocation ref. R26 'Land north of Orchard Piece, Blackmore' which is being promoted by Crest. We note that as part of the previous consultation on the Draft Local Plan in 2016, there was support received from a number of local residents regarding the allocation of this site (ref. 076) for housing.
1.4 A Vision Statement prepared by Thrive Architects is enclosed at Appendix 1. This Statement articulates how approximately 40 dwellings can be delivered as part of a high quality, generously landscaped scheme. The illustrative layout shown carefully considers the site's opportunities and constraints and has been informed by detailed technical studies undertaken in liaison with statutory consultees.
1.5 This report sets out the key areas that Crest wish to make representations upon. In responding to this consultation, these comments take into account Paragraph 35 of the NPPF which requires Local Plans to be sound. To meet this requirement they should be positively prepared, justified, effective and consistent with National Policy.
Settlement Strategy
1.6 The draft Pre Submission Local Plan states at paragraph 2.8 that in accordance with the NPPF, housing in rural areas should be located where it will enhance the vitality of rural communities, to ensure villages grow and thrive.
1.7 As part of the Council's Settlement Hierarchy Assessment, Blackmore is identified as a 'Rural Village' or Category 3 Settlement, which is defined as a village that provides day to day needs for local residents, where limited urban extensions are encouraged to meet local needs.
1.8 However, Blackmore is unique in comparison to other Category 3 Settlements due to its more clearly defined spatial configuration and range of centrally located village services.
1.9 Enclosed by permanent boundaries on all sides, Land North of Orchard Piece makes only a "moderate" contribution to the purposes of including land within the Green Belt (BBC's Green Belt Study, November 2018) and represents the most suitable, logical and obvious extension to any village in the Borough. In contrast, the majority of the Borough's other villages are characterised by more linear, sporadic settlement boundaries preventing logical extensions.
1.10 Pre-Submission Local Plan paragraph 2.16 states minimal amendments are proposed to the Green Belt boundaries surrounding larger villages in order to retain the character of the borough, in line with the spatial strategy. In this respect, it is proposed that site ref. R26 be removed from the Green Belt and allocated for new housing, to help meet an identified need for new housing in rural locations. This is also critical in terms of addressing localised affordability issues and retaining the viability and vitality of local shops and services.
1.11 The Local Plan's approach to releasing Green Belt land (including Land North of Orchard Piece) at Category 3 settlements is therefore considered to be compliant with Para 136 of the NPPF and is fully supported. Housing Need
1.12 The Pre Submission Local Plan seeks to provide 7,752 residential dwellings during the plan period (2016- 2033). These dwellings will be delivered at an average rate of 310 dwellings per year to 2022/23, followed by 548 dwellings per year from 2023/24-2033.
1.13 Draft Policy SP02 'Managing Growth' states that new development within the Borough will be directed towards the proposed site allocations. Green Belt land on the edge of larger villages, such as site allocation ref. R26, is recognised within the draft Plan as making an important contribution to the required housing provision in the Borough.
1.14 As set out in our previous representations (dated March 2016), we still have some concerns about the significant reliance on the proposed development of Dunton Hills Garden Village to meet the Borough's housing need. The Pre-Submission Draft Local Plan states this site would provide 2,700 new homes, which equates to 35% of the borough's housing need. There are concerns in respect of a third of the housing supply coming from one source and it is highly questionable whether such a large scale concept can be relied upon to address the borough's significant housing need.
1.15 This increases the importance of the Borough's smaller site allocations including Land North of Orchard Piece, that are capable of being delivered in the short term.
Land north of Orchard Piece, Blackmore
1.16 These representations strongly support the principle of allocating Land north of Orchard Piece, Blackmore (R26) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore. This approach is entirely appropriate, in accordance with the Settlement Strategy outlined above.
1.17 The proposed site allocation is considered to promote sustainable development, and in accordance with draft Policy SP01 'Sustainable Development' will ensure that the character and setting of Blackmore village is preserved and enhanced.
1.18 An extract of the proposed site allocation (Policy R26) is included below for ease of reference: [see attachement]
1.19 The allocation acknowledges that the site is considered to be deliverable within the next two to three years. This is fully supported.
1.20 Land North of Orchard Piece was initially allocated for housing in the Draft Local Plan (2018) for approximately 40 dwellings. This more closely accords with Policy HP03 of the current Pre-Submission Plan which seeks to "achieve a net density of at least 35 dwellings per hectare net or higher". A density of 35 dwellings per hectare applied to the site's net developable area of 1.52 hectares (as identified in the Plan) equates to 53 dwellings.
1.21 However, the current Pre-Submission Plan reduces the quantum of homes allocated at Land North of Orchard Piece to approximately 30 dwellings.
1.22 The single paragraph justification provided in the supporting Sustainability Appraisal (SA) states that "Ahead of the 8th November 2018 Extraordinary Council meeting the Council worked to explore potential adjustments to the strategy, as previously published, in light of representations received, with the Council reaching the tentative conclusion that, whilst all of the January 2018 allocations remain suitable, there was a need to reduce the number of homes allocated to certain sites38" Footnote 38 then states "Specifically: the yield of the two adjacent sites at Blackmore was reduced by 26 homes to take account of the potential need for surface water flooding measures on site."
1.23 Ardent Consulting Engineers have undertaken detailed technical work relating to flooding and drainage to inform proposals for the site. In terms of drainage the site is located within fluvial Flood Zone 1 (less than 0.1% chance of flooding in any year or a 1:1000 year chance). The Brentwood Strategic Flood Risk Assessment (SFRA - Nov 2018) shows that the Site is in an area that is not vulnerable to groundwater flooding.
1.24 Some residents have noted incidents of surface water ponding along Redrose Lane during excessive periods of rainfall. However, the area noted is beyond the eastern boundary of the site where the watercourse is culverted under Redrose Lane. Given the local topography, the flooding depth in Redrose Lane has a negligible impact upon the site. As a precautionary measure, it is intended that the minimum floor level of the proposed dwellings in the north east corner of the site will be raised by approximately 300mm. In addition, ditches along the boundary of the development could be implemented.
1.25 The engineered Sustainable Drainage System (SuDS) will provide a betterment to the existing situation by managing the flow of surface water discharge rates into the surrounding network. CNE continue to liaise with both ECC and the EA in this regard.
1.26 Therefore, although the principle of the site's allocation is fully supported, the reduction in quantum of homes from 40 to 30 homes does not align with detailed technical evidence, nor is it compliant with Plan Policy HP03 which seeks to maximise the density of development (at a minimum of 35 dwellings per hectare) through a design-led approach.
1.27 The appended Vision Statement articulates how approximately 40 dwellings can be delivered as part of a high quality, generously landscaped scheme, reflective of the existing density and pattern of surrounding residential development. The illustrative layout carefully considers the site's opportunities and constraints and has been informed by detailed technical studies undertaken in liaison with statutory consultees.
1.28 To ensure the Plan is Sound, we therefore request that the wording of the site allocation be amended to reinstate the indicative capacity of the development to circa 40 units.
1.29 Draft Policy R26 states that a minimum of 25% of the proposed dwellings should be reserved for people with a strong and demonstrable local connection or those over 50 years of age, and these dwellings should comprise affordable housing:
1.30 Crest are supportive in principle of this approach, to ensure priority for affordable housing is given to local people. However, there are a number of concerns with the clarity and enforceability of these requirements.
1.31 Firstly, there is no definition of the type or tenure of 'affordable housing' that 25% of the dwellings should comprise. It is not clear if these are affordable dwellings that would be provided by a Registered Provider (RP) or those which would be retained and sold by the developer. If these dwellings are for affordable rent, to be let by an RP, then it would be up to that RP to work with the Council to ensure that the dwellings are reserved for local people. As such, we suggest greater clarification is required
1.32 If affordable housing could comprise other affordable products, such as those in intermediate tenure then it is acknowledged that it would be the developer's responsibility to ensure that 25% of the dwellings are provided to those with a local connection. As such, the Council would need to provide further detail as to how 'residents requiring separate accommodation' or 'close relatives of existing local residents who have a demonstrable need to either support them or be supported by them' would be defined and identified.
1.33 Flexibility should also be built into the wording of this policy to ensure that this provision of 25% dwellings to be reserved for local residents is subject to market demand and that within a certain time frame, if there is no interest in these units from those with a demonstrable local connection, then these units could be provided to alternative occupiers. This would need to be secured in the S106 agreement attached to any planning permission for the site.
1.34 Overall, we strongly support the proposed allocation of this site, which would help to meet an identified local housing need and maintain the character and vitality of an important rural village.
Appendices
Appendix 1: Land North of Orchard Piece, Blackmore - Vision Statement

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Brentwood will be subject to Housing Delivery Test (HDT) assessment on the basis of the minimum Local Housing Need figures until such time that their plans are adopted.

Bellway Homes and Crest Nicholson representations Brentwood Regulation 19 Pre-Submission Local Plan (February 2019)
Merits of our client's landholdings and the Dunton Hills Garden Village
Bellway Homes and Crest Nicholson's landholdings (part of allocation R01) are unconstrained, suitable, deliverable and available. As such the landholding can be brought forward as part of the wider Dunton Hills Garden Village allocation.
Our clients are housebuilders, not land promoters, and are seeking delivery at the earliest opportunity pending suitable access. Crest Nicholson and Bellway Homes will continue to work with officers and Councillors (and other landowners/developers) to help bring forward this key site for meeting local housing needs in South Essex. It is absolutely right that the allocation should not be anchored to the work that will be carried out as part of the Association of South Essex Local Authorities (ASELA) and the emerging Joint Strategic Plan (JSP).
The identification of strategic scale sites to meet Brentwood's housing needs is supported, as is the principle of a new settlement via the Dunton Hills Garden Village Strategic Allocation (Policy R01) and its ambition for the delivery of additional homes beyond the plan period. The allocation represents an efficient use of greenfield land adjudged to be sustainable. Similarly we commend the Council for taking the decision to bring forward strategic greenbelt release alongside a comprehensively planned new settlement.
Our clients would support improved integration with Basildon alongside a landscape solution/approach agreed via a Statement of Common Ground and complementary policy positions (and/or supporting text) in both the Brentwood and Basildon Local Plans. This would help to deliver Dunton Hills Garden Village and the future expansion of West Basildon whilst maintaining separation physically through the provision of publicly accessible green infrastructure and improving connectivity for new and existing residents. Our clients do not support the position taken by Basildon Borough Council and have submitted representations objecting to the draft Basildon Local Plan.
Policy SP02: Managing Growth
Paragraphs 4.11 - 4.21 of the draft plan set out Brentwood's housing need position based upon the application of the standard methodology for calculating a minimum Local Housing Need figure; and the identification of a 20% buffer of housing sites for the first five years of the plan. The plan, at paragraph 1.38, also states that:
"..it may be necessary to review the Brentwood Local Plan, at least in parts, to ensure any opportunities for further growth and infrastructure provision in the Borough identified in the Joint Strategic Plan can be realised."
Our clients support this approach. Brentwood is seeking to meet their identified housing needs in full plus a sufficient buffer in the early part of the plan period. Crucially the draft plan is not using the JSP as a reason for deferring difficult planning decisions. As such, the draft plan is not reliant upon the emerging JSP to meet Brentwood's needs up to 2033. There has been no consultation to date on the JSP (as at March 2019) and it would be wholly unsound to rely upon a future JSP to meet identified needs up to 2033. Our clients support the pragmatic approach set out by Brentwood which is in accordance with the National Planning Policy Framework (paragraphs 11, 16 and 26 - a 'positively' prepared plan that seeks 'opportunities to meet the development needs' of their area and is 'sufficiently flexible to adapt to rapid change').
Our clients would advocate delaying submission of the publication plan until the 2018 affordability ratio data is released by the Office for National Statistics (the data used in the standard methodology for calculating housing need), due for publication in March/April 2019. This would allow time for factual updates to be made to Policy SP02 and housing target. Should submission come before the publication of the affordability ratio data, Brentwood should consider over allocating sites to increase the buffer of sites over for the whole plan period - sufficient to provide flexibility in respect of any increases brought about by the new affordability data published prior to or shortly after submission.
aecom.com
7/14
The recent release of the Housing Delivery Test (HDT) in February 2019 confirmed that Brentwood and all the other ASELA authorities (with the exception of Thurrock) have to identify a 20% buffer to their five year housing land supply and prepare a HDT Action Plan by August 2019. The minimum Local Housing Need figure (produced by the new standard methodology) will be applied to all authorities from 2018/19 for the purposes of the HDT (unless there is a plan that is less than 5 years old). As such Brentwood (and Basildon) will both be subject to HDT assessment on the basis of the minimum Local Housing Need figures until such time that their plans are adopted.
Table 1 (below) shows the HDT results published by MHCLG (19th February 2019) for all Councils that make up the ASELA. This shows housing delivery has only been achieved in one of the past three monitoring years (2016/17) for Basildon and it was never achieved by Brentwood. The HDT results evidence a persistent under delivery of housing in the South Essex region. Brentwood and Basildon are at risk of failing the HDT thresholds in 2019 and 2020. At present, Brentwood is in danger of falling below the 45% threshold this November 2019. This would leave the authority open to the presumption in favour of sustainable development (the 'tilted balance') and susceptible to speculative applications outside of the identified draft allocations. For Basildon there is a real risk that they will also be captured by the presumption in favour of sustainable development (75% threshold) as early as November 2020. Basildon's position is even more precarious given that they have not identified sufficient land to meet their minimum Local Housing Need, let alone a 20% buffer for the first five years, in their previous consultation draft plan.
Table 1 South Essex HDT results (MHCLG, February 2019)
[see attachment]
This illustrates the severity of the housing crisis in South Essex and the pressing requirement for all ASELA authorities to identify sufficient land supply (to meet their needs and a 20% buffer for the first five years) and maintain the plan-led approach. Basildon's failure to allocate sufficient sites to meet housing needs will impact the other ASELA partners (e.g. increased unmet needs in the region).
Duty to Cooperate
The above issues should be addressed as a matter of urgency through Brentwood and Basildon's Duty to Cooperate Statements of Common Ground. A Duty to Cooperate position statement is welcome, although the MOU with the ASELA is insufficient to evidence the detailed Duty to Cooperate matters that need to be addressed with Basildon. A Statement of Common Ground that outlines areas of uncommon ground would be just as valuable in advance of submission of both plans and the forthcoming examinations.
This will help to avoid creating inconsistencies or prejudice any future plan making as part of the ASLEA JSP. If Basildon and Brentwood both wish to avoid the appearance of sprawl along the A127, this can be achieved through a simple Statement of Common Ground and via identical high-level policies (or supporting guidance) in each Local Plan. At present the current policy position does not ensure an integrated approach to delivery of the Garden Village and adjacent sites to the West of Basildon. It is our client's view that a failure to tackle this issue head-on now could stall delivery on Dunton Hills Garden Village. The JSP is not the appropriate vehicle for resolving a planning issue within the emerging Basildon and Brentwood plans; this matter must be resolved prior to submission, of both Local Plans (ideally via a Statement of Common Ground).
Policy NE13: Site Allocations in Green Belt / Policy HP18: Designing Landscape and the Public Realm
Our clients support the strategic release of greenbelt sites in sustainable locations. Dunton Hills Garden Village has followed a robust Green Belt review; Sustainability Appraisal; and site selection process. The draft plan does not allocate land between Dunton Hills Garden Village and West Horndon; therefore it maintains physical separation and avoids the coalescence of the new settlement and existing built up area of West Horndon. To date there is no evidence that it would be possible to meet the Borough's acute housing needs without amending the Green Belt boundaries as proposed in the draft plan.
The Stage III Green Belt Review January 2019 (GBR3) continues the work of the previous two stages. Again the methodology used appears sound and has been consistently applied. GBR3 assesses the DHGV site, Parcel 200, as being Not Contained, exhibiting Significant Separation Reduction between settlements, as being Functional Countryside and of Limited Relationship to Historic Towns. This results in an overall conclusion of Parcel 200 making a moderate to high contribution to the Green Belt. As with the LSCA the scale of DHGV inevitably results in elevated scores.
The Dunton Hills Garden Village allocation (shaded yellow) and wider Green Belt parcel incorporating land West of Basildon in Basildon Borough (shaded red) shown on Figure 1 (below) is an area bounded by the A127, the A128, a railway line and the western edge of Basildon - there are few (if any) examples nationally of more contained and defensible boundary in Green Belt terms.
Figure 1 Green Belt Context: Land West of Basildon (red) and Dunton Hills Garden Village (yellow)
[see attachment]
There would be clear separation maintained between Dunton Hills Garden Village and West Horndon in Brentwood Borough. Paragraph 9.12 is also supported as it recognises that "The B148 (West Mayne) is the eastern road beyond the borough boundary separating the site from the built-up area of Basildon". If Dunton Hills Garden Village and the land West of Basildon (in Basildon Borough) are both allocated it is only logical to remove all of this land from the Green Belt based upon the strong defensible boundaries that exist for both areas. Landscape approach, design principles and physical separation can (as previously discussed) be dealt with via a Statement of Common Ground and complementary Local Plan policies (and guidance) in the respective plans. Policy R01 includes a detailed statutory policy to ensure the new settlement is comprehensively planned via landscape-led approach. This will ensure the development is not simply ribbon development along the A127 and instead an autonomous Settlement Category 2 Garden Village that will complement the existing settlement hierarchy and is well related to the existing communities of Basildon and Laindon and West Horndon.
The Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options October 2018 (LSCA) assigns a landscape capacity to the potential allocations. The methodology used appears sound and has been consistently applied. The LSCA identifies the DHGV site, Parcel 200, as being of high landscape sensitivity, medium - low landscape value and medium - medium low landscape capacity. It is noted that the scale of the strategic options considered make comparison with smaller sites difficult. The scale of DHGV inevitably results in elevated scores.
The site is not the subject of any landscape quality designations that would prevent development. Our clients consider that Policy HP18: Designing Landscape and the Public Realm, in combination with Policy R01(I) clause C, provide an adequate policy framework for guiding a future landscape scheme - including the provision of green infrastructure between R01 and the development of the West of Basildon.
Policy R01: Dunton Hills Garden Village Strategic Allocation
The policy would benefit from being shortened and simplified. Much of the detail could instead be covered in the supporting text. Our clients would recommend a less prescriptive policy in favour of a series of development principles. The policy also recognises the appropriate phasing of infrastructure and mechanisms for delivery. However, our clients have a number of detailed comments to help enhance the clarity and utility of the draft policy.
R01(I)
 Clause B uses the term "self-sustaining" - this is currently an undefined term in the context of the facilities that may be required by future residents. It is likely that services and schooling would also be accessed in Basildon and so the policy should also recognise the importance with connectivity to nearby allocations and settlements in Basildon Borough. Whilst appreciating the need for a garden village to be separate, it should also be appropriately connected and complimentary to nearby settlements.
 There is a slight inconsistency between policy clauses A and D in the use of "around 2,700 homes" and "at least 2,700 homes" in the plan period. Our clients would favour the more positive "at least" in light of the pressing housing needs in the area.
 Policy clause D(c) currently expresses a requirement for employment land as 5.5ha. An alternative approach would be to also reference a jobs figure, employment densities are not fixed and the policy will need to remain flexible to provide the optimum employment solution on the site up to 2033.
 Policy clause D(d) references a co-located Secondary school, but this term is not defined in terms of what facilities could be appropriately co-located or any indication on forms of entry etc. This clause could cross reference to the Infrastructure Delivery Plan that shall remain a living documented capable of being updated as the development of the site evolves.
 Policy clause D(h) states 50% of the "total land area", this term is not defined and may have implications for the net developable area. Without the benefit of a detailed masterplan and Environment Statement supporting an application this requirement appears needlessly onerous and will make the allocation less flexible. We would suggest removal of a specific percentage in advance of further masterplanning and consultation.
R01 (II)
 Policy clause C(f) states: "a green infrastructure buffer / wedge on the eastern boundary with Basildon Borough to achieve visual separation to help significantly improve the landscaped and habitat value thus reinforcing the beneficial purpose and use of the green belt in that zone." This matter needs careful consideration in advance of submission in light of Basildon's representations and their erroneous position on Green Belt coalescence and countryside encroachment in their draft plan (which fails to allocate sufficient land to meet needs). Brentwood should provide further clarity that this separation can be achieved without sterilising large tracts of the allocation. A modest multifunctional green gap running north-south in close proximity to the Borough boundary would be a proportionate response in this location.
 Policy clause D(c) states "pathways through the green and blue infrastructure (GBI) network will be made of permeable material and follow a coherent treatment throughout the village. The pathways will all connect into a circular walk, with interconnected shortcut routes and be signposted offering directions to key destination points". It is premature at this stage to place overly restrictive pathway design where they may be sound place-making reasons for not following this approach in all areas.
 Policy clause I(a) states that emphasis will be given to: "incorporating car sharing clubs and electric vehicle only development". Whilst the principle is supported, this may not be appropriate for all areas of this large allocation and would be overly restrictive.
 Policy clause L(b) includes a small typo for BREEAM. This clause should make clear that BREEAM is for certain types of building only.
R01 (III)
 Clause B states: "The development and phased delivery of DHGV must ensure the timely delivery of the required on-site and off-site infrastructure to address the impact of the new garden village". Whilst supported and the timely delivery on infrastructure is essential in the creation of a sense of community, off-site infrastructure may be beyond the control of the primary land owners/promoter, and risks stalling development if a Grampian condition is envisaged.
An explicit policy clause is urgently required to ensure for a no ransom position. The primary developer must build roads up to the boundary of Crest Nicholson and Bellway Homes landholding. Without this added clause the allocation would be ineffective based upon the tests of soundness.
The Site benefits from the involvement of volume housebuilders which, according to the Letwin Review (2018), leads to a variety in product and higher build out rates. An extensive analysis of national house builder annual reports, conducted by Turley on behalf of Bellway Homes, demonstrates that average delivery rates (per outlet) range from between 40-58 units pa1. There is potential for sites (normally larger sites) to see a number of outlets building new homes at any one time. Additional outlets are sometimes in the form of a different house builder, but it can also be in the form of different products sold from different marketing suites by the same house builder. Crest Nicholson and Bellway Home's landholdings are jointly promoted in order to deliver high quality sustainable developments at pace and will help to achieve the housing trajectory set out in Appendix 1 of the draft plan.
The plan's delivery trajectory relies on increased delivery in the later part of the plan period (partly reliant on infrastructure investment). This emphasises the importance of infrastructure equalisation and removing any ransom scenarios as far as practically possible through statutory policy. In addition, it would be prudent for the ASELA authorities to work together to lever in external funding for reinforcements such as the gas pipeline to enable an alternative access arrangements and internal connectivity that would release more development land for housing and public open space later in the plan period.
R01 Supporting text comments:
 Paragraph 9.30 includes a reference to 'Medium' density- but this is not defined. The allocation location is in close proximity to Basildon and West Horndon and the potential for sustainable modes of transport lends itself to higher densities in district and local centres.
Transport policies B11 - B17
The general approach taken to transport within the Local Plan with the Built Environment policies (BE11 to BE17) is supported and it can be seen that these policies are feeding through into the policies for the site specific allocations.
The evidence base for the Local Plan includes Brentwood Borough Local Plan Transport Assessment (Local Plan TA) dated (October 2018) prepared by PBA and the Infrastructure Delivery Plan (IDP) prepared by the Council. These documents together provides the transport element of the evidence base and support the Council's proposed development strategy including the proposed development at Dunton Hills. They are essential elements of the evidence base and their soundness is not questioned in these representation, however, the conclusions of the Local Plan TA and the IDP need to be better reflected in the Local Plan.
The Local Plan TA sets out the approach to the modelling work, results of modelling and junction assessment, highlights those worse performing junctions that may require mitigations, the sustainable measure proposed and the impact this has on the junction assessment to enable the development sites to come forward. The assessment covers key 27 junctions within Brentwood planning authority.
The assessment assumed that DHGV would provide 2,500 new homes in the Local Plan period along with 5.5ha of employment land. In addition, number of sites located within Basildon Borough Council and Havering Borough Council were included within the reference case scenario in order to accurately assess the impact of Brentwood Local Plan. The West Basildon Urban Extension was included within the reference case assuming provision of 1000 new homes as per 2016 Basildon Local Plan publication.
The Local Plan TA identifies a number of junctions that would need to be improved across the Borough to support the development proposed in the Local Plan. However, the Local Plan Submission Version does not include reference to these. As an example, the following table contains the identified improvements in the surrounding roads to Dunton Hills Garden Village.
Table 2 Results of PBA capacity assessment, Brentwood Local Plan Evidence Base
[see attachment]
While it is clear that some of these improvements would be provided via Essex County Council (ECC) or Highways England as the relevant highway authorities there is no reference made in the Local Plan to them. It would be expected that the evidence base would transfer through to the IDP to be clear on how and when these identified infrastructure improvements would be provided.
As each identified allocated site comes forward to a planning application stage it will define what highway improvements are needed through the Transport Assessment associated with the individual site. However, guidance should be given on what improvements have been identified as part of the Local Plan TA to ensure that the need for them is considered and if they are required then how would they be funded i.e. guidance is needed on the scope for any future Transport Assessments to support developments.
The IDP contains a similar table for highway infrastructure improvements and those relevant to Dunton Hills Garden Village are listed in Table 3 below:
Table 3 IDP Schedule extract.
In addition to four infrastructure requirements relating specifically to DHGV a number of requirements are set out in the IDP for new developments and site allocations coming forward in the Local Plan period. Key improvements to be delivered as part of DHGV development are:
 DHGV: Widening Connectivity - further feasibility studies required to improvements of pedestrian connectivity across the A127 and A128;
 DHGV: Walkways/ Cycleways - provision of a good footway and cycle way network;
 DHGV: Sustainable Transport Infrastructure - provision of cycle hub within the DHGV site; and
 DHGV: Public Realm and Village Square - subject to detailed masterplanning good quality pedestrian centres should be provided.
It is acknowledged within the proposed policy for Dunton Hills Garden Village that reference is made for the need for a Transport Assessment report to be undertaken and this is where the detailed assessment can be made of the highway infrastructure needed to support the proposed allocation. However, there should be some reference to the published evidence base to guide the scope of this work. This is not to say that the identified improvements will be needed, but they should be considered as they have been identified within the evidence base.
Attendance at the examination hearing sessions
Our clients request attendance at the relevant hearing sessions to make verbal submissions in response to matters and questions related to: the Duty to Cooperate; housing numbers and the spatial strategy, landscape, transport, infrastructure, deliverability and the strategic allocations. We reserve the right to make further representations at the examination hearing sessions, should work on Brentwood's Community Infrastructure Levy evolve in respect of any implications on strategic sites and their ability to deliver policy compliant schemes.

1.0 INTRODUCTION
1.1 These Representations on the Brentwood Borough Council Reg 19 draft Local Plan have been prepared on behalf of Croudace Homes who are promoting their site (Officers Meadows - site number 034), which falls within the broader allocation of "Land North of Shenfield". The allocation encompasses several land ownerships, including Sites 158, 235, 087, 263 and 276, as well as the "Officer's Meadow" site (034), all of which make up the allocation Policy R03. It should be noted that Croudace Homes has controlling land interest in Site 034 only, therefore whilst development proposals have taken the other sites into account, this document is in respect of the "Officer's Meadow" site.
1.2 "Land North of Shenfield" was previously promoted through the Reg 18 Local Plan process (see Site Allocations Map Jan 2016 which supported the Draft Local Plan) historically as one of three separate strategic sites, now shown in the Reg 19 draft Local Plan site allocation as one site, "Officer's Meadow and surrounding land" (ref. Policy R03) allocated for residential development. The "Officer's Meadow" site is the focus of these Representations to the Reg 19 draft Local Plan and is hereby referred to as "the Site".
1.3 These representations are submitted to the Local Plan consultation document and set out our support for the Brentwood Borough Council (BBC) Local Plan in terms of the proposed spatial strategy and the identification of the Site as an allocation for growth.
1.4 These representations are focused on the Site allocation and demonstrate that the allocation is "sound" and deliverable having regard to National policy and a number of technical matters for the Site. It also reviews the Local Plan in terms of soundness of the Duty to Co-operate, the proposed spatial strategy (inc. Sustainability Appraisal) and other policies in the Plan including for Development Management purposes.
1.5 These representations are supported by technical reports included as appendices, which, on behalf of Croudace Homes, provide the background evidence to support the allocation and demonstrates it is "suitable", "available", "achievable" and therefore "deliverable". This will be referred to in these representations and it has regard to BBC's Evidence Base. The technical reports prepared by the consultant team, detail matters concerning:
* Transport;
* Landscape/Green Belt;
* Drainage;
* Noise
* Ecology;
* Archaeology; and
* Masterplanning.
* Shenfield High School "All through" education provision proposals.
1.6 The following sections of these representations are set out as follows:
* Section 2.0 - National Policy;
* Section 3.0 - Duty to Co-operate;
* Section 4.0 - Local Plan Strategy;
* Section 5.0 - Policy LP R03 -Land North of Shenfield (Officer's Meadow);
* Section 6.0 - Delivery of Land North of Shenfield (Officer's Meadow);
* Section 7.0 - Soundness of other policies in the Local Plan; and
* Section 8.0 - Conclusion.
2.0 NATIONAL POLICY
2.1 This section provides an overview of the NPPF with particular regard to plan-making. Other policies in the NPPF will also be referred to later in these representations.
i) National Planning Policy Framework
2.2 On 24 July 2018, the revised National Planning Policy Framework (2018 NPPF) was published by National Government, setting out the planning policies for England and how these are expected to be applied in both plan-making and decision-taking. Post 24 January 2019 any plans submitted after this date must refer to the revised NPPF. This document therefore focusses on the revised 2018 NPPF.
2.3 The revised NPPF introduces the Government's standardised methodology for assessing housing needs. For those LPAs which do not submit plans within the NPPF's transitional period, the standard method will apply as a starting point for assessing housing needs.
a) Plan-Making
2.4 The NPPF 2018 (Para 35) sets out the requirement for Local Plans to be examined by an independent Inspector whose role is to assess whether the Plan has been prepared in accordance with legal and procedural requirements, and whether it is "sound". An LPA should submit a Plan for Examination which it considers is "sound" - namely that it is:
* Positively prepared (as a minimum seeking to meet the area's objectively assessed needs);
* Justified;
* Effective; and
* Consistent with national policy.
2.5 These representations will assess the Pre-Submission Local Plan against the tests of soundness, as above. The next section details the Duty to Co-operate in this regard.
3.0 DUTY TO CO-OPERATE
3.1 This section considers the legal compliance and procedural matters associated with the Local Plan with regard to the "Duty to Co-operate".
i) Policy Framework
3.2 The "Duty to Co-operate" as provided for in Section 110 of the Localism Act 2011 came into effect on 15 Nov 2011. The "duty" was introduced under the 2011 Act to address the impact of the loss of the "top-down" effect from the Regional Strategy and to offer a transparent way in which LPAs should relate to one another on cross boundary issues. The "duty" is now shared between LPAs requiring them to collaborate on cross-boundary matters and issues of sub-regional and regional importance, especially housing provision and infrastructure issues.
3.3 The NPPF 2018 (Paras 24-27) is clear in directing LPAs as to the importance of the "Duty to Co-Operate" and the pro-active approach necessary to ensure a collaborative approach to reflect individual local plans.
ii) BBC's 'Duty to Co-Operate' (DtC)
3.4 The NPPF recommends that where a Housing Market Area (HMA) extends across more than one local authority plan makers should assess need for housing for the whole HMA, rather than just the individual authority. The SHMA (Oct 2018) sets out that Brentwood District is a self-contained Housing Market Area (HMA). On this basis, no further joint evidence base documents were commissioned, but strategic work continues with South Essex Councils.
3.5 The Objectively Assessed Need (OAN) for BBC amounts to 380 dwellings per annum (dpa) as the SHMA advises that the Council plans on the previous OAN evidence (despite referring to 350 dwellings per annum (dpa) following the current guidance, for the period 2019-2029). In addition, the Council propose additional land allocations over and above "need" (20% above 380 dpa). This approach is welcomed in the SHMA guidance, as overprovision should provide additional flexibility in the supply and delivery of sites.
3.6 Since the draft Brentwood Borough Council Reg 19 Local Plan has been published, the PPG HENA details the standard method for assessing housing need and now clarifies that the 2014-based household projections published by the Office for National Statistics should be used to set the 'baseline' for the standard method calculation. The standard method number for Brentwood is 452 dpa.
3.7 The OAN is 7,752 dwellings during the Plan period (2016 - 2033) and it is welcomed that the Local Plan is seeking to meet this need in full (and potentially overprovide). This is addressed further in the housing strategy section to follow. The Plan also provides an equitable distribution of new homes across the HMA and this will be addressed under the Sustainability Appraisal.
3.8 It is evident that BBC has engaged with neighbouring authorities regarding cross-boundary matters as well as meeting housing need, as set out in the Duty to Co-operate Brentwood Position Statement (February 2019).
3.9 As part of the DtC the Borough would normally need to consider whether it is a sustainable location for unmet cross boundary need. However, as Brentwood is a Green Belt authority (89% is Green Belt), it is unlikely that Brentwood will be in a position to accept any unmet housing need from the South Essex housing market area. The Essex neighbours (Chelmsford and Epping Forest) both have plans submitted for examination that are not reliant on Brentwood accepting any of their housing growth.
3.10 Ongoing Duty to Cooperate work continues with South Essex as part of a strategic growth study and participation in a Joint Strategic Plan.
3.11 The Association of South Essex Local Authorities (ASELA) memorandum of understanding was recently signed by Basildon Borough Council, Brentwood Borough Council, Castle Point Borough Council, Essex County Council, Rochford District Council, Southend on Sea Brough Council and Thurrock Borough Council (Jan 2018). This highlights the constraints and challenges facing other local authorities in terms of meeting their housing needs, and emphasises the importance upon BBC in terms of meeting its own needs in full. We therefore welcome BBC's aspirations in seeking to meet its own needs and indeed in seeking to provide to some flexibility too.
3.12 Duty to Co-operate discussions have confirmed that immediate neighbouring authorities are aiming to meet OAHN within their boundaries, but some will have difficulties in this regard. However, as Brentwood is a Green Belt authority, it is unlikely that Brentwood will be in a position to accept any unmet housing need from the South Essex housing market area.
3.13 To ensure the Local Plan is justified and effective (NPPF, para 35), it is considered that the above issues should continue to be updated in the evolving DtC Statement (February 2019).
3.14 The Council needs to continue to have regard to neighbouring authority plans and adequately co-operate with neighbouring authorities, rather than awaiting the future joint strategic plan, as well as Essex County Council plans, and strategies of other relevant bodies.
3.15 This working can be further supported by the Duty to Cooperate meetings dealing with the strategic planning issues relating to the South East Essex 2050 Programme. Also, the Association of South Essex Local Authorities (ASELA) Statement of Common Ground which includes a commitment to joint working through the preparation of a Joint Strategic Plan for South Essex.
3.16 It is recommended that BBC continues to embrace opportunities to work with the other members of ASELA, as well as producing statements of common ground with its neighbouring authorities, which is a key element of plan preparation, in order to secure a "sound" Local Plan which meets the requirements of the Duty to Co-operate.
4.0 LOCAL PLAN STRATEGY
4.1 This section examines and provides commentary on the proposed spatial strategy in the Local Plan, insofar that it relates to the housing and employment provision, and the allocation of strategic sites for growth including within the Green Belt.
4.2 First, we set out our representations on the Sustainability Appraisal for the Local Plan.
a) Sustainability Appraisal
4.3 The BBC Sustainability Appraisal (incorporating Strategic Environmental Assessment) provides an assessment as to how the spatial strategy for the Local Plan was arrived (identifying, describing and evaluating the likely significant effects of implementing the plan).
4.4 The strategy has evolved from the early 'Pathway to a Sustainable Brentwood' Issues and Options document (2009), which set out a series of strategic objectives. The overarching priorities set out in the Interim SA (Jan 2018) are:
* Environment and Housing Management;
* Community and Health;
* Economic Development;
* Planning & Licensing; and
* Transformation.
4.5 In order to achieve these priorities the following plan themes have been set out (with associated objectives as set out in the SA):
* Managing Growth;
* Sustainable communities;
* Economic prosperity;
* Environmental protection and enhancement;
* Quality of Life and community infrastructure; and
* Transport and Movement.
4.6 Having regard to these themes and objectives, 10 No. reasonable spatial strategy alternatives were drawn up in the SA. The desire to deliver at least one large-scale, strategic site (likely for a mix of uses, to include both housing and employment) is quite well established, recognising: A) limited opportunities within settlements; B) no potential to export 'unmet needs' (as discussed); and C) the alternative of piecemeal Green Belt development dispersed widely has significant draw-backs (this option was appraised within the 2013 Interim SA Report).
4.7 A number of strategic site options have been examined over recent years, including through consultation and SA work, such that there is now a refined understanding of those sites that are genuine contenders for allocation through the Local Plan - There is specific mention of North of Brentwood and ....' the potential for expansion to impact 'in-combination' with other potential extensions to the urban Brentwood/Shenfield area, most notably the potential 825 homes on land at Officers Meadow (directly to the east)'.
4.8 The SA goes on to note that there is a need to give careful consideration to growth opportunities at Brentwood/Shenfield urban area.......Brownfield opportunities are limited; hence there is a need to examine Green Belt urban extension options. All land around the urban area is given brief consideration, with reference to the site options and the designated constraints that exist. Specifically:
North of Shenfield
A large area of land is bounded by the railway line to the east, and the A1023 to the west; plus there is a parcel of land to the north of the A1023, bounded by the A12. There are relatively few designated constraints, although considerations include a spur of Arnolds Wood Local Wildlife Site (LWS), and proximity to the railway and main roads. This land parcel comprises three HELAA sites, all of which are preferred allocations at the current time (Officer's Meadow; Land east of A1023; and Land north of A1023).
[SA of Brentwood Local Plan, January 2019 - page 113]
4.9 Of the options considered, the SA concluded that "Option 3" Dunton Hills Garden Village only, in addition to the sites that are a 'constant' across the reasonable alternatives, was the preferred option for growth as it performs well in terms of the majority of sustainability objectives. Furthermore, the option of identifying the delivery of 'constant' sites was also preferred with the objective of meeting both short and long-term needs.
4.10 We fully support and consider the approach of the Sustainability Appraisal to be "sound" in terms of alternative strategies assessed for the Local Plan and consider that the most sustainable option has been arrived at.
4.11 The SA reviewed site options that could deliver the proposed spatial strategy. This includes "suitable" sites as derived from the SHLAA against a series of 12No SA criteria including Housing, Landscape, Community and well-being and other sustainability considerations. This included a "red, amber, green" assessment of sites as against the selected 12No criteria. We support this approach and consider it to meet the requirements of the SEA in terms of the assessment of environmental impacts - this includes BBC's assessment of the Site at North of Shenfield for which we also fully support and consider to be "sound".
4.12 The process allowed for two strategic site options to be discounted (considered 'unreasonable') given planning/sustainability considerations and deliverability considerations. The extent of reasonable sites has been restricted to balance the need to meet housing needs as well as ensuring that pressure will not be put on infrastructure nor pose a serious risk to air quality, local amenity, natural and heritage assets and biodiversity.
4.13 Our Client's considerations of the Council's Sustainability Appraisal have been informed by the accompanying "Review of Sustainability Appraisal" (Barton Willmore EIA, March 2019), which is attached to these representations. (See Appendix 01).
4.14 The preferred approach is Option 3, which involves allocating Dunton Hills Garden Village only, in addition to the sites that are a 'constant' across the reasonable alternatives (including Officers Meadows), and thereby putting in place an overall land supply sufficient to provide the required housing target dpa (assuming no delayed delivery).
4.15 We support the overall approach to the Sustainability Appraisal, insofar as:
* It follows a robust process in evaluating alternative options for growth as well as specific site options;
* The approach to individual site options is considered to be sound; and
* It is considered to be "sound" in that it arrives at the most reasonable option for growth - Dunton Hills Garden Village in addition to the sites that are 'constant' across the reasonable alternatives- as encompassing the allocation at Land North of Shenfield (034).
b) Housing Strategy
4.16 On 19 February 2019, MHCLG published the long-awaited outcome of the 'Technical consultation on updates to national planning policy and guidance', which clarifies the methodology for assessing housing need incorporated in the updated Housing and Economic Needs Assessment (HENA) Published on 20 Feb 2019. The standard method for assessing housing need is detailed in the PPG HENA and now clarifies that the 2014-based household projections published by the Office for National Statistics should be used to set the 'baseline' for the standard method calculation. The standard method number for Brentwood is 452 dpa.
4.17 In order to provide flexibility in the supply of housing sites, help boost delivery and to aim towards the standard method figure, the Council has proposed a further 20% supply buffer when allocating development sites in the Local Plan above the established annual housing figure of 380 dwellings per year, as set out in the SHMA. The buffer allows for an additional housing supply in the borough to be maintained throughout the Local Plan period and is supported in national planning guidance. The Reg 19 Draft Local Plan refers to 456 dpa based on the 20% SHMA uplift on 380 dpa.
4.18 The Local Plan sets out (Policy SP02) the OAN for housing in the Borough as being 7,752 dwellings during the Plan period (2016 - 2033); which when projected across the 17-year plan period gives an annualised housing delivery target of 456 new homes per year. The Council has not been able to identify a 5-yr HLS that delivers this current annualised requirement. When calculating HLS for our representations we have based our assumptions on 452 dpa which is the most up to date guidance (February 2019).
4.19 As a result of 89% of the Borough being designated Green Belt, the Council advises it is difficult to achieve a five-year supply, as many allocated sites within the Green Belt will not be available until the adoption of the Plan. On this basis a larger proportion of sites will not be delivered until after 2023, when they begin to benefit from detailed planning consent.
4.20 Therefore, a stepped trajectory is proposed, with an initial housing delivery target of 310 dpa to 2023 has been set, followed by a higher target of 584 dpa thereafter, which totals 7,752 homes overall in accordance with Policy SP02.
4.21 The Local Plan (Chapter 4, Policy SP02: Managing Growth) indicates that the residual requirement will be sought largely through new development being directed towards the site allocations set out in Chapter 8; and highly accessible locations along transit/growth corridors. These are as follows and seek to deliver circa. 4,500 units up to 2033:
Table 4: Strategic Sites [see attachment]
4.22 In terms of the allocation at Land North of Shenfield ("Officers Meadow"), this includes an overall requirement across the whole site allocation at Policy R03 for 825 units to be delivered in the Plan period. This delivery schedule is supported and is addressed further in the next section.
4.23 We support the housing strategy for the Local Plan and welcome that BBC is seeking to meet its housing needs in full. This is particularly important having regard to the likely inability of adjacent authorities (referred to on page 5) to meet their own needs. We therefore consider the housing strategy in the Plan to be "sound" in accordance with the NPPF (Para 35).
c) Employment Strategy
4.24 Policy PC02: Job Growth and Employment Land identifies that provision is made for at least 47.39ha of new employment land (B-use) to address the needs of the Borough up to 2033. To ensure that the Plan is more effective, it is recommended that this is followed by supporting text setting out the extent of need as derived from the Brentwood Economic Futures report (2018) and Strategic Housing Market Assessment (2018).
4.25 This need is proposed to be met through allocations set out at Policy PC03: Employment Land Allocations. This includes provision of appropriate new employment development on North of A1023 (part of the Land North of Shenfield R03 land use allocation). We fully support this aspect of the Plan including the broad strategy underpinning both the housing and employment allocations. The employment strategy for the Local Plan is justified and "sound" in line with the NPPF (para 35).
d) Five-Year Housing Land Supply
4.26 The Local Plan is unclear in terms of being able to demonstrate a 5-yr HLS of housing land for the purposes of the Plan.
4.27 The most recent AMR (Nov 2018) demonstrates that BBC currently has a supply of 4.1 years - against requirement of 411.6dpa (2,058 units over 5-years) which encompasses a 20% buffer as required by the NPPF and Housing Delivery Test. This is as a result of persistent under delivery, as delivery is currently calculated as 50.83% for BBC, below the 85% requirement.
4.28 The AMR 5-yr supply relates to the period 2018/19 - 2023 and concerns, inter-alia, sites with planning permission, existing commitments and strategic sites at Dunton Hills Garden Village, West Hordon Industrial Estate, Ford Headquarters, etc. The Plan's trajectory details the delivery at proposed allocated sites (2016/17 - 2032/33) amounting to 6,088 units.
4.29 The 2018 AMR suggests the delivery of 819 units (Allocations, Reg 19 Local Plan) within the same timeframe (2018-2023). The figure is derived from existing permissions, developments, allocations and commitments, as well as the 20% buffer, is 1,694.7 units, and concludes the supply is 4.1 years (as set out below):
Table 6: Five Year Supply Position (2018-2023) [see attachment]
4.30 The AMR 2018 refers to the PPPG: HELAA, which sets out how a 5-yr HLS is measured where LPAs have a "stepped" rather than annual average requirements; it states:
Five-year land supply is measured across the plan period against the specific stepped requirements for the particular 5-year period. Stepped trajectories will need to ensure that planned housing requirements are met fully within the plan period.
[Paragraph 017, Reference ID: 2a-017-20180913]
4.31 The AMR 2018 sets out (Table 4: Comparison of annualised housing delivery target and projected completions) a housing delivery target of 7,752 homes (456 dpa over the 17-year Plan period), together with annualised projected housing completions. The report states that from a comparison of this data an initial stepped requirement of 310dpa to 2023, followed by a higher stepped up requirement of 584dpa for the remainder of the Plan period, is a logical approach to reach 7,752 homes by 2033.
4.32 As a result of the high proportion of Green Belt in the Borough, it is extremely difficult to achieve the annualised 5-yr HLS requirement. This is because, as set out in the AMR 2018, sites on the edge of settlements currently within the Green Belt are not available for development purposes until the emerging Local Plan is adopted. Therefore, the potential for a stepped trajectory has been proposed, which delivers a greater proportion of the required homes beyond 2023.
4.33 The above demonstrates that BBC is not fully able to demonstrate a 5-yr HLS for Local Plan purposes. This position could be expedited by allowing allocated sites, such as "Officers Meadow" to come forward 1-2 years sooner, within the present 5-year period, to help meet the required 5-yr HLS position.
5.0 LAND NORTH OF SHENFIELD - POLICY R03
5.1 Land North of Shenfield (Policy R03: Strategic Site - Land North of Shenfield) is allocated in the Pre-submission Reg 19 Local Plan and the extent of the allocation is shown below:
Figure 1: Land North of Shenfield- Allocation Area [see attachment]
5.2 This shows the Site area as allocated as a whole; despite Land North of Shenfield having 6 land parcels within it, namely Site parcels 034, 158, 235, 087,263 and 276, as identified at Appendix 1: Housing Trajectory in the Reg 19 Local Plan and previously set out in earlier iterations of the Reg 18 Local Plan suite of documentation.
5.3 We set out below our comments on Policy RO3 and Appendix 1- Housing Trajectory in regard to the proposed delivery rates. This is largely supportive, however there are some aspects we do not consider to be "sound".
i) Amount and Type of Development:
a. Provision for around 825 new homes of mixed size and type, including affordable housing.
5.4 This criterion is supported/considered to be sound and "effective" in accordance with the objectives of the NPPF (para 61) relating to creating mixed and balance communities. The proposals for the Site will therefore be able to be delivered in accordance with this policy objective.
b. Provision of land (circa 2.1 hectares) for a co-located 2FE [additional text] primary school and early years and childcare nursery (Use Class D1). To be located adjacent to Alexander Lane. [additional text]
5.5 We largely support this criterion, albeit consider it should be amended (as above) to provide for greater clarity. Therefore as presently worded, we object to this criterion.
5.6 Forecasted figures contained in 'Commissioning School Places in Essex 2016-2021' indicate that there will be a deficit in pupil places by 2020/21 when accounting for demographic factors and the proposed uplift in residential development.
5.7 Earlier/recent work undertaken by the High School (and others) considered the anticipated need for a new 1FE Primary School. The proposed policy wording should clarify that it is now proposing a 2FE Primary School. We have prepared an accompanying note (Appendix 02) that reflects are discussions in this regard.
5.8 Consideration should be given to the location of the Primary School. Again, the recent work undertaken by the High School has examined this, inc the early years facility and nursery element, and that it should ideally be located on the existing school playing fields, just north of Alexander Lane. This would enable the Shenfield High School to deliver an 'all through' school provision, comprehensively expanding the educational offer available on-site.
5.9 The NPPF (para 94) seeks that LPAs take a proactive, positive and collaborative approach to meeting school place requirement and to development that will widen choice in education. The principles of this element of Policy R03 is therefore "consistent" with the NPPF, but the wording should be clarified further. We would be happy to continue discussions with Shenfield High School, BBC & ECC Officers in respect of seeking to agree the most suitable location for the primary school provision.
5.10 In terms of its own generated education requirements, the allocation would give rise to a need for a 1FE Primary School and financial contributions towards secondary school provision. Through positive discussions with Shenfield High School, we have been working closely towards its objective of becoming a "through-school" (by encompassing Primary provision) and contributing towards secondary provision (at the High School) on a pro-rata basis.
c. Provision for a residential care home (around 60 bed scheme as part of the overall allocation).
5.11 The principle of this criterion is supported/ considered to be sound and a care home could be accommodated on the 'Officer's Meadow' site, however this should be subject to the balanced and reasonable distribution of other infrastructure across the Site allocation as a whole. The NPPF (section 5) on "Delivering a Sufficient Supply of Homes" requires that housing need for different groups in the community should be assessed and reflected in planning policies. The provision of a residential care home in Policy R03 would contribute towards the offer of care for older people in Shenfield and is therefore "consistent" with the NPPF, in accordance with national policy and is deemed sound.
d. Provision for up to [additional text] 5% self-build and custom build across the entire allocation area.
5.12 The principle of this criterion is supported, but not as presently worded. We therefore object to this criterion in its present form.
5.13 Section 1 of the Self-Build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) requires each relevant authority to keep a register of individuals and associations seeking to acquire serviced plots for their own self-build and custom housebuilding. Whilst the provision of self-build and custom build should be considered, the evidence base for a 5% need across the entire allocation should be addressed against the local "needs register" and demand for such provision at the prevailing time.
5.14 In order to align with National policy, the evidence base and local need should be fully assessed before any commitment is made to the provision of this house type in this location. It is therefore considered that this element of Policy R03 is unsound.
5.15 It is recommended that this aspect of the policy is amended to "up to" 5% as shown above, to reflect prevailing "need" at the time.
e. Provision of 2ha of land for employment purposes.
5.16 The provision of 2ha of employment land as part of the wider allocation is agreed in principle. Employment land situated on land north of Chelmsford Road, as per the location identified in the BBC Site Analysis Overview report (Feb 2019), is supported, given its location adjacent the A12. This is the most appropriate location for such provision and is "consistent" with the NPPF (para 20). Therefore, and if situated in this location, this criterion is considered sound.
ii) Development Principles:
a. Comprehensive masterplan and phasing strategy to be prepared and considered as planning applications come forward.
5.17 We support this criterion and it is confirmed that development can come forward and be delivered within the timescale as shown in the housing trajectory. We also support a comprehensive masterplan and phasing strategy to set out effective phasing of the requisite infrastructure, as identified in the Infrastructure Delivery Plan (IDP) is "consistent" with the NPPF and is considered sound.
5.18 The overall needs of development must have regard to potential considerations in terms of viability in order to be fully "justified", something not yet addressed in the IDP, which should be rectified in the next iteration of the IDP.
b. Site is identified as a key gateway location and development should reflect this in terms of design quality particularly on land near to Junction 12, A12.
5.19 We broadly support these provisions and the concept masterplan sets out conceptually the land take for development in this location, including the key gateway employment location and residential, however this land is not within our Client's control and as such will be the subject of a separate planning application and detailed framework masterplan. In principle, and from an overall design perspective, this key gateway location is consistent with Section 12 of the NPPF and is "justified" and therefore considered sound.
c. Vehicular access via Chelmsford Road (A1023) and Alexander Lane.
5.20 It is recognised that the delivery of vehicular access via Chelmsford road and Alexander Lane is a necessity as part of these proposals. Our Client's accompanying Transport Strategy (Vectos, March 2019) provides evidence to support the development of the Officer's Meadow Site in terms of reducing the need to travel and providing opportunities for non-car travel. This is "consistent" with the NPPF, in particular Section 9 on "Promoting Sustainable Transport". The provision of access via both Chelmsford Road (A1023) and Alexander Lane allows for flexibility in terms of phasing and means that development can take place simultaneously in more than one location on the Site. It is therefore considered that this criteria is sound.
d. Potential for diversion of Alexander Lane, creating a quiet lane for pedestrians and cyclists, with the provision for new and improved route through the development site linking to Chelmsford Road.
5.21 The potential diversion of Alexander Lane is welcomed in terms of pedestrian safety and improved access. This is because a quieter Alexander Lane will improve access to local schools, pedestrian and cycle infrastructure and the existing PRoW, encouraging active mobility. This policy is therefore considered "justified" in light of the NPPF (para 102).
e. Enhancing sustainable links with Shenfield station and local services and facilities in the wider area.
5.22 The accompanying (Vectos) Transport Strategy confirms that the travel opportunities afforded by the service at Shenfield Railway Station and local bus routes will ensure that travel by public transport is a realistic option for future residents. The NPPF (para 102) states that opportunities to promote public transport use should be identified and pursued by Local Plans. This policy is therefore considered to be "consistent" with the objectives of the NPPF and is sound.
f. Provide well-connected internal road layouts which allow for good accessibility.
5.23 The development of Officer's Meadow would provide opportunities to encourage walking and cycling through new and improved routes and crossing facilities. Improving the accessibility within an already sustainable setting will also help to minimise vehicular traffic, in accordance with National policy. This is "consistent" with the NPPF objectives set out in both Section 8 "Promoting Healthy and Safe Communities" and Section 9 "Promoting Sustainable Transport" .
g. Provision for new multi-functional green infrastructure including public open space.
5.24 The provision of green infrastructure and open space throughout the Site is supported. The development of Officer's Meadow introduces the opportunity to introduce ecological corridors, open space and green infrastructure linkages, as well as enhancing the recreational resource and connectivity value of the Site. The NPPF (para 181) states that planning policies should maximise opportunities for green infrastructure provision and enhancement. This policy is therefore considered "effective" in terms of meeting the requirements set out in the NPPF.
h. Maintain and enhance Public Right of Way within the site and to the wider area.
5.25 Our Client's accompanying Landscape Assessment (Barton Willmore, March 2019) provides information to support the maintenance and enhancement of the existing PRoW on site. Although limiting development, this PRoW allows for the opportunity to introduce ecological corridors, open space and green infrastructure linkages. The NPPF (para 98) states that policies should protect and enhance the PRoW, including taking opportunities to provide better facilities for users. It is therefore considered that this policy is "consistent" and sound in accordance with the NPPF.
i. Protect and where appropriate enhance the Local Wildlife Site (Arnold's Wood).
5.26 Arnold's Wood comprises a narrow strip of Ancient Woodland to the north and the east of the Site. The accompanying Ecological Report (Aspect Ecology (March 2019) identifies this feature as a Local Wildlife Site, whereby appropriate conservation and enhancement through development is a priority. The NPPF (para 170) seeks that planning policies contribute to and enhance the natural and local environment by protecting valued landscapes and sites of biodiversity value, such as area of ancient woodland. The protection and enhancement of the Local Wildlife Site is therefore "justified" with regard to the NPPF, leading to the consideration of this policy as sound.
j. Provide for appropriate landscaping and buffers along sensitive boundaries adjoining the A12 and railway line.
5.27 Our Client's emerging proposals have been informed by a series of technical reports, including the Landscape Report, which provides for a planted buffer to be provided along the A1023 Chelmsford Road to help soften views of the proposed residential development at Officer's Meadow. This policy is therefore "effective" in terms of protecting residential amenity and enhancing the natural environment. The use of appropriate landscaping buffers is also in accordance with the NPPF (Section 15) on "Conserving and Enhancing the Natural Environment", making this criterion sound.
iii) Infrastructure Requirements:
a. Provide pedestrian and cycle crossing points across Chelmsford Road (A1023) where appropriate.
5.28 The accompanying Transport Strategy (Vectos) provides for new and enhanced pedestrian and cycle connections within the Site and to the wider area. As individual development parcels are separated by Chelmsford Road, pedestrian and cycle crossings are required where appropriate to allow safe connection between parcels (as identified in by Infrastructure Requirements). This criteria is therefore supported as the provision of crossing points across Chelmsford Road (A1023) will help to maximise opportunities for sustainable transport modes throughout the Site, to Shenfield railway station and various local services. The NPPF (para 104) states that planning policies should provide for high quality walking and cycling networks. This policy is therefore considered "consistent" with national policy.
b. Provision for improved bus service.
5.29 The provision of an improved bus service, with reference to the IDP, is supported. This criterion is sound in the light of Para 110 of the NPPF. It is therefore "justified".
c. The Site is located within a Critical Drainage Area. This development may have the potential to impact on the Critical Drainage Area in respect of surface water flooding. As a result of this, the site is likely to require an individually designed mitigation scheme to address this issue.
5.30 The majority of the Site is located within Flood Zone 1. As referred to in the accompanying Drainage Report (JNP, March 2019), the critical drainage can be dealt with by the creation of a surface water storage basin/wetland area to attenuate and release the overland surface water flows from off site at a reduced rate. An individually designed mitigation scheme can be implemented on-site via a variety of SuDS, in accordance with the provisions of the NPPF (para 163). These components will also adequately provide for surface water flows generated by the proposed development. The above criteria is therefore considered to be sound and "effective".
5.31 In addition to the above elements of physical infrastructure, and as mentioned previously in respect of other aspects of Policy RO3 allocation, we are also mindful of accompanying social infrastructure - in particular the educational needs of the resultant residents and the relationship with the adjoining Shenfield High School. It is therefore appropriate to reiterate our Client's willingness to work closely with the High School in helping to deliver its aspirations in providing for a "through school" (with Primary provision) and our off-site educational financial contributions will be directed to support this.
5.32 In overall terms, we largely support the provisions of Policy RO3 and have sought to reflect this is the accompanying illustrative concept masterplan, which demonstrates the delivery of the requisite infrastructure for the Site Allocation as a whole including:
- Social infrastructure - primary school, early years and nursery care;
- Transport infrastructure - pedestrian and cycle crossing points;
- Critical drainage mitigation; and
- Blue and Green Infrastructure.
5.33 The above demonstrates our overall support for the allocation of the Site and we can confirm that the proposed development is deliverable within the timescales established by BBC. The delivery of Land North of Shenfield ("Officer's Meadows") is addressed in the next section.
6.0 DELIVERY OF LAND NORTH OF SHENFIELD
6.1 A range of technical work and evidence has been worked up for the Site and which demonstrates the deliverability of the proposals. This technical input is set out in full in the Technical Representations accompanying these submissions.
6.2 This report therefore does not seek to repeat the technical material in full, instead it provides a summary of the main disciplines and how they relate to the delivery of the project.
6.3 This includes work in relation to the following disciplines:
i) Transport (Vectos);
ii) Landscape/Green Belt Assessment (Barton Willmore Landscape);
iii) Drainage (JNP Group)
iv) Noise (Sharps Gayler)
v) Ecology (Aspect Ecology);
vi) Archaeology (Albion Archaeology); and
vii) Masterplan (Barton Willmore Design).
6.4 Below is a brief summary of each of the update reports submitted in terms of the delivery of the scheme.
i) Transport
6.5 The accompanying Transport Strategy (Vectos) (Appendix 03) sets out the principle of a sustainable transport strategy for Officer's Meadow, reducing the need to travel and providing opportunities for non-car journeys. The proximity of the Site to local services and the proposed 'all through' school across the wider site will reduce trip generation and promote sustainable communities.
6.6 The Transport Strategy identifies the junction location i.e. A1023 Chelmsford Road/A129 Hutton Road/A1023 Shenfield Road and the appropriate mitigation measures, which include the implementation of MOVA or similar as a mitigation, in order provide adequate capacity. The access and egress via Alexander Lane will be provided in the form of simple priority junctions.
6.7 The new access points/roundabouts can be fully accommodated within the Site area and/or on highway land. Highways improvements are therefore deliverable as part of the comprehensive development for the scheme. As such, Land North of Shenfield is suitable for allocation in the Local Plan, in terms of highways and transport constraints.
ii) Landscape and Visual Appraisal/Green Belt Review
6.8 A Landscape and Visual Appraisal (BW Landscape) (Appendix 04) has been undertaken to provide a review of the landscape character and visual amenity of the Site and surrounding area. These aspects have informed the parameters of the illustrative masterplan and have demonstrated that the Site is suitable to be released through 'exceptional circumstances' for development, as addressed below. It supports BBC's removal of Land North of Shenfield from the present Green Belt designation, which presently washes over the entire Site and its surrounding environs.
6.9 Direct adverse impacts of development on the wider Green Belt setting would be minimised by locating strategic open space on prominent land, particularly in the north east the Site. Low density housing could be located in the most prominent areas, framing the retained Ancient Woodland area to the north and east of the Site. A PRoW also traverses the Site, enabling the introduction of ecological corridors, open space and green infrastructure linkages, as well as enhancing the recreational resource and connectivity of the Site.
6.10 Development of the Site would form a logical extension that is in keeping with the existing settlement, better connecting the ribbon development between Chelmsford Road and the settlement edge of Alexander Lane. In terms of visibility, glimpses of the Site can be seen from elevated views to the west. However, the landform ensures that it is largely well contained by a combination of vegetation cover and built form, restricting long-distance views. A landscape-led approach to development within the Site would seek to ensure that existing defensible boundaries continue to prevent unrestricted sprawl.
6.11 The LVA concludes that allocation of the Site would result in successful assimilation and integration of new residential development, with the potential for adverse effects on the landscape setting moderated, as required by the NPPF. The Site is considered to be of "low sensitivity" as it is of a low landscape value and the localised visual envelope of the Site, coupled with the surrounding land uses, lends itself to residential development. The Site makes a minimal contribution towards the 5No purposes of the Green Belt, making it suitable for release and able to contribute towards a suitable pattern of development for Shenfield.
iii) Drainage
6.12 A Flood Risk and Drainage Note has been prepared (JNP Group) (Appendix 05). This confirms the location of the majority of the Site within Flood Zone 1, where there is the lowest probability of flooding and where new development should be steered. A small part of the Site is located within Zones 2 and 3. Built development (housing, social infrastructure, etc.) will avoid Flood Risk areas.
6.13 All proposed buildings within "Officer's Meadows" are to be located in Flood Zone 1. Essential infrastructure which passes through a small area designated as Flood Zone 3 will be subject to the "Exception Test" and site-specific flood risk assessment to demonstrate safe access & egress from the site and that the development does not increase flood risk both on and off site. Safe access & egress will be provided off Chelmsford Road A1023 and Alexander Lane. Where affected, allowance for flood compensation storage will be provided to ensure no net loss in flood storage.
6.14 The critical drainage can be dealt with by the creation of surface water storage basins/wetland areas to attenuate and release the overland surface water flows form off site at a reduced rate. Development generated surface water flows can be dealt with via SuDS components and a storage basin/wetland attenuation area. The Site is therefore suitable and deliverable from a flood risk and drainage perspective.
iv) Noise
6.15 An assessment of "likely noise constraints" has been undertaken (Sharps Gayler) (Appendix 06) to identify potential constraints relating to noise and vibration upon Officer's Meadow. The below conclusion is based on a desktop assessment, informed by computer modelling of transportation noise sources in the area (A12, A1023 and the mainline railway).
6.16 Whilst there is a low to medium risk on the boundaries of the Site with Chelmsford Road and the rail line, the majority of the Site presents a low risk. At low noise levels, the Site is likely to be acceptable from a noise perspective, provided that a good acoustic design process is followed at the detailed application stage, particularly for development within 50m of Chelmsford Road and the rail line.
6.17 The assessment concluded that there are no significant constraints on Site in relation to noise. Land North of Shenfield is therefore suitable and deliverable from an acoustic perspective.
v) Ecology
6.18 An Ecological Appraisal has been undertaken (Aspect Ecology) (Appendix 07). This report confirms that the Site comprises a range of habitats including arable, woodland, grassland, watercourse, hedgerows, scrub and lines of trees. The woodland at the north-east of the Site, the watercourse and the hedgerows are of elevated ecological value and are considered to be important ecological features.
6.19 Protected species such as bats, badgers, dormice and reptiles have not been identified within the vicinity of the site at this stage. Although thought to have 'good' suitability for Great Crested Newt, a DNA survey (2015) found the pond nearest to the Site unlikely to support a Great Crested Newt population. A further Great Crested Newt presence/absence survey of all relevant ponds associated with the Site is to be undertaken in 2019.
6.20 The habitats at the Site are currently unmanaged from an ecology point of view and the development proposal presents the opportunity of securing suitable management practices, appropriate mitigation and 'net gains' in terms of biodiversity. When considering ecological constraints, the Site is therefore both suitable and deliverable, subject to further survey work.
vi) Heritage Assessment
6.21 A Desk-based Heritage Assessment (Albion Archaeology) accompanies these representations, which has also been informed by a preliminary walk-over of the Site. The accompanying report (Appendix 08) reviews the potential for below ground archaeological interest and potential impact arising from development on such features; as well as an assessment of any direct impact on potential heritage assets.
6.22 No heritage assets other than the crop mark of a bomb crater, have been recorded in the proposed development area. Other heritage assets comprise former buildings, the postulated course of a Roman road, find-spots and historic settlement cores, whose setting will not be impacted by the proposed development. The adjacent railway lines, roads, buildings and vegetation suggest that the proposed new buildings are unlikely to be visible from these heritage assets. The potential impact on the setting is therefore assessed as "no change". The significance of this impact is "insignificant".
6.23 The potential for archaeological remains has been assessed covering prehistoric to modern periods. In general terms the "significance" of any remains is low to moderate. Any potential impact of the new development on potential buried archaeological remains could be mitigated by measures to investigate and record the presence/absence of potential archaeological assets. Officer's Meadows is thereby deliverable from an archaeological perspective.
vii) Masterplan
6.24 The accompanying illustrative concept masterplan (BW Design) (Appendix 09) has been developed in response to the above technical information prepared for the Site.
6.25 This demonstrates the ability of the Site itself to deliver:
* Circa 510 homes ("Officer's Meadow" site) inc. affordable provision;
* The proposed dwellings can be delivered within the timescale of the housing trajectory, with varying densities;
* Other potential linkages to Chelmsford Road (A1023) and Alexander Lane;
* A 60-bed care home;
* A Local Centre/ community facility;
* Multi-functional green and blue infrastructure; and
* Sustainable transport links.
6.26 Moreover, the illustrative concept masterplan also demonstrates the delivery of:
* Significant areas of Public Open Space encompassing:
- Natural and Semi-Natural Green Spaces;
- Outdoor Sports Facilities; and
- Children's/Young People's Play Area.
* Primary School provision on the adjoining Shenfield High School.
6.27 The above provides an overview of the technical inputs to the Land North of Shenfield (Officer's Meadow) and which confirms that the Site and proposals for it are deliverable within the Local Plan context. The proposals for the Site form part of an iterative process and further information will come to light in advance of a planning application to ascertain the detailed parameters for the Site.
6.28 These matters will be "screened" for a full Environmental Impact Assessment for a subsequent planning application, and it is envisaged the EIA Screening will be submitted later in 2019.
7.0 SOUNDNESS OF OTHER LOCAL PLAN POLICIES
7.1 This section does not seek to comment on other specific allocations/sites. Instead it focuses on policies of relevance within the Local Plan and sets out our comments and recommendations on these in terms of the tests of soundness in the NPPF.
7.2 Policy SP01: Sustainable Development takes a positive approach towards "Presumption in Favour of Sustainable Development" and seeks to apply this in terms of planning applications, in accordance with the Development Plan. The NPPF (para 11) assumes a strong "Presumption in Favour of Sustainable Development" in all planning related matters and places a responsibility on LPAs to positively seek opportunities to meet the development needs of their area and to, as a minimum, provide for objectively assessed needs for housing and other uses. This policy is "consistent" with the NPPF and is therefore sound.
7.3 Policy SP02: Managing Growth seeks to support the delivery of homes by setting out provision for 7,752 new dwellings to be built over the Plan period 2016-2033, at an annual rate of 310 dwellings up to 2022/2023, followed by 584 dwellings from 2023/24-2033. This objective is not supported, as it is considered that this stepped trajectory which delivers a greater proportion of the required homes beyond 2023, could be reviewed to allow more housing to come forward from the period 2021 onwards. This is with particular reference to NPPF (para 23) which states that "strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs". This policy is therefore "not consistent" with the NPPF and not sound.
7.4 We consider that in order to address this, the Council should review its housing trajectory and at the same time, clarify the new dwelling number ahead of the Local Plan submission, to align with the February 2019 agreed position on the 'baseline' for the standard method calculation.
7.5 The Council should, in addition, work with developers to bring applications forward in advance of the adoption of the Local Plan, to meet housing need.
7.6 Policy SP03: Health Impact Assessments (HIAs) states that Brentwood Borough Council is committed to ensuring all new developments promote healthier and inclusive environments. The majority of proposals will be required to assess their impacts on health and well-being upon the capacity of existing health care and social care services and facilities, the environmental impacts, and the promotion of health improvement activities, arising from the development. Developments of 50 or more units are required to submit a Health and Well-Being Impact Assessment, as required by the EPOA HIA Guidance Note.
7.7 This policy is considered to be unsound as it is not "justified". The requirement to undertake a Health Impact Assessment (HIA) is a superfluous burden on applicants. It should be down to the Local Plan to take into account wider health concerns in the local area and focus policies upon addressing these concerns. Health and well-being should be covered within the polices of the Local Plan and where a development aligns with these, an HIA should not be required.
7.8 Policy SPO4: Developer Contributions refers to the need for all new development to be supported by, and have good access to, all necessary infrastructure. Developers and land owners must work positively with the Council, neighbouring authorities and other infrastructure providers throughout the planning process to ensure that the cumulative impact of development is considered and then mitigated.
7.9 Applicants proposing new development will be expected to make direct provision or contribute towards the delivery of relevant infrastructure, as required by the development either alone or cumulatively with other developments. The Infrastructure Delivery Plan (IDP) identifies the types of infrastructure required to support the anticipated growth in the borough and includes a summary of the current identified infrastructure projects.
7.10 Policy SPO4 should be more explicit on the exact nature of requirements that the developer may be required to meet to avoid overly onerous requirements or confusion over cumulative impact and phasing with other developments and therefore this policy is not "justified" and is unsound.
7.11 Policy SP05: Construction Management states that all major development should sign up to the Considerate Constructors Scheme, or equivalent. Major development must consider the cumulative impacts of other major development occurring in the vicinity, to reduce the cumulative impacts.
7.12 It is considered that this policy accords with the NPPF and is therefore found to be sound, with particular reference to NPPF (para 72) which refers to larger scale development supported by the necessary infrastructure and facilities.
7.13 Policy SP06: Effective Delivery of Development states that proposals for large allocation sites will be expected to be developed in partnership with the Council, infrastructure providers and other relevant organisations, through a collaborative masterplanning approach. Development proposals should submit a supporting statement setting out the sustainable long-term governance and stewardship arrangements for community assets including land, services and facilities such as village halls, community centres, libraries, parks, green spaces, and buildings for sports, leisure, healthcare, education, social, arts and cultural activities. This policy is overly onerous and therefore "unjustified". This policy is therefore considered to be unsound.
7.14 Policy BE02: Sustainable Construction and Resource Efficiency requires all development proposals to maximise the principles of energy conservation and efficiency. Whilst the NPPF (para 153) has regard to the inclusion of renewable and decentralised energy as part of a new development, it states that such features are only required where it is either feasible or viable. This policy is therefore not "consistent" with National Policy.
7.15 We therefore object to the policy in its present form. In order to ensure consistency with National policy, criteria (f) of Policy BE02 should be revised to mirror the NPPF position. Therefore, it is considered that proposed Policy BE02 is unsound.
7.16 Policy BE03: Carbon Reduction, Renewable Energy and Water Efficiency states that proposals for renewable, low carbon or decentralised energy schemes will be supported, subject to adverse cumulative and visual impacts, which cannot be satisfactorily addressed. Criteria (b) of the proposed policy sets out the minimum standards of sustainable construction and carbon reduction. It is Government policy to seek to deliver improvements to emissions from buildings through the application of building regulations. It is therefore considered that the table provided in proposed Policy BE03 is not required, and therefore this policy is "unjustified" and unsound.
7.17 Policy BE04: Establishing Low Carbon and Renewable Energy Infrastructure Network sets out that developments will be required to provide for the necessary infrastructure to meet the needs of the development, specifically stand-alone renewable energy infrastructure. The policy advises that new development of over 500 units, or where the clustering of neighbouring sites totals over 500 units, will be expected to incorporate decentralised energy infrastructure.
7.18 The supporting text refers to the need for District heating networks and the identification of Strategic allocations in the Brentwood IDP, including the Officers Meadow's masterplan area, that could provide opportunities for DH and CHP schemes as energy solutions for new development.
7.19 This policy is considered overly onerous and "unjustified" in relation to the NPPF and therefore unsound.
7.20 In order to make the policy more effective, it could set out that the delivery of renewable energy infrastructure should be required based on evidence of need and viability and a "viability assessment" (at the time planning applications are submitted/determined) - as per Policy SP04.
7.21 Policy BE08: Sustainable Drainage seeks that all developments should incorporate appropriate Sustainable Drainage Systems (SuDs) for the disposal of surface water, in order to avoid any increase in flood risk or adverse impact on water quality. Larger sites over 1 hectare in Zone 1 must be accompanied by a Flood Risk Assessment. Water runoff will comply with the requirements of this policy by provision of SuDS in the surface water drainage strategy. The NPPF (para 163) refers to the need for local planning authorities to ensure that flood risk is not increased elsewhere. Where appropriate, applications should be supported by a site-specific flood-risk assessment. This aspect of the policy is therefore considered "consistent" with the NPPF.
7.22 Given the extensive nature of the development, opportunities exist to incorporate the above the SuDs management across the site both locally and site-wide. However, the requirement for prevention if run-off for all rainfall events up to 5mm is in excess of the SuDS manual and is therefore "unjustified". Unfortunately, this therefore renders the overall Policy BE08 to be unsound.
7.23 Policy BE10: Connecting new developments to digital infrastructure seeks to support Brentwood's economic growth and productivity by improving the offer of digital infrastructure available within the Borough. Whilst planning strives to achieve the highest possible standards of construction and performance for new dwellings, Council's should not seek higher standards than Building Regulations on any other technical standards. Proposed Policy BE10 is therefore "unjustified" in light of National policy and therefore unsound.
7.24 Policy BE11: Strategic Transport Infrastructure requires that development in proximity of the railway stations demonstrate how the scheme connects the surrounding walking, cycling and public transport links to the station, linking new developments with the fast high-capacity transport links into London from Shenfield and the improved linkages from the Elizabeth line. Development close to schools and early years childcare facilities should facilitate an attractive public realm that is safe for children and encourages walking and cycling to address the impacts of school run traffic, in line with ECC's Developers' Guide to Infrastructure Contributions. This aligns with the NPPF (section 9) on "Promoting Sustainable Transport". These considerations therefore appear to be "justified", in accordance with national planning policy and therefore the policy is sound.
7.25 Policy BE13: Sustainable Means of Travel and Walkable Streets and Policy BE16: Mitigating the Transport Impacts of Development refers to sustainable modes of transport that should be facilitated through new developments, promoting accessibility and integration into the wider community and existing networks. Any development requiring a new road or road access, walking and cycling facilities and public transport, will be required to have regard to the adopted ECC's Development Management Policies or successor documents.
7.26 The policies seek to secure developments that are, inter-alia, designed to make necessary contributions to the improvement of existing infrastructure and provision of new infrastructure; be consistent and contribute to the implementation of the Essex County Council's Development Management Policies and include Transport Assessments and Travel Plans. This aligns with the NPPF (section 9) "Promoting Sustainable Transport" and is therefore considered "justified" and sound.
7.27 Policy BE17: Parking Standards refers to the vehicle parking requirement set out in the most up-to-date Essex Parking Standards. The NPPF (para 105) states that when setting local parking standards policies should take into account: a) the accessibility of development b) the type, mix and use of development c) the availability of and opportunities for public transport d) local car ownership levels and e) the need to ensure an adequate provision of spaces for charging plug-in and ultra-low emission vehicles. This aligns with the flexibility allowed for in Policy BE17, whereby the imposed parking standards are subject to the site's ability to minimise pressure on land and encourage the use of alternative modes of transport.
7.28 However, Policy BE12 also deals with "parking matters", but is not aligned with Policy BE17. This adds further inconsistency, in addition to Policy BE17 itself being "inconsistent" with the NPPF. It is therefore presently unsound.
7.29 Policy BE18: Green and Blue Infrastructure requires that Brentwood's existing ecological networks, open spaces, and green/blue features within the built environment are protected, planned, enhanced and managed as a part of the Borough's wider network of green and blue infrastructure. Points A-I of Policy BE18 identify the measures by which development proposals can maximise opportunities to protect and enhance green and blue infrastructure, aligning with the NPPF (section 15) "Conserving and Enhancing the Natural Environment".
7.30 However, it is presently unclear how any net gains/losses and any associated requirements would be measured/calculated, or the mechanism by which the Council or developer would deliver this. This is therefore both "unjustified" and "inconsistent", and therefore unsound.
7.31 Our Client largely supports the principle of Policy BE18, but it also unfortunately includes the requirement for a developer to ensure there is sufficient foul capacity within the local network before a development commences. Whilst our Client would liaise with Anglican Water, it is ultimately the Water Authority's responsibility to ensure sufficient capacity. Therefore as presently worded, the policy is "unjustified" and is unsound.
7.32 Policy BE19: Access to Nature seeks that major developers provide direct access to nature and that this provision is protected, planned, designed and managed as an integrated feature of the landscape. Developments in areas that are more than 1km walking distance from an accessible green open space should also seek opportunities to improve resident's experience and interaction with nature by means of design. The NPPF (section 8) "Promoting Healthy and Safe Communities" states that planning policies should be based on robust and up-to-date assessments of the need for open space, this policy is therefore deemed to be "consistent" with the NPPF and sound.
7.33 Policy BE22: Open Space in New Development seeks that major developments provide functional on-site open space and/or recreational amenities, in accordance with standards set out in the Council's Open Space Standards (see Figure 5.4 Open Space Standards and Fig 5.5 Fields in Trust Children's Play Space Standards in the Reg 19 Local Plan). Maintenance Plans should be submitted at planning application stage for all new facilities provided for exercise or recreation purposes.
7.34 The Council's Open Space Standards seek proposals which meet the Fields in Trust (Guidance for Outdoor Play Space: Beyond the Six Acre Standard) minimum standards. The FiT standards relate to provision on the basis of hectares per 1,000 population generated. The Council's Open Space Standards are considered to be effective as they are based on FiT standards and are therefore "justified" and the policy is sound.
7.35 Policy BE23: Open Space, Sport and Recreational Facilities states that permissions will not be granted for the development of designated Protected Urban Open Space or Local Green Space unless it can be demonstrated that alternative and improved provision can be created, existing open space enhanced or no additional displacement within the Green Belt caused. As with Policy BE22, where appropriate all proposals will be required to comply with the Council's Open Space Standards which aim to meet those set out by FiT. It is therefore considered that policy BE22 is "justified" in line with national guidance and therefore sound.
7.36 Policy HP01: Housing Mix sets out that all new development should deliver an inclusive and accessible environment throughout. On development sites of 500 or more units, the Council will require an appropriate mix of dwelling types, sizes and tenures to meet the identified housing needs in the borough as set out in the Strategic Housing Market Assessment (SHMA). Each dwelling is to be constructed to meet requirement M4(2) accessible and adaptable dwellings, unless built in line with M4(3) wheelchair adaptable dwellings. A minimum of 5% self-build homes is to be provided, which can include custom housebuilding and provision for Specialist Accommodation, taking account of local housing need in accordance with the criteria set out in Policy HP04 Specialist Accommodation. Where a development site has been divided into parts, or is being delivered in phases, the area to be used for determining whether this policy applies will be the whole original site.
7.37 The objective of securing accessible and adaptable homes is supported, however, it is unclear as to how the "each dwelling to be constructed to meet requirement M4(2) accessible and adaptable dwellings, unless it is built in line with M4(3) wheelchair adaptable dwellings" is a fair and reasonable request.
7.38 The supporting text refers to DCLG research which shows that, based on English Partnerships figures from 2011-2012, nearly 30% of households have at least one person with a long-term illness and over 3% have one or more wheelchair user. While nationally 3.3% of households have a wheelchair user, for households living in affordable housing this rises to 7.1%. The rates are also higher for older households and, given that the number of older person households in the borough is set to increase over the period to 2033, the Council seeks to ensure 5% of affordable housing development on proposals of 60 or more dwellings archives requirement M4(3) wheelchair accessible dwellings.
7.39 This need for "all developments" to meet this target is not set out in the evidence or in the NPPG (referred to in the supporting text) and is therefore "unjustified" and unsound.
7.40 Policy HP03: Residential Density sets out that residential development proposals will generally be expected to achieve a net density of at least 35 dwellings per hectare net or higher. Proposals for new residential development should take a design-led approach to density which ensures schemes are sympathetic to local character and make efficient use of land. Proposals for housing developments should "Make an Effective Use of Land" in line with NPPF (Section 11). This policy is therefore "consistent" with the NPPF and sound, but must provide for a degree of flexibility to allow for local circumstances.
7.41 Policy HPO4: Specialist Accommodation the Council encourages and supports proposals which contribute to the delivery of Specialist Accommodation, as referenced in the Land North of Shenfield Site allocation "other types of specialist housing (to be provided) in accordance with the Council's policy requirements". This form of accommodation includes, but is not limited to, housing for older people such as Independent Living schemes for the frail elderly.
7.42 The Council's SHMA indicates that, if occupation patterns of Specialist Residential Accommodation for older people remain at current levels, there will be a requirement for 494 additional specialist units to 2033, aligning with the requirement in the Land North of Shenfield site allocation for provision of a residential care home (a 60-bed scheme as part of the overall allocation). This policy is also "consistent" with the NPPF section 5 (para 64 b) and is therefore considered to be sound.
7.43 Policy HPO5: Affordable Housing seeks to provide a portion of affordable housing on residential developments of 11 dwellings or more or on those which have a combined gross floorspace of greater than 1,000 sq. m (gross internal area).
7.44 The affordable housing requirement relates to 35% provision in all areas of the Borough. The Council requires that the tenure split be made up of 86% Affordable/Social Rent and 14% as other forms of affordable housing (this includes starter homes, intermediate homes and shared ownership and all other forms of affordable housing as described by national guidance or legislation) or regard to the most up to date SHMA. The affordable housing is to be designed in such a way as to be seamlessly integrated to that of market housing elements of a scheme and distributed throughout the development, so as to avoid the over concentration in one area.
7.45 Viability is referred to, but the policy does not go far enough. We would recommend that the policy includes a clause which requires a viability assessment to be submitted and considered whereby schemes are unable to meet the full affordable provision, which is not included at present. The policy is therefore "unjustified" and unsound.
7.46 Policy HP06: Standards for New Housing requires that all major residential developments meet the Government's nationally described space standard. It is considered that the standard is an appropriate tool to use when considering the provision of good housing. However, this should not be limited to major development, but should instead extend to all emerging residential development, whilst allowing for the consideration of local circumstances and site-specific conditions, in order to accord the NPPF (Section 12, Achieving Well-Designed Places). The policy is therefore "unjustified" in relation to need and viability (our emphasis) in accordance with the NPPF. The adoption of nationally described space standards is also at the discretion of the LPA and should be decided upon in a local context. The policy is therefore considered unsound.
7.47 Policy HP12: Planning for Inclusive Communities refers to the need to plan for and build inclusive environments that support communities. Proposals should provide access to good quality community spaces, services and infrastructure, encouraging social interaction, ensuring inclusivity and promoting safety. The policy is deemed "consistent" with NPPF (section 8) "Promoting Healthy and Safe Communities" which states that planning policies should aim to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible, and support healthy lifestyles. The policy is therefore considered sound.
7.48 Policy HP13: Creating Successful Places seeks that proposals meet high design standards, in order to deliver safe, inclusive, attractive and accessible places. Elements A-M of policy HP13 identify measures considered to create successful places, in accordance with section 12 of the NPPF on "Achieving Well-Designed Places". The NPPF (para 128) states that design quality should be considered throughout the evolution and assessment of individual proposals. Policy HP13 is therefore considered to be "consistent" with the NPPF and sound.
7.49 Policy HP16: Buildings Design seeks for development to be well designed and of a high quality, having regard to Development Management criteria including scale, density, layout, siting, character and appearance. This policy is considered to be "consistent" with the NPPF having particular regard to Section 12 on "Achieving Well-Designed Places" and therefore sound.
7.50 Policy PC02: Job Growth and Employment Land seeks that provision is made for 5,000 additional jobs in the Borough over the Plan period at a rate of 250 per year. NPPF Section 6 on "Building a Strong, Competitive Economy" sets out that planning policies should support economic growth, in order to create jobs and prosperity by taking a positive approach to sustainable new development. The strategic allocation at Land North of Shenfield supports economic growth and creates new opportunities and is "consistent" with national guidance and is sound.
7.51 Policy PC03: Employment Land Allocations highlights areas allocated by the Council for general employment and office development. Para 82 of the NPPF states that planning policies should recognise and address the specific locational requirements of different employment sectors. The allocations set out in policy PC03 are informed by the wider spatial strategy, which aims to retain the Borough's character and encourage employment growth in suitable locations, in accordance with national planning policy. This policy is therefore deemed to be "consistent" with the NPPF and considered to be sound.
7.52 Policies NE01: Protecting and Enhancing the Natural Environment (inc SSSIs) and NE03: Trees, Woodland, Hedgerows (inc Local Wildlife Site, Local Nature Reserves) work to restrict development that would have a detrimental effect on, or result in the loss of, significant landscape heritage or a feature of ecological importance.
7.53 Our Client wholly supports the principles of both of these policies, albeit as presently worded, they both contain contradictory requirements: Policy NE01 (para B) states that proposals that lead to deterioration or loss of the Borough's designated and non-designated biodiversity assets will not be permitted; whereas Policy NE01 (para C) goes on to state that where adverse impacts are unavoidable they must be adequately and proportionally mitigated (ie it appears to allow for deterioration where they are unavoidable and can be suitably mitigated).
7.54 Policy NE03 (para A) contains a similar contradictory approach to the provisions of the remainder of the policy - as with Policy NE01.
7.55 In the light of this both Policy NE01 and Policy NE03 are not inconsistent with each other, they are also "inconsistent" with National policy, "unjustified" and therefore unsound.
7.56 Policy NE05: Air Quality seeks to restrict development, which would directly or indirectly, impact air quality within the Borough. Measures to offset or mitigate those impacts are introduced as part of proposals to ensure that receptors would not be subject to unacceptable risk as a result of poor air quality. This policy is "consistent" with the objectives of the NPPF (para 181) and is therefore considered sound.
7.57 Policy NE06: Flood Risk requires that development avoid flood risk to people and property, managing any residual risk and taking account of the impacts of climate change. Developments should be located in areas with the lowest probability of flooding (Flood Zones 1 & 2). Where development is located within Flood Zone 3, the Exception Test will apply.
7.58 The NPPF (section 14) "Meeting the Challenge of Climate Change, Flooding and Coastal Change" states that inappropriate development in areas at risk of flooding should be avoided by directing development away from the areas at the highest risk. The majority of Policy NE06 therefore aligns with National guidance and therefore mostly sound. However, and as presently worded, it suggests tat applicants may be obligated to set aside land to provide flood management to benefit areas outside of that development. This is unduly onerous, inconsistent with National policy and therefore unsound.
7.59 Similarly, the entirety of a development area does not need to remain operational at times of flood (such as access roads), if there is an alternative safe means of escape that is provided. Subsection c) of Policy NE06 is therefore not justified and also unsound.
7.60 Policy NE09: Green Belt seeks that the Metropolitan Green Belt within Brentwood Borough will be preserved from inappropriate development so that it continues to main openness and serve key functions. Policy NE09 states that all development proposals within the Green Belt will be considered in accordance with the provisions of section 13 of the NPPF on "Protecting Green Belt Land". It is therefore considered that policy NE09 is "justified" and sound, in the light of national policy.
7.61 Policy NE13: Site Allocations in the Green Belt states that sites allocated to meet housing need, within the Green Belt, will be expected to provide significant community benefits. These are the "exceptional circumstances" for sites to be removed from the Green Belt to allow development to take place, providing new defensible boundaries and protecting the open countryside. The NPPF (para 138) states that, where it has been concluded necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.
7.62 The allocated "Officer's Meadow" site provides opportunities for sustainable development and transport modes to be maximised, with its close proximity to Shenfield railway station, in accordance with National policy, leading to the consideration of Policy NE13 as "consistent" with the NPPF and sound.
7.63 The overall approach within the Development Management related policies is supported, however amendments to policy/Appendices of Local Plan is recommended in places as set out above. This would ensure robustness in terms of delivering a sound Local Plan that is positively prepared, justified, effective and consistent with national planning policy.
8.0 CONCLUSION
8.1 The Regulation 19 "Pre-Submission Local Plan" consultation document is supported. These representations fully support the allocation of Land North of Shenfield, which includes our Client's land at "Officer's Meadow". These representations focus mostly on land within our Client's control and are supported by a series of accompanying technical reports that support the proposed allocation.
8.2 Our Client supports the wider and comprehensive development of Policy RO3: Land North of Shenfield, which could ultimately for circa 825 dwellings (inc affordable provision).
8.3 Specifically, the land controlled by our Client represents the largest area of land within Policy RO3 and is largely supportive of the policy requirements set out in the Local Plan. Our Client is keen to work closely with the Borough Council and adjoining landowners to provide a comprehensive approach to development, and our Client's elements would comprise:
* Circa 510 dwellings (inc. Affordable provision)
* A new Local Centre, inc. potential healthcare;
* A 60-bed care home
* Significant areas of "Green" and "Blue" Infrastructure;
* Other community facilities, inc. sports provision.
8.4 These representations have also set out our Client's support of working closely with the adjoining Shenfield High School to provide for enhanced educational facilities. This would be in the form of funding towards on-site Primary provision to help create a "through-school", plus financial contributions to existing secondary provision (if required).
8.5 We would welcome the opportunity of discussing our concerns, with suggested amendments with BBC and ECC Officers at the earliest opportunity.
8.6 Subject to a number of modifications as recommended in this report, we consider the Local Plan to be largely sound in accordance with the NPPF.

Allowing allocated sites, such as "Officers Meadow" to come forward 1-2 years sooner, to help meet the required 5-yr HLS position.

1.0 INTRODUCTION
1.1 These Representations on the Brentwood Borough Council Reg 19 draft Local Plan have been prepared on behalf of Croudace Homes who are promoting their site (Officers Meadows - site number 034), which falls within the broader allocation of "Land North of Shenfield". The allocation encompasses several land ownerships, including Sites 158, 235, 087, 263 and 276, as well as the "Officer's Meadow" site (034), all of which make up the allocation Policy R03. It should be noted that Croudace Homes has controlling land interest in Site 034 only, therefore whilst development proposals have taken the other sites into account, this document is in respect of the "Officer's Meadow" site.
1.2 "Land North of Shenfield" was previously promoted through the Reg 18 Local Plan process (see Site Allocations Map Jan 2016 which supported the Draft Local Plan) historically as one of three separate strategic sites, now shown in the Reg 19 draft Local Plan site allocation as one site, "Officer's Meadow and surrounding land" (ref. Policy R03) allocated for residential development. The "Officer's Meadow" site is the focus of these Representations to the Reg 19 draft Local Plan and is hereby referred to as "the Site".
1.3 These representations are submitted to the Local Plan consultation document and set out our support for the Brentwood Borough Council (BBC) Local Plan in terms of the proposed spatial strategy and the identification of the Site as an allocation for growth.
1.4 These representations are focused on the Site allocation and demonstrate that the allocation is "sound" and deliverable having regard to National policy and a number of technical matters for the Site. It also reviews the Local Plan in terms of soundness of the Duty to Co-operate, the proposed spatial strategy (inc. Sustainability Appraisal) and other policies in the Plan including for Development Management purposes.
1.5 These representations are supported by technical reports included as appendices, which, on behalf of Croudace Homes, provide the background evidence to support the allocation and demonstrates it is "suitable", "available", "achievable" and therefore "deliverable". This will be referred to in these representations and it has regard to BBC's Evidence Base. The technical reports prepared by the consultant team, detail matters concerning:
* Transport;
* Landscape/Green Belt;
* Drainage;
* Noise
* Ecology;
* Archaeology; and
* Masterplanning.
* Shenfield High School "All through" education provision proposals.
1.6 The following sections of these representations are set out as follows:
* Section 2.0 - National Policy;
* Section 3.0 - Duty to Co-operate;
* Section 4.0 - Local Plan Strategy;
* Section 5.0 - Policy LP R03 -Land North of Shenfield (Officer's Meadow);
* Section 6.0 - Delivery of Land North of Shenfield (Officer's Meadow);
* Section 7.0 - Soundness of other policies in the Local Plan; and
* Section 8.0 - Conclusion.
2.0 NATIONAL POLICY
2.1 This section provides an overview of the NPPF with particular regard to plan-making. Other policies in the NPPF will also be referred to later in these representations.
i) National Planning Policy Framework
2.2 On 24 July 2018, the revised National Planning Policy Framework (2018 NPPF) was published by National Government, setting out the planning policies for England and how these are expected to be applied in both plan-making and decision-taking. Post 24 January 2019 any plans submitted after this date must refer to the revised NPPF. This document therefore focusses on the revised 2018 NPPF.
2.3 The revised NPPF introduces the Government's standardised methodology for assessing housing needs. For those LPAs which do not submit plans within the NPPF's transitional period, the standard method will apply as a starting point for assessing housing needs.
a) Plan-Making
2.4 The NPPF 2018 (Para 35) sets out the requirement for Local Plans to be examined by an independent Inspector whose role is to assess whether the Plan has been prepared in accordance with legal and procedural requirements, and whether it is "sound". An LPA should submit a Plan for Examination which it considers is "sound" - namely that it is:
* Positively prepared (as a minimum seeking to meet the area's objectively assessed needs);
* Justified;
* Effective; and
* Consistent with national policy.
2.5 These representations will assess the Pre-Submission Local Plan against the tests of soundness, as above. The next section details the Duty to Co-operate in this regard.
3.0 DUTY TO CO-OPERATE
3.1 This section considers the legal compliance and procedural matters associated with the Local Plan with regard to the "Duty to Co-operate".
i) Policy Framework
3.2 The "Duty to Co-operate" as provided for in Section 110 of the Localism Act 2011 came into effect on 15 Nov 2011. The "duty" was introduced under the 2011 Act to address the impact of the loss of the "top-down" effect from the Regional Strategy and to offer a transparent way in which LPAs should relate to one another on cross boundary issues. The "duty" is now shared between LPAs requiring them to collaborate on cross-boundary matters and issues of sub-regional and regional importance, especially housing provision and infrastructure issues.
3.3 The NPPF 2018 (Paras 24-27) is clear in directing LPAs as to the importance of the "Duty to Co-Operate" and the pro-active approach necessary to ensure a collaborative approach to reflect individual local plans.
ii) BBC's 'Duty to Co-Operate' (DtC)
3.4 The NPPF recommends that where a Housing Market Area (HMA) extends across more than one local authority plan makers should assess need for housing for the whole HMA, rather than just the individual authority. The SHMA (Oct 2018) sets out that Brentwood District is a self-contained Housing Market Area (HMA). On this basis, no further joint evidence base documents were commissioned, but strategic work continues with South Essex Councils.
3.5 The Objectively Assessed Need (OAN) for BBC amounts to 380 dwellings per annum (dpa) as the SHMA advises that the Council plans on the previous OAN evidence (despite referring to 350 dwellings per annum (dpa) following the current guidance, for the period 2019-2029). In addition, the Council propose additional land allocations over and above "need" (20% above 380 dpa). This approach is welcomed in the SHMA guidance, as overprovision should provide additional flexibility in the supply and delivery of sites.
3.6 Since the draft Brentwood Borough Council Reg 19 Local Plan has been published, the PPG HENA details the standard method for assessing housing need and now clarifies that the 2014-based household projections published by the Office for National Statistics should be used to set the 'baseline' for the standard method calculation. The standard method number for Brentwood is 452 dpa.
3.7 The OAN is 7,752 dwellings during the Plan period (2016 - 2033) and it is welcomed that the Local Plan is seeking to meet this need in full (and potentially overprovide). This is addressed further in the housing strategy section to follow. The Plan also provides an equitable distribution of new homes across the HMA and this will be addressed under the Sustainability Appraisal.
3.8 It is evident that BBC has engaged with neighbouring authorities regarding cross-boundary matters as well as meeting housing need, as set out in the Duty to Co-operate Brentwood Position Statement (February 2019).
3.9 As part of the DtC the Borough would normally need to consider whether it is a sustainable location for unmet cross boundary need. However, as Brentwood is a Green Belt authority (89% is Green Belt), it is unlikely that Brentwood will be in a position to accept any unmet housing need from the South Essex housing market area. The Essex neighbours (Chelmsford and Epping Forest) both have plans submitted for examination that are not reliant on Brentwood accepting any of their housing growth.
3.10 Ongoing Duty to Cooperate work continues with South Essex as part of a strategic growth study and participation in a Joint Strategic Plan.
3.11 The Association of South Essex Local Authorities (ASELA) memorandum of understanding was recently signed by Basildon Borough Council, Brentwood Borough Council, Castle Point Borough Council, Essex County Council, Rochford District Council, Southend on Sea Brough Council and Thurrock Borough Council (Jan 2018). This highlights the constraints and challenges facing other local authorities in terms of meeting their housing needs, and emphasises the importance upon BBC in terms of meeting its own needs in full. We therefore welcome BBC's aspirations in seeking to meet its own needs and indeed in seeking to provide to some flexibility too.
3.12 Duty to Co-operate discussions have confirmed that immediate neighbouring authorities are aiming to meet OAHN within their boundaries, but some will have difficulties in this regard. However, as Brentwood is a Green Belt authority, it is unlikely that Brentwood will be in a position to accept any unmet housing need from the South Essex housing market area.
3.13 To ensure the Local Plan is justified and effective (NPPF, para 35), it is considered that the above issues should continue to be updated in the evolving DtC Statement (February 2019).
3.14 The Council needs to continue to have regard to neighbouring authority plans and adequately co-operate with neighbouring authorities, rather than awaiting the future joint strategic plan, as well as Essex County Council plans, and strategies of other relevant bodies.
3.15 This working can be further supported by the Duty to Cooperate meetings dealing with the strategic planning issues relating to the South East Essex 2050 Programme. Also, the Association of South Essex Local Authorities (ASELA) Statement of Common Ground which includes a commitment to joint working through the preparation of a Joint Strategic Plan for South Essex.
3.16 It is recommended that BBC continues to embrace opportunities to work with the other members of ASELA, as well as producing statements of common ground with its neighbouring authorities, which is a key element of plan preparation, in order to secure a "sound" Local Plan which meets the requirements of the Duty to Co-operate.
4.0 LOCAL PLAN STRATEGY
4.1 This section examines and provides commentary on the proposed spatial strategy in the Local Plan, insofar that it relates to the housing and employment provision, and the allocation of strategic sites for growth including within the Green Belt.
4.2 First, we set out our representations on the Sustainability Appraisal for the Local Plan.
a) Sustainability Appraisal
4.3 The BBC Sustainability Appraisal (incorporating Strategic Environmental Assessment) provides an assessment as to how the spatial strategy for the Local Plan was arrived (identifying, describing and evaluating the likely significant effects of implementing the plan).
4.4 The strategy has evolved from the early 'Pathway to a Sustainable Brentwood' Issues and Options document (2009), which set out a series of strategic objectives. The overarching priorities set out in the Interim SA (Jan 2018) are:
* Environment and Housing Management;
* Community and Health;
* Economic Development;
* Planning & Licensing; and
* Transformation.
4.5 In order to achieve these priorities the following plan themes have been set out (with associated objectives as set out in the SA):
* Managing Growth;
* Sustainable communities;
* Economic prosperity;
* Environmental protection and enhancement;
* Quality of Life and community infrastructure; and
* Transport and Movement.
4.6 Having regard to these themes and objectives, 10 No. reasonable spatial strategy alternatives were drawn up in the SA. The desire to deliver at least one large-scale, strategic site (likely for a mix of uses, to include both housing and employment) is quite well established, recognising: A) limited opportunities within settlements; B) no potential to export 'unmet needs' (as discussed); and C) the alternative of piecemeal Green Belt development dispersed widely has significant draw-backs (this option was appraised within the 2013 Interim SA Report).
4.7 A number of strategic site options have been examined over recent years, including through consultation and SA work, such that there is now a refined understanding of those sites that are genuine contenders for allocation through the Local Plan - There is specific mention of North of Brentwood and ....' the potential for expansion to impact 'in-combination' with other potential extensions to the urban Brentwood/Shenfield area, most notably the potential 825 homes on land at Officers Meadow (directly to the east)'.
4.8 The SA goes on to note that there is a need to give careful consideration to growth opportunities at Brentwood/Shenfield urban area.......Brownfield opportunities are limited; hence there is a need to examine Green Belt urban extension options. All land around the urban area is given brief consideration, with reference to the site options and the designated constraints that exist. Specifically:
North of Shenfield
A large area of land is bounded by the railway line to the east, and the A1023 to the west; plus there is a parcel of land to the north of the A1023, bounded by the A12. There are relatively few designated constraints, although considerations include a spur of Arnolds Wood Local Wildlife Site (LWS), and proximity to the railway and main roads. This land parcel comprises three HELAA sites, all of which are preferred allocations at the current time (Officer's Meadow; Land east of A1023; and Land north of A1023).
[SA of Brentwood Local Plan, January 2019 - page 113]
4.9 Of the options considered, the SA concluded that "Option 3" Dunton Hills Garden Village only, in addition to the sites that are a 'constant' across the reasonable alternatives, was the preferred option for growth as it performs well in terms of the majority of sustainability objectives. Furthermore, the option of identifying the delivery of 'constant' sites was also preferred with the objective of meeting both short and long-term needs.
4.10 We fully support and consider the approach of the Sustainability Appraisal to be "sound" in terms of alternative strategies assessed for the Local Plan and consider that the most sustainable option has been arrived at.
4.11 The SA reviewed site options that could deliver the proposed spatial strategy. This includes "suitable" sites as derived from the SHLAA against a series of 12No SA criteria including Housing, Landscape, Community and well-being and other sustainability considerations. This included a "red, amber, green" assessment of sites as against the selected 12No criteria. We support this approach and consider it to meet the requirements of the SEA in terms of the assessment of environmental impacts - this includes BBC's assessment of the Site at North of Shenfield for which we also fully support and consider to be "sound".
4.12 The process allowed for two strategic site options to be discounted (considered 'unreasonable') given planning/sustainability considerations and deliverability considerations. The extent of reasonable sites has been restricted to balance the need to meet housing needs as well as ensuring that pressure will not be put on infrastructure nor pose a serious risk to air quality, local amenity, natural and heritage assets and biodiversity.
4.13 Our Client's considerations of the Council's Sustainability Appraisal have been informed by the accompanying "Review of Sustainability Appraisal" (Barton Willmore EIA, March 2019), which is attached to these representations. (See Appendix 01).
4.14 The preferred approach is Option 3, which involves allocating Dunton Hills Garden Village only, in addition to the sites that are a 'constant' across the reasonable alternatives (including Officers Meadows), and thereby putting in place an overall land supply sufficient to provide the required housing target dpa (assuming no delayed delivery).
4.15 We support the overall approach to the Sustainability Appraisal, insofar as:
* It follows a robust process in evaluating alternative options for growth as well as specific site options;
* The approach to individual site options is considered to be sound; and
* It is considered to be "sound" in that it arrives at the most reasonable option for growth - Dunton Hills Garden Village in addition to the sites that are 'constant' across the reasonable alternatives- as encompassing the allocation at Land North of Shenfield (034).
b) Housing Strategy
4.16 On 19 February 2019, MHCLG published the long-awaited outcome of the 'Technical consultation on updates to national planning policy and guidance', which clarifies the methodology for assessing housing need incorporated in the updated Housing and Economic Needs Assessment (HENA) Published on 20 Feb 2019. The standard method for assessing housing need is detailed in the PPG HENA and now clarifies that the 2014-based household projections published by the Office for National Statistics should be used to set the 'baseline' for the standard method calculation. The standard method number for Brentwood is 452 dpa.
4.17 In order to provide flexibility in the supply of housing sites, help boost delivery and to aim towards the standard method figure, the Council has proposed a further 20% supply buffer when allocating development sites in the Local Plan above the established annual housing figure of 380 dwellings per year, as set out in the SHMA. The buffer allows for an additional housing supply in the borough to be maintained throughout the Local Plan period and is supported in national planning guidance. The Reg 19 Draft Local Plan refers to 456 dpa based on the 20% SHMA uplift on 380 dpa.
4.18 The Local Plan sets out (Policy SP02) the OAN for housing in the Borough as being 7,752 dwellings during the Plan period (2016 - 2033); which when projected across the 17-year plan period gives an annualised housing delivery target of 456 new homes per year. The Council has not been able to identify a 5-yr HLS that delivers this current annualised requirement. When calculating HLS for our representations we have based our assumptions on 452 dpa which is the most up to date guidance (February 2019).
4.19 As a result of 89% of the Borough being designated Green Belt, the Council advises it is difficult to achieve a five-year supply, as many allocated sites within the Green Belt will not be available until the adoption of the Plan. On this basis a larger proportion of sites will not be delivered until after 2023, when they begin to benefit from detailed planning consent.
4.20 Therefore, a stepped trajectory is proposed, with an initial housing delivery target of 310 dpa to 2023 has been set, followed by a higher target of 584 dpa thereafter, which totals 7,752 homes overall in accordance with Policy SP02.
4.21 The Local Plan (Chapter 4, Policy SP02: Managing Growth) indicates that the residual requirement will be sought largely through new development being directed towards the site allocations set out in Chapter 8; and highly accessible locations along transit/growth corridors. These are as follows and seek to deliver circa. 4,500 units up to 2033:
Table 4: Strategic Sites [see attachment]
4.22 In terms of the allocation at Land North of Shenfield ("Officers Meadow"), this includes an overall requirement across the whole site allocation at Policy R03 for 825 units to be delivered in the Plan period. This delivery schedule is supported and is addressed further in the next section.
4.23 We support the housing strategy for the Local Plan and welcome that BBC is seeking to meet its housing needs in full. This is particularly important having regard to the likely inability of adjacent authorities (referred to on page 5) to meet their own needs. We therefore consider the housing strategy in the Plan to be "sound" in accordance with the NPPF (Para 35).
c) Employment Strategy
4.24 Policy PC02: Job Growth and Employment Land identifies that provision is made for at least 47.39ha of new employment land (B-use) to address the needs of the Borough up to 2033. To ensure that the Plan is more effective, it is recommended that this is followed by supporting text setting out the extent of need as derived from the Brentwood Economic Futures report (2018) and Strategic Housing Market Assessment (2018).
4.25 This need is proposed to be met through allocations set out at Policy PC03: Employment Land Allocations. This includes provision of appropriate new employment development on North of A1023 (part of the Land North of Shenfield R03 land use allocation). We fully support this aspect of the Plan including the broad strategy underpinning both the housing and employment allocations. The employment strategy for the Local Plan is justified and "sound" in line with the NPPF (para 35).
d) Five-Year Housing Land Supply
4.26 The Local Plan is unclear in terms of being able to demonstrate a 5-yr HLS of housing land for the purposes of the Plan.
4.27 The most recent AMR (Nov 2018) demonstrates that BBC currently has a supply of 4.1 years - against requirement of 411.6dpa (2,058 units over 5-years) which encompasses a 20% buffer as required by the NPPF and Housing Delivery Test. This is as a result of persistent under delivery, as delivery is currently calculated as 50.83% for BBC, below the 85% requirement.
4.28 The AMR 5-yr supply relates to the period 2018/19 - 2023 and concerns, inter-alia, sites with planning permission, existing commitments and strategic sites at Dunton Hills Garden Village, West Hordon Industrial Estate, Ford Headquarters, etc. The Plan's trajectory details the delivery at proposed allocated sites (2016/17 - 2032/33) amounting to 6,088 units.
4.29 The 2018 AMR suggests the delivery of 819 units (Allocations, Reg 19 Local Plan) within the same timeframe (2018-2023). The figure is derived from existing permissions, developments, allocations and commitments, as well as the 20% buffer, is 1,694.7 units, and concludes the supply is 4.1 years (as set out below):
Table 6: Five Year Supply Position (2018-2023) [see attachment]
4.30 The AMR 2018 refers to the PPPG: HELAA, which sets out how a 5-yr HLS is measured where LPAs have a "stepped" rather than annual average requirements; it states:
Five-year land supply is measured across the plan period against the specific stepped requirements for the particular 5-year period. Stepped trajectories will need to ensure that planned housing requirements are met fully within the plan period.
[Paragraph 017, Reference ID: 2a-017-20180913]
4.31 The AMR 2018 sets out (Table 4: Comparison of annualised housing delivery target and projected completions) a housing delivery target of 7,752 homes (456 dpa over the 17-year Plan period), together with annualised projected housing completions. The report states that from a comparison of this data an initial stepped requirement of 310dpa to 2023, followed by a higher stepped up requirement of 584dpa for the remainder of the Plan period, is a logical approach to reach 7,752 homes by 2033.
4.32 As a result of the high proportion of Green Belt in the Borough, it is extremely difficult to achieve the annualised 5-yr HLS requirement. This is because, as set out in the AMR 2018, sites on the edge of settlements currently within the Green Belt are not available for development purposes until the emerging Local Plan is adopted. Therefore, the potential for a stepped trajectory has been proposed, which delivers a greater proportion of the required homes beyond 2023.
4.33 The above demonstrates that BBC is not fully able to demonstrate a 5-yr HLS for Local Plan purposes. This position could be expedited by allowing allocated sites, such as "Officers Meadow" to come forward 1-2 years sooner, within the present 5-year period, to help meet the required 5-yr HLS position.
5.0 LAND NORTH OF SHENFIELD - POLICY R03
5.1 Land North of Shenfield (Policy R03: Strategic Site - Land North of Shenfield) is allocated in the Pre-submission Reg 19 Local Plan and the extent of the allocation is shown below:
Figure 1: Land North of Shenfield- Allocation Area [see attachment]
5.2 This shows the Site area as allocated as a whole; despite Land North of Shenfield having 6 land parcels within it, namely Site parcels 034, 158, 235, 087,263 and 276, as identified at Appendix 1: Housing Trajectory in the Reg 19 Local Plan and previously set out in earlier iterations of the Reg 18 Local Plan suite of documentation.
5.3 We set out below our comments on Policy RO3 and Appendix 1- Housing Trajectory in regard to the proposed delivery rates. This is largely supportive, however there are some aspects we do not consider to be "sound".
i) Amount and Type of Development:
a. Provision for around 825 new homes of mixed size and type, including affordable housing.
5.4 This criterion is supported/considered to be sound and "effective" in accordance with the objectives of the NPPF (para 61) relating to creating mixed and balance communities. The proposals for the Site will therefore be able to be delivered in accordance with this policy objective.
b. Provision of land (circa 2.1 hectares) for a co-located 2FE [additional text] primary school and early years and childcare nursery (Use Class D1). To be located adjacent to Alexander Lane. [additional text]
5.5 We largely support this criterion, albeit consider it should be amended (as above) to provide for greater clarity. Therefore as presently worded, we object to this criterion.
5.6 Forecasted figures contained in 'Commissioning School Places in Essex 2016-2021' indicate that there will be a deficit in pupil places by 2020/21 when accounting for demographic factors and the proposed uplift in residential development.
5.7 Earlier/recent work undertaken by the High School (and others) considered the anticipated need for a new 1FE Primary School. The proposed policy wording should clarify that it is now proposing a 2FE Primary School. We have prepared an accompanying note (Appendix 02) that reflects are discussions in this regard.
5.8 Consideration should be given to the location of the Primary School. Again, the recent work undertaken by the High School has examined this, inc the early years facility and nursery element, and that it should ideally be located on the existing school playing fields, just north of Alexander Lane. This would enable the Shenfield High School to deliver an 'all through' school provision, comprehensively expanding the educational offer available on-site.
5.9 The NPPF (para 94) seeks that LPAs take a proactive, positive and collaborative approach to meeting school place requirement and to development that will widen choice in education. The principles of this element of Policy R03 is therefore "consistent" with the NPPF, but the wording should be clarified further. We would be happy to continue discussions with Shenfield High School, BBC & ECC Officers in respect of seeking to agree the most suitable location for the primary school provision.
5.10 In terms of its own generated education requirements, the allocation would give rise to a need for a 1FE Primary School and financial contributions towards secondary school provision. Through positive discussions with Shenfield High School, we have been working closely towards its objective of becoming a "through-school" (by encompassing Primary provision) and contributing towards secondary provision (at the High School) on a pro-rata basis.
c. Provision for a residential care home (around 60 bed scheme as part of the overall allocation).
5.11 The principle of this criterion is supported/ considered to be sound and a care home could be accommodated on the 'Officer's Meadow' site, however this should be subject to the balanced and reasonable distribution of other infrastructure across the Site allocation as a whole. The NPPF (section 5) on "Delivering a Sufficient Supply of Homes" requires that housing need for different groups in the community should be assessed and reflected in planning policies. The provision of a residential care home in Policy R03 would contribute towards the offer of care for older people in Shenfield and is therefore "consistent" with the NPPF, in accordance with national policy and is deemed sound.
d. Provision for up to [additional text] 5% self-build and custom build across the entire allocation area.
5.12 The principle of this criterion is supported, but not as presently worded. We therefore object to this criterion in its present form.
5.13 Section 1 of the Self-Build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) requires each relevant authority to keep a register of individuals and associations seeking to acquire serviced plots for their own self-build and custom housebuilding. Whilst the provision of self-build and custom build should be considered, the evidence base for a 5% need across the entire allocation should be addressed against the local "needs register" and demand for such provision at the prevailing time.
5.14 In order to align with National policy, the evidence base and local need should be fully assessed before any commitment is made to the provision of this house type in this location. It is therefore considered that this element of Policy R03 is unsound.
5.15 It is recommended that this aspect of the policy is amended to "up to" 5% as shown above, to reflect prevailing "need" at the time.
e. Provision of 2ha of land for employment purposes.
5.16 The provision of 2ha of employment land as part of the wider allocation is agreed in principle. Employment land situated on land north of Chelmsford Road, as per the location identified in the BBC Site Analysis Overview report (Feb 2019), is supported, given its location adjacent the A12. This is the most appropriate location for such provision and is "consistent" with the NPPF (para 20). Therefore, and if situated in this location, this criterion is considered sound.
ii) Development Principles:
a. Comprehensive masterplan and phasing strategy to be prepared and considered as planning applications come forward.
5.17 We support this criterion and it is confirmed that development can come forward and be delivered within the timescale as shown in the housing trajectory. We also support a comprehensive masterplan and phasing strategy to set out effective phasing of the requisite infrastructure, as identified in the Infrastructure Delivery Plan (IDP) is "consistent" with the NPPF and is considered sound.
5.18 The overall needs of development must have regard to potential considerations in terms of viability in order to be fully "justified", something not yet addressed in the IDP, which should be rectified in the next iteration of the IDP.
b. Site is identified as a key gateway location and development should reflect this in terms of design quality particularly on land near to Junction 12, A12.
5.19 We broadly support these provisions and the concept masterplan sets out conceptually the land take for development in this location, including the key gateway employment location and residential, however this land is not within our Client's control and as such will be the subject of a separate planning application and detailed framework masterplan. In principle, and from an overall design perspective, this key gateway location is consistent with Section 12 of the NPPF and is "justified" and therefore considered sound.
c. Vehicular access via Chelmsford Road (A1023) and Alexander Lane.
5.20 It is recognised that the delivery of vehicular access via Chelmsford road and Alexander Lane is a necessity as part of these proposals. Our Client's accompanying Transport Strategy (Vectos, March 2019) provides evidence to support the development of the Officer's Meadow Site in terms of reducing the need to travel and providing opportunities for non-car travel. This is "consistent" with the NPPF, in particular Section 9 on "Promoting Sustainable Transport". The provision of access via both Chelmsford Road (A1023) and Alexander Lane allows for flexibility in terms of phasing and means that development can take place simultaneously in more than one location on the Site. It is therefore considered that this criteria is sound.
d. Potential for diversion of Alexander Lane, creating a quiet lane for pedestrians and cyclists, with the provision for new and improved route through the development site linking to Chelmsford Road.
5.21 The potential diversion of Alexander Lane is welcomed in terms of pedestrian safety and improved access. This is because a quieter Alexander Lane will improve access to local schools, pedestrian and cycle infrastructure and the existing PRoW, encouraging active mobility. This policy is therefore considered "justified" in light of the NPPF (para 102).
e. Enhancing sustainable links with Shenfield station and local services and facilities in the wider area.
5.22 The accompanying (Vectos) Transport Strategy confirms that the travel opportunities afforded by the service at Shenfield Railway Station and local bus routes will ensure that travel by public transport is a realistic option for future residents. The NPPF (para 102) states that opportunities to promote public transport use should be identified and pursued by Local Plans. This policy is therefore considered to be "consistent" with the objectives of the NPPF and is sound.
f. Provide well-connected internal road layouts which allow for good accessibility.
5.23 The development of Officer's Meadow would provide opportunities to encourage walking and cycling through new and improved routes and crossing facilities. Improving the accessibility within an already sustainable setting will also help to minimise vehicular traffic, in accordance with National policy. This is "consistent" with the NPPF objectives set out in both Section 8 "Promoting Healthy and Safe Communities" and Section 9 "Promoting Sustainable Transport" .
g. Provision for new multi-functional green infrastructure including public open space.
5.24 The provision of green infrastructure and open space throughout the Site is supported. The development of Officer's Meadow introduces the opportunity to introduce ecological corridors, open space and green infrastructure linkages, as well as enhancing the recreational resource and connectivity value of the Site. The NPPF (para 181) states that planning policies should maximise opportunities for green infrastructure provision and enhancement. This policy is therefore considered "effective" in terms of meeting the requirements set out in the NPPF.
h. Maintain and enhance Public Right of Way within the site and to the wider area.
5.25 Our Client's accompanying Landscape Assessment (Barton Willmore, March 2019) provides information to support the maintenance and enhancement of the existing PRoW on site. Although limiting development, this PRoW allows for the opportunity to introduce ecological corridors, open space and green infrastructure linkages. The NPPF (para 98) states that policies should protect and enhance the PRoW, including taking opportunities to provide better facilities for users. It is therefore considered that this policy is "consistent" and sound in accordance with the NPPF.
i. Protect and where appropriate enhance the Local Wildlife Site (Arnold's Wood).
5.26 Arnold's Wood comprises a narrow strip of Ancient Woodland to the north and the east of the Site. The accompanying Ecological Report (Aspect Ecology (March 2019) identifies this feature as a Local Wildlife Site, whereby appropriate conservation and enhancement through development is a priority. The NPPF (para 170) seeks that planning policies contribute to and enhance the natural and local environment by protecting valued landscapes and sites of biodiversity value, such as area of ancient woodland. The protection and enhancement of the Local Wildlife Site is therefore "justified" with regard to the NPPF, leading to the consideration of this policy as sound.
j. Provide for appropriate landscaping and buffers along sensitive boundaries adjoining the A12 and railway line.
5.27 Our Client's emerging proposals have been informed by a series of technical reports, including the Landscape Report, which provides for a planted buffer to be provided along the A1023 Chelmsford Road to help soften views of the proposed residential development at Officer's Meadow. This policy is therefore "effective" in terms of protecting residential amenity and enhancing the natural environment. The use of appropriate landscaping buffers is also in accordance with the NPPF (Section 15) on "Conserving and Enhancing the Natural Environment", making this criterion sound.
iii) Infrastructure Requirements:
a. Provide pedestrian and cycle crossing points across Chelmsford Road (A1023) where appropriate.
5.28 The accompanying Transport Strategy (Vectos) provides for new and enhanced pedestrian and cycle connections within the Site and to the wider area. As individual development parcels are separated by Chelmsford Road, pedestrian and cycle crossings are required where appropriate to allow safe connection between parcels (as identified in by Infrastructure Requirements). This criteria is therefore supported as the provision of crossing points across Chelmsford Road (A1023) will help to maximise opportunities for sustainable transport modes throughout the Site, to Shenfield railway station and various local services. The NPPF (para 104) states that planning policies should provide for high quality walking and cycling networks. This policy is therefore considered "consistent" with national policy.
b. Provision for improved bus service.
5.29 The provision of an improved bus service, with reference to the IDP, is supported. This criterion is sound in the light of Para 110 of the NPPF. It is therefore "justified".
c. The Site is located within a Critical Drainage Area. This development may have the potential to impact on the Critical Drainage Area in respect of surface water flooding. As a result of this, the site is likely to require an individually designed mitigation scheme to address this issue.
5.30 The majority of the Site is located within Flood Zone 1. As referred to in the accompanying Drainage Report (JNP, March 2019), the critical drainage can be dealt with by the creation of a surface water storage basin/wetland area to attenuate and release the overland surface water flows from off site at a reduced rate. An individually designed mitigation scheme can be implemented on-site via a variety of SuDS, in accordance with the provisions of the NPPF (para 163). These components will also adequately provide for surface water flows generated by the proposed development. The above criteria is therefore considered to be sound and "effective".
5.31 In addition to the above elements of physical infrastructure, and as mentioned previously in respect of other aspects of Policy RO3 allocation, we are also mindful of accompanying social infrastructure - in particular the educational needs of the resultant residents and the relationship with the adjoining Shenfield High School. It is therefore appropriate to reiterate our Client's willingness to work closely with the High School in helping to deliver its aspirations in providing for a "through school" (with Primary provision) and our off-site educational financial contributions will be directed to support this.
5.32 In overall terms, we largely support the provisions of Policy RO3 and have sought to reflect this is the accompanying illustrative concept masterplan, which demonstrates the delivery of the requisite infrastructure for the Site Allocation as a whole including:
- Social infrastructure - primary school, early years and nursery care;
- Transport infrastructure - pedestrian and cycle crossing points;
- Critical drainage mitigation; and
- Blue and Green Infrastructure.
5.33 The above demonstrates our overall support for the allocation of the Site and we can confirm that the proposed development is deliverable within the timescales established by BBC. The delivery of Land North of Shenfield ("Officer's Meadows") is addressed in the next section.
6.0 DELIVERY OF LAND NORTH OF SHENFIELD
6.1 A range of technical work and evidence has been worked up for the Site and which demonstrates the deliverability of the proposals. This technical input is set out in full in the Technical Representations accompanying these submissions.
6.2 This report therefore does not seek to repeat the technical material in full, instead it provides a summary of the main disciplines and how they relate to the delivery of the project.
6.3 This includes work in relation to the following disciplines:
i) Transport (Vectos);
ii) Landscape/Green Belt Assessment (Barton Willmore Landscape);
iii) Drainage (JNP Group)
iv) Noise (Sharps Gayler)
v) Ecology (Aspect Ecology);
vi) Archaeology (Albion Archaeology); and
vii) Masterplan (Barton Willmore Design).
6.4 Below is a brief summary of each of the update reports submitted in terms of the delivery of the scheme.
i) Transport
6.5 The accompanying Transport Strategy (Vectos) (Appendix 03) sets out the principle of a sustainable transport strategy for Officer's Meadow, reducing the need to travel and providing opportunities for non-car journeys. The proximity of the Site to local services and the proposed 'all through' school across the wider site will reduce trip generation and promote sustainable communities.
6.6 The Transport Strategy identifies the junction location i.e. A1023 Chelmsford Road/A129 Hutton Road/A1023 Shenfield Road and the appropriate mitigation measures, which include the implementation of MOVA or similar as a mitigation, in order provide adequate capacity. The access and egress via Alexander Lane will be provided in the form of simple priority junctions.
6.7 The new access points/roundabouts can be fully accommodated within the Site area and/or on highway land. Highways improvements are therefore deliverable as part of the comprehensive development for the scheme. As such, Land North of Shenfield is suitable for allocation in the Local Plan, in terms of highways and transport constraints.
ii) Landscape and Visual Appraisal/Green Belt Review
6.8 A Landscape and Visual Appraisal (BW Landscape) (Appendix 04) has been undertaken to provide a review of the landscape character and visual amenity of the Site and surrounding area. These aspects have informed the parameters of the illustrative masterplan and have demonstrated that the Site is suitable to be released through 'exceptional circumstances' for development, as addressed below. It supports BBC's removal of Land North of Shenfield from the present Green Belt designation, which presently washes over the entire Site and its surrounding environs.
6.9 Direct adverse impacts of development on the wider Green Belt setting would be minimised by locating strategic open space on prominent land, particularly in the north east the Site. Low density housing could be located in the most prominent areas, framing the retained Ancient Woodland area to the north and east of the Site. A PRoW also traverses the Site, enabling the introduction of ecological corridors, open space and green infrastructure linkages, as well as enhancing the recreational resource and connectivity of the Site.
6.10 Development of the Site would form a logical extension that is in keeping with the existing settlement, better connecting the ribbon development between Chelmsford Road and the settlement edge of Alexander Lane. In terms of visibility, glimpses of the Site can be seen from elevated views to the west. However, the landform ensures that it is largely well contained by a combination of vegetation cover and built form, restricting long-distance views. A landscape-led approach to development within the Site would seek to ensure that existing defensible boundaries continue to prevent unrestricted sprawl.
6.11 The LVA concludes that allocation of the Site would result in successful assimilation and integration of new residential development, with the potential for adverse effects on the landscape setting moderated, as required by the NPPF. The Site is considered to be of "low sensitivity" as it is of a low landscape value and the localised visual envelope of the Site, coupled with the surrounding land uses, lends itself to residential development. The Site makes a minimal contribution towards the 5No purposes of the Green Belt, making it suitable for release and able to contribute towards a suitable pattern of development for Shenfield.
iii) Drainage
6.12 A Flood Risk and Drainage Note has been prepared (JNP Group) (Appendix 05). This confirms the location of the majority of the Site within Flood Zone 1, where there is the lowest probability of flooding and where new development should be steered. A small part of the Site is located within Zones 2 and 3. Built development (housing, social infrastructure, etc.) will avoid Flood Risk areas.
6.13 All proposed buildings within "Officer's Meadows" are to be located in Flood Zone 1. Essential infrastructure which passes through a small area designated as Flood Zone 3 will be subject to the "Exception Test" and site-specific flood risk assessment to demonstrate safe access & egress from the site and that the development does not increase flood risk both on and off site. Safe access & egress will be provided off Chelmsford Road A1023 and Alexander Lane. Where affected, allowance for flood compensation storage will be provided to ensure no net loss in flood storage.
6.14 The critical drainage can be dealt with by the creation of surface water storage basins/wetland areas to attenuate and release the overland surface water flows form off site at a reduced rate. Development generated surface water flows can be dealt with via SuDS components and a storage basin/wetland attenuation area. The Site is therefore suitable and deliverable from a flood risk and drainage perspective.
iv) Noise
6.15 An assessment of "likely noise constraints" has been undertaken (Sharps Gayler) (Appendix 06) to identify potential constraints relating to noise and vibration upon Officer's Meadow. The below conclusion is based on a desktop assessment, informed by computer modelling of transportation noise sources in the area (A12, A1023 and the mainline railway).
6.16 Whilst there is a low to medium risk on the boundaries of the Site with Chelmsford Road and the rail line, the majority of the Site presents a low risk. At low noise levels, the Site is likely to be acceptable from a noise perspective, provided that a good acoustic design process is followed at the detailed application stage, particularly for development within 50m of Chelmsford Road and the rail line.
6.17 The assessment concluded that there are no significant constraints on Site in relation to noise. Land North of Shenfield is therefore suitable and deliverable from an acoustic perspective.
v) Ecology
6.18 An Ecological Appraisal has been undertaken (Aspect Ecology) (Appendix 07). This report confirms that the Site comprises a range of habitats including arable, woodland, grassland, watercourse, hedgerows, scrub and lines of trees. The woodland at the north-east of the Site, the watercourse and the hedgerows are of elevated ecological value and are considered to be important ecological features.
6.19 Protected species such as bats, badgers, dormice and reptiles have not been identified within the vicinity of the site at this stage. Although thought to have 'good' suitability for Great Crested Newt, a DNA survey (2015) found the pond nearest to the Site unlikely to support a Great Crested Newt population. A further Great Crested Newt presence/absence survey of all relevant ponds associated with the Site is to be undertaken in 2019.
6.20 The habitats at the Site are currently unmanaged from an ecology point of view and the development proposal presents the opportunity of securing suitable management practices, appropriate mitigation and 'net gains' in terms of biodiversity. When considering ecological constraints, the Site is therefore both suitable and deliverable, subject to further survey work.
vi) Heritage Assessment
6.21 A Desk-based Heritage Assessment (Albion Archaeology) accompanies these representations, which has also been informed by a preliminary walk-over of the Site. The accompanying report (Appendix 08) reviews the potential for below ground archaeological interest and potential impact arising from development on such features; as well as an assessment of any direct impact on potential heritage assets.
6.22 No heritage assets other than the crop mark of a bomb crater, have been recorded in the proposed development area. Other heritage assets comprise former buildings, the postulated course of a Roman road, find-spots and historic settlement cores, whose setting will not be impacted by the proposed development. The adjacent railway lines, roads, buildings and vegetation suggest that the proposed new buildings are unlikely to be visible from these heritage assets. The potential impact on the setting is therefore assessed as "no change". The significance of this impact is "insignificant".
6.23 The potential for archaeological remains has been assessed covering prehistoric to modern periods. In general terms the "significance" of any remains is low to moderate. Any potential impact of the new development on potential buried archaeological remains could be mitigated by measures to investigate and record the presence/absence of potential archaeological assets. Officer's Meadows is thereby deliverable from an archaeological perspective.
vii) Masterplan
6.24 The accompanying illustrative concept masterplan (BW Design) (Appendix 09) has been developed in response to the above technical information prepared for the Site.
6.25 This demonstrates the ability of the Site itself to deliver:
* Circa 510 homes ("Officer's Meadow" site) inc. affordable provision;
* The proposed dwellings can be delivered within the timescale of the housing trajectory, with varying densities;
* Other potential linkages to Chelmsford Road (A1023) and Alexander Lane;
* A 60-bed care home;
* A Local Centre/ community facility;
* Multi-functional green and blue infrastructure; and
* Sustainable transport links.
6.26 Moreover, the illustrative concept masterplan also demonstrates the delivery of:
* Significant areas of Public Open Space encompassing:
- Natural and Semi-Natural Green Spaces;
- Outdoor Sports Facilities; and
- Children's/Young People's Play Area.
* Primary School provision on the adjoining Shenfield High School.
6.27 The above provides an overview of the technical inputs to the Land North of Shenfield (Officer's Meadow) and which confirms that the Site and proposals for it are deliverable within the Local Plan context. The proposals for the Site form part of an iterative process and further information will come to light in advance of a planning application to ascertain the detailed parameters for the Site.
6.28 These matters will be "screened" for a full Environmental Impact Assessment for a subsequent planning application, and it is envisaged the EIA Screening will be submitted later in 2019.
7.0 SOUNDNESS OF OTHER LOCAL PLAN POLICIES
7.1 This section does not seek to comment on other specific allocations/sites. Instead it focuses on policies of relevance within the Local Plan and sets out our comments and recommendations on these in terms of the tests of soundness in the NPPF.
7.2 Policy SP01: Sustainable Development takes a positive approach towards "Presumption in Favour of Sustainable Development" and seeks to apply this in terms of planning applications, in accordance with the Development Plan. The NPPF (para 11) assumes a strong "Presumption in Favour of Sustainable Development" in all planning related matters and places a responsibility on LPAs to positively seek opportunities to meet the development needs of their area and to, as a minimum, provide for objectively assessed needs for housing and other uses. This policy is "consistent" with the NPPF and is therefore sound.
7.3 Policy SP02: Managing Growth seeks to support the delivery of homes by setting out provision for 7,752 new dwellings to be built over the Plan period 2016-2033, at an annual rate of 310 dwellings up to 2022/2023, followed by 584 dwellings from 2023/24-2033. This objective is not supported, as it is considered that this stepped trajectory which delivers a greater proportion of the required homes beyond 2023, could be reviewed to allow more housing to come forward from the period 2021 onwards. This is with particular reference to NPPF (para 23) which states that "strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs". This policy is therefore "not consistent" with the NPPF and not sound.
7.4 We consider that in order to address this, the Council should review its housing trajectory and at the same time, clarify the new dwelling number ahead of the Local Plan submission, to align with the February 2019 agreed position on the 'baseline' for the standard method calculation.
7.5 The Council should, in addition, work with developers to bring applications forward in advance of the adoption of the Local Plan, to meet housing need.
7.6 Policy SP03: Health Impact Assessments (HIAs) states that Brentwood Borough Council is committed to ensuring all new developments promote healthier and inclusive environments. The majority of proposals will be required to assess their impacts on health and well-being upon the capacity of existing health care and social care services and facilities, the environmental impacts, and the promotion of health improvement activities, arising from the development. Developments of 50 or more units are required to submit a Health and Well-Being Impact Assessment, as required by the EPOA HIA Guidance Note.
7.7 This policy is considered to be unsound as it is not "justified". The requirement to undertake a Health Impact Assessment (HIA) is a superfluous burden on applicants. It should be down to the Local Plan to take into account wider health concerns in the local area and focus policies upon addressing these concerns. Health and well-being should be covered within the polices of the Local Plan and where a development aligns with these, an HIA should not be required.
7.8 Policy SPO4: Developer Contributions refers to the need for all new development to be supported by, and have good access to, all necessary infrastructure. Developers and land owners must work positively with the Council, neighbouring authorities and other infrastructure providers throughout the planning process to ensure that the cumulative impact of development is considered and then mitigated.
7.9 Applicants proposing new development will be expected to make direct provision or contribute towards the delivery of relevant infrastructure, as required by the development either alone or cumulatively with other developments. The Infrastructure Delivery Plan (IDP) identifies the types of infrastructure required to support the anticipated growth in the borough and includes a summary of the current identified infrastructure projects.
7.10 Policy SPO4 should be more explicit on the exact nature of requirements that the developer may be required to meet to avoid overly onerous requirements or confusion over cumulative impact and phasing with other developments and therefore this policy is not "justified" and is unsound.
7.11 Policy SP05: Construction Management states that all major development should sign up to the Considerate Constructors Scheme, or equivalent. Major development must consider the cumulative impacts of other major development occurring in the vicinity, to reduce the cumulative impacts.
7.12 It is considered that this policy accords with the NPPF and is therefore found to be sound, with particular reference to NPPF (para 72) which refers to larger scale development supported by the necessary infrastructure and facilities.
7.13 Policy SP06: Effective Delivery of Development states that proposals for large allocation sites will be expected to be developed in partnership with the Council, infrastructure providers and other relevant organisations, through a collaborative masterplanning approach. Development proposals should submit a supporting statement setting out the sustainable long-term governance and stewardship arrangements for community assets including land, services and facilities such as village halls, community centres, libraries, parks, green spaces, and buildings for sports, leisure, healthcare, education, social, arts and cultural activities. This policy is overly onerous and therefore "unjustified". This policy is therefore considered to be unsound.
7.14 Policy BE02: Sustainable Construction and Resource Efficiency requires all development proposals to maximise the principles of energy conservation and efficiency. Whilst the NPPF (para 153) has regard to the inclusion of renewable and decentralised energy as part of a new development, it states that such features are only required where it is either feasible or viable. This policy is therefore not "consistent" with National Policy.
7.15 We therefore object to the policy in its present form. In order to ensure consistency with National policy, criteria (f) of Policy BE02 should be revised to mirror the NPPF position. Therefore, it is considered that proposed Policy BE02 is unsound.
7.16 Policy BE03: Carbon Reduction, Renewable Energy and Water Efficiency states that proposals for renewable, low carbon or decentralised energy schemes will be supported, subject to adverse cumulative and visual impacts, which cannot be satisfactorily addressed. Criteria (b) of the proposed policy sets out the minimum standards of sustainable construction and carbon reduction. It is Government policy to seek to deliver improvements to emissions from buildings through the application of building regulations. It is therefore considered that the table provided in proposed Policy BE03 is not required, and therefore this policy is "unjustified" and unsound.
7.17 Policy BE04: Establishing Low Carbon and Renewable Energy Infrastructure Network sets out that developments will be required to provide for the necessary infrastructure to meet the needs of the development, specifically stand-alone renewable energy infrastructure. The policy advises that new development of over 500 units, or where the clustering of neighbouring sites totals over 500 units, will be expected to incorporate decentralised energy infrastructure.
7.18 The supporting text refers to the need for District heating networks and the identification of Strategic allocations in the Brentwood IDP, including the Officers Meadow's masterplan area, that could provide opportunities for DH and CHP schemes as energy solutions for new development.
7.19 This policy is considered overly onerous and "unjustified" in relation to the NPPF and therefore unsound.
7.20 In order to make the policy more effective, it could set out that the delivery of renewable energy infrastructure should be required based on evidence of need and viability and a "viability assessment" (at the time planning applications are submitted/determined) - as per Policy SP04.
7.21 Policy BE08: Sustainable Drainage seeks that all developments should incorporate appropriate Sustainable Drainage Systems (SuDs) for the disposal of surface water, in order to avoid any increase in flood risk or adverse impact on water quality. Larger sites over 1 hectare in Zone 1 must be accompanied by a Flood Risk Assessment. Water runoff will comply with the requirements of this policy by provision of SuDS in the surface water drainage strategy. The NPPF (para 163) refers to the need for local planning authorities to ensure that flood risk is not increased elsewhere. Where appropriate, applications should be supported by a site-specific flood-risk assessment. This aspect of the policy is therefore considered "consistent" with the NPPF.
7.22 Given the extensive nature of the development, opportunities exist to incorporate the above the SuDs management across the site both locally and site-wide. However, the requirement for prevention if run-off for all rainfall events up to 5mm is in excess of the SuDS manual and is therefore "unjustified". Unfortunately, this therefore renders the overall Policy BE08 to be unsound.
7.23 Policy BE10: Connecting new developments to digital infrastructure seeks to support Brentwood's economic growth and productivity by improving the offer of digital infrastructure available within the Borough. Whilst planning strives to achieve the highest possible standards of construction and performance for new dwellings, Council's should not seek higher standards than Building Regulations on any other technical standards. Proposed Policy BE10 is therefore "unjustified" in light of National policy and therefore unsound.
7.24 Policy BE11: Strategic Transport Infrastructure requires that development in proximity of the railway stations demonstrate how the scheme connects the surrounding walking, cycling and public transport links to the station, linking new developments with the fast high-capacity transport links into London from Shenfield and the improved linkages from the Elizabeth line. Development close to schools and early years childcare facilities should facilitate an attractive public realm that is safe for children and encourages walking and cycling to address the impacts of school run traffic, in line with ECC's Developers' Guide to Infrastructure Contributions. This aligns with the NPPF (section 9) on "Promoting Sustainable Transport". These considerations therefore appear to be "justified", in accordance with national planning policy and therefore the policy is sound.
7.25 Policy BE13: Sustainable Means of Travel and Walkable Streets and Policy BE16: Mitigating the Transport Impacts of Development refers to sustainable modes of transport that should be facilitated through new developments, promoting accessibility and integration into the wider community and existing networks. Any development requiring a new road or road access, walking and cycling facilities and public transport, will be required to have regard to the adopted ECC's Development Management Policies or successor documents.
7.26 The policies seek to secure developments that are, inter-alia, designed to make necessary contributions to the improvement of existing infrastructure and provision of new infrastructure; be consistent and contribute to the implementation of the Essex County Council's Development Management Policies and include Transport Assessments and Travel Plans. This aligns with the NPPF (section 9) "Promoting Sustainable Transport" and is therefore considered "justified" and sound.
7.27 Policy BE17: Parking Standards refers to the vehicle parking requirement set out in the most up-to-date Essex Parking Standards. The NPPF (para 105) states that when setting local parking standards policies should take into account: a) the accessibility of development b) the type, mix and use of development c) the availability of and opportunities for public transport d) local car ownership levels and e) the need to ensure an adequate provision of spaces for charging plug-in and ultra-low emission vehicles. This aligns with the flexibility allowed for in Policy BE17, whereby the imposed parking standards are subject to the site's ability to minimise pressure on land and encourage the use of alternative modes of transport.
7.28 However, Policy BE12 also deals with "parking matters", but is not aligned with Policy BE17. This adds further inconsistency, in addition to Policy BE17 itself being "inconsistent" with the NPPF. It is therefore presently unsound.
7.29 Policy BE18: Green and Blue Infrastructure requires that Brentwood's existing ecological networks, open spaces, and green/blue features within the built environment are protected, planned, enhanced and managed as a part of the Borough's wider network of green and blue infrastructure. Points A-I of Policy BE18 identify the measures by which development proposals can maximise opportunities to protect and enhance green and blue infrastructure, aligning with the NPPF (section 15) "Conserving and Enhancing the Natural Environment".
7.30 However, it is presently unclear how any net gains/losses and any associated requirements would be measured/calculated, or the mechanism by which the Council or developer would deliver this. This is therefore both "unjustified" and "inconsistent", and therefore unsound.
7.31 Our Client largely supports the principle of Policy BE18, but it also unfortunately includes the requirement for a developer to ensure there is sufficient foul capacity within the local network before a development commences. Whilst our Client would liaise with Anglican Water, it is ultimately the Water Authority's responsibility to ensure sufficient capacity. Therefore as presently worded, the policy is "unjustified" and is unsound.
7.32 Policy BE19: Access to Nature seeks that major developers provide direct access to nature and that this provision is protected, planned, designed and managed as an integrated feature of the landscape. Developments in areas that are more than 1km walking distance from an accessible green open space should also seek opportunities to improve resident's experience and interaction with nature by means of design. The NPPF (section 8) "Promoting Healthy and Safe Communities" states that planning policies should be based on robust and up-to-date assessments of the need for open space, this policy is therefore deemed to be "consistent" with the NPPF and sound.
7.33 Policy BE22: Open Space in New Development seeks that major developments provide functional on-site open space and/or recreational amenities, in accordance with standards set out in the Council's Open Space Standards (see Figure 5.4 Open Space Standards and Fig 5.5 Fields in Trust Children's Play Space Standards in the Reg 19 Local Plan). Maintenance Plans should be submitted at planning application stage for all new facilities provided for exercise or recreation purposes.
7.34 The Council's Open Space Standards seek proposals which meet the Fields in Trust (Guidance for Outdoor Play Space: Beyond the Six Acre Standard) minimum standards. The FiT standards relate to provision on the basis of hectares per 1,000 population generated. The Council's Open Space Standards are considered to be effective as they are based on FiT standards and are therefore "justified" and the policy is sound.
7.35 Policy BE23: Open Space, Sport and Recreational Facilities states that permissions will not be granted for the development of designated Protected Urban Open Space or Local Green Space unless it can be demonstrated that alternative and improved provision can be created, existing open space enhanced or no additional displacement within the Green Belt caused. As with Policy BE22, where appropriate all proposals will be required to comply with the Council's Open Space Standards which aim to meet those set out by FiT. It is therefore considered that policy BE22 is "justified" in line with national guidance and therefore sound.
7.36 Policy HP01: Housing Mix sets out that all new development should deliver an inclusive and accessible environment throughout. On development sites of 500 or more units, the Council will require an appropriate mix of dwelling types, sizes and tenures to meet the identified housing needs in the borough as set out in the Strategic Housing Market Assessment (SHMA). Each dwelling is to be constructed to meet requirement M4(2) accessible and adaptable dwellings, unless built in line with M4(3) wheelchair adaptable dwellings. A minimum of 5% self-build homes is to be provided, which can include custom housebuilding and provision for Specialist Accommodation, taking account of local housing need in accordance with the criteria set out in Policy HP04 Specialist Accommodation. Where a development site has been divided into parts, or is being delivered in phases, the area to be used for determining whether this policy applies will be the whole original site.
7.37 The objective of securing accessible and adaptable homes is supported, however, it is unclear as to how the "each dwelling to be constructed to meet requirement M4(2) accessible and adaptable dwellings, unless it is built in line with M4(3) wheelchair adaptable dwellings" is a fair and reasonable request.
7.38 The supporting text refers to DCLG research which shows that, based on English Partnerships figures from 2011-2012, nearly 30% of households have at least one person with a long-term illness and over 3% have one or more wheelchair user. While nationally 3.3% of households have a wheelchair user, for households living in affordable housing this rises to 7.1%. The rates are also higher for older households and, given that the number of older person households in the borough is set to increase over the period to 2033, the Council seeks to ensure 5% of affordable housing development on proposals of 60 or more dwellings archives requirement M4(3) wheelchair accessible dwellings.
7.39 This need for "all developments" to meet this target is not set out in the evidence or in the NPPG (referred to in the supporting text) and is therefore "unjustified" and unsound.
7.40 Policy HP03: Residential Density sets out that residential development proposals will generally be expected to achieve a net density of at least 35 dwellings per hectare net or higher. Proposals for new residential development should take a design-led approach to density which ensures schemes are sympathetic to local character and make efficient use of land. Proposals for housing developments should "Make an Effective Use of Land" in line with NPPF (Section 11). This policy is therefore "consistent" with the NPPF and sound, but must provide for a degree of flexibility to allow for local circumstances.
7.41 Policy HPO4: Specialist Accommodation the Council encourages and supports proposals which contribute to the delivery of Specialist Accommodation, as referenced in the Land North of Shenfield Site allocation "other types of specialist housing (to be provided) in accordance with the Council's policy requirements". This form of accommodation includes, but is not limited to, housing for older people such as Independent Living schemes for the frail elderly.
7.42 The Council's SHMA indicates that, if occupation patterns of Specialist Residential Accommodation for older people remain at current levels, there will be a requirement for 494 additional specialist units to 2033, aligning with the requirement in the Land North of Shenfield site allocation for provision of a residential care home (a 60-bed scheme as part of the overall allocation). This policy is also "consistent" with the NPPF section 5 (para 64 b) and is therefore considered to be sound.
7.43 Policy HPO5: Affordable Housing seeks to provide a portion of affordable housing on residential developments of 11 dwellings or more or on those which have a combined gross floorspace of greater than 1,000 sq. m (gross internal area).
7.44 The affordable housing requirement relates to 35% provision in all areas of the Borough. The Council requires that the tenure split be made up of 86% Affordable/Social Rent and 14% as other forms of affordable housing (this includes starter homes, intermediate homes and shared ownership and all other forms of affordable housing as described by national guidance or legislation) or regard to the most up to date SHMA. The affordable housing is to be designed in such a way as to be seamlessly integrated to that of market housing elements of a scheme and distributed throughout the development, so as to avoid the over concentration in one area.
7.45 Viability is referred to, but the policy does not go far enough. We would recommend that the policy includes a clause which requires a viability assessment to be submitted and considered whereby schemes are unable to meet the full affordable provision, which is not included at present. The policy is therefore "unjustified" and unsound.
7.46 Policy HP06: Standards for New Housing requires that all major residential developments meet the Government's nationally described space standard. It is considered that the standard is an appropriate tool to use when considering the provision of good housing. However, this should not be limited to major development, but should instead extend to all emerging residential development, whilst allowing for the consideration of local circumstances and site-specific conditions, in order to accord the NPPF (Section 12, Achieving Well-Designed Places). The policy is therefore "unjustified" in relation to need and viability (our emphasis) in accordance with the NPPF. The adoption of nationally described space standards is also at the discretion of the LPA and should be decided upon in a local context. The policy is therefore considered unsound.
7.47 Policy HP12: Planning for Inclusive Communities refers to the need to plan for and build inclusive environments that support communities. Proposals should provide access to good quality community spaces, services and infrastructure, encouraging social interaction, ensuring inclusivity and promoting safety. The policy is deemed "consistent" with NPPF (section 8) "Promoting Healthy and Safe Communities" which states that planning policies should aim to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible, and support healthy lifestyles. The policy is therefore considered sound.
7.48 Policy HP13: Creating Successful Places seeks that proposals meet high design standards, in order to deliver safe, inclusive, attractive and accessible places. Elements A-M of policy HP13 identify measures considered to create successful places, in accordance with section 12 of the NPPF on "Achieving Well-Designed Places". The NPPF (para 128) states that design quality should be considered throughout the evolution and assessment of individual proposals. Policy HP13 is therefore considered to be "consistent" with the NPPF and sound.
7.49 Policy HP16: Buildings Design seeks for development to be well designed and of a high quality, having regard to Development Management criteria including scale, density, layout, siting, character and appearance. This policy is considered to be "consistent" with the NPPF having particular regard to Section 12 on "Achieving Well-Designed Places" and therefore sound.
7.50 Policy PC02: Job Growth and Employment Land seeks that provision is made for 5,000 additional jobs in the Borough over the Plan period at a rate of 250 per year. NPPF Section 6 on "Building a Strong, Competitive Economy" sets out that planning policies should support economic growth, in order to create jobs and prosperity by taking a positive approach to sustainable new development. The strategic allocation at Land North of Shenfield supports economic growth and creates new opportunities and is "consistent" with national guidance and is sound.
7.51 Policy PC03: Employment Land Allocations highlights areas allocated by the Council for general employment and office development. Para 82 of the NPPF states that planning policies should recognise and address the specific locational requirements of different employment sectors. The allocations set out in policy PC03 are informed by the wider spatial strategy, which aims to retain the Borough's character and encourage employment growth in suitable locations, in accordance with national planning policy. This policy is therefore deemed to be "consistent" with the NPPF and considered to be sound.
7.52 Policies NE01: Protecting and Enhancing the Natural Environment (inc SSSIs) and NE03: Trees, Woodland, Hedgerows (inc Local Wildlife Site, Local Nature Reserves) work to restrict development that would have a detrimental effect on, or result in the loss of, significant landscape heritage or a feature of ecological importance.
7.53 Our Client wholly supports the principles of both of these policies, albeit as presently worded, they both contain contradictory requirements: Policy NE01 (para B) states that proposals that lead to deterioration or loss of the Borough's designated and non-designated biodiversity assets will not be permitted; whereas Policy NE01 (para C) goes on to state that where adverse impacts are unavoidable they must be adequately and proportionally mitigated (ie it appears to allow for deterioration where they are unavoidable and can be suitably mitigated).
7.54 Policy NE03 (para A) contains a similar contradictory approach to the provisions of the remainder of the policy - as with Policy NE01.
7.55 In the light of this both Policy NE01 and Policy NE03 are not inconsistent with each other, they are also "inconsistent" with National policy, "unjustified" and therefore unsound.
7.56 Policy NE05: Air Quality seeks to restrict development, which would directly or indirectly, impact air quality within the Borough. Measures to offset or mitigate those impacts are introduced as part of proposals to ensure that receptors would not be subject to unacceptable risk as a result of poor air quality. This policy is "consistent" with the objectives of the NPPF (para 181) and is therefore considered sound.
7.57 Policy NE06: Flood Risk requires that development avoid flood risk to people and property, managing any residual risk and taking account of the impacts of climate change. Developments should be located in areas with the lowest probability of flooding (Flood Zones 1 & 2). Where development is located within Flood Zone 3, the Exception Test will apply.
7.58 The NPPF (section 14) "Meeting the Challenge of Climate Change, Flooding and Coastal Change" states that inappropriate development in areas at risk of flooding should be avoided by directing development away from the areas at the highest risk. The majority of Policy NE06 therefore aligns with National guidance and therefore mostly sound. However, and as presently worded, it suggests tat applicants may be obligated to set aside land to provide flood management to benefit areas outside of that development. This is unduly onerous, inconsistent with National policy and therefore unsound.
7.59 Similarly, the entirety of a development area does not need to remain operational at times of flood (such as access roads), if there is an alternative safe means of escape that is provided. Subsection c) of Policy NE06 is therefore not justified and also unsound.
7.60 Policy NE09: Green Belt seeks that the Metropolitan Green Belt within Brentwood Borough will be preserved from inappropriate development so that it continues to main openness and serve key functions. Policy NE09 states that all development proposals within the Green Belt will be considered in accordance with the provisions of section 13 of the NPPF on "Protecting Green Belt Land". It is therefore considered that policy NE09 is "justified" and sound, in the light of national policy.
7.61 Policy NE13: Site Allocations in the Green Belt states that sites allocated to meet housing need, within the Green Belt, will be expected to provide significant community benefits. These are the "exceptional circumstances" for sites to be removed from the Green Belt to allow development to take place, providing new defensible boundaries and protecting the open countryside. The NPPF (para 138) states that, where it has been concluded necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.
7.62 The allocated "Officer's Meadow" site provides opportunities for sustainable development and transport modes to be maximised, with its close proximity to Shenfield railway station, in accordance with National policy, leading to the consideration of Policy NE13 as "consistent" with the NPPF and sound.
7.63 The overall approach within the Development Management related policies is supported, however amendments to policy/Appendices of Local Plan is recommended in places as set out above. This would ensure robustness in terms of delivering a sound Local Plan that is positively prepared, justified, effective and consistent with national planning policy.
8.0 CONCLUSION
8.1 The Regulation 19 "Pre-Submission Local Plan" consultation document is supported. These representations fully support the allocation of Land North of Shenfield, which includes our Client's land at "Officer's Meadow". These representations focus mostly on land within our Client's control and are supported by a series of accompanying technical reports that support the proposed allocation.
8.2 Our Client supports the wider and comprehensive development of Policy RO3: Land North of Shenfield, which could ultimately for circa 825 dwellings (inc affordable provision).
8.3 Specifically, the land controlled by our Client represents the largest area of land within Policy RO3 and is largely supportive of the policy requirements set out in the Local Plan. Our Client is keen to work closely with the Borough Council and adjoining landowners to provide a comprehensive approach to development, and our Client's elements would comprise:
* Circa 510 dwellings (inc. Affordable provision)
* A new Local Centre, inc. potential healthcare;
* A 60-bed care home
* Significant areas of "Green" and "Blue" Infrastructure;
* Other community facilities, inc. sports provision.
8.4 These representations have also set out our Client's support of working closely with the adjoining Shenfield High School to provide for enhanced educational facilities. This would be in the form of funding towards on-site Primary provision to help create a "through-school", plus financial contributions to existing secondary provision (if required).
8.5 We would welcome the opportunity of discussing our concerns, with suggested amendments with BBC and ECC Officers at the earliest opportunity.
8.6 Subject to a number of modifications as recommended in this report, we consider the Local Plan to be largely sound in accordance with the NPPF.

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

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

The Plan should support 5YHS through the allocation of smaller scale sites that can be delivered over short timescales. Land at Bayleys Mead is a site that would cater to this need, with its deliverability discussed in greater detail later on in this representation.

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

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

1. Introduction

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

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

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

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

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

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

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


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

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








 

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

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

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

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

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

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

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

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

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

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

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

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

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

2.15. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.

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

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

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

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

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

2.21. As such, it is a concern that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does again demonstrate an inability to rely on large strategic sites for short term housing delivery, and emphasises the need for smaller sites to be supported by policies which will allow their short term delivery to ensure the Local Plan is sound.

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

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

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

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

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

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

Access

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

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

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

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

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

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

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


Policy SP05 Construction Management

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

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

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

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


Policy BE02 Sustainable Construction and Resource Efficiency

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

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


Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency

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

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


Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network

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

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

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

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


Policy BE10 Connecting New Developments to Digital Infrastructure

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

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

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

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



3. Site Deliverability

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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


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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

In addition to amending the housing trajectory to reflect the realistic and earlier delivery of the site, as proposed by a developer with an option on the land, the inclusion of the site within the first five years on the plan period will assist BBC with their five-year housing land supply position.

1. Introduction

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

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

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

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

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

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

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


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

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








 

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

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

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

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

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

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

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

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

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

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

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

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

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

2.15. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.

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

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

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

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

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

2.21. As such, it is a concern that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does again demonstrate an inability to rely on large strategic sites for short term housing delivery, and emphasises the need for smaller sites to be supported by policies which will allow their short term delivery to ensure the Local Plan is sound.

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

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

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

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

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

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

Access

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

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

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

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

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

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

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


Policy SP05 Construction Management

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

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

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

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


Policy BE02 Sustainable Construction and Resource Efficiency

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

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


Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency

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

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


Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network

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

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

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

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


Policy BE10 Connecting New Developments to Digital Infrastructure

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

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

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

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



3. Site Deliverability

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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


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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

The suggested inability of the plan to ensure a consistent five-year supply is not consistent with national policy. Land at Hanging Hill Lane, could cater to this need.

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

The Plan should be updated to make provision for the Borough's objectively assessed need, to take account of the figure in the Government's Standard Methodology for Calculating Housing Need, with an additional 20% buffer to reflect the Housing Delivery Test.

RE Planning Policy Framework 1.24 - 1.25
Planning Policy Framework
Since the Local Plan Regulation 18 consultation, which took place in early 2018, the revised NPPF has been published. This Plan will therefore now be examined against the policies set out in the revised NPPF (February 2019). Paragraph 212 of the NPPF confirms this, stating that:
'Plans may ...need to be revised to reflect policy changes which this replacement Framework has made. This should be progressed as quickly as possible, either through a partial revision or by preparing a new plan.'
We question whether, in light of this fundamental change to the planning policy context, as well as changes to the introduction of the Standard Methodology for calculating housing need and the Housing Delivery Test, which will be discussed below, the Plan should progress to Examination.
In addition, we note that significant elements of the evidence base to the Plan, which were prepared under the 2012 NPPF, have not been updated.
For example, the Site Assessment Methodology and Summary of Outcomes - Working Draft provides the basis on which sites have been assessed as suitable for development and whether they should be allocated in the Plan. This document has not been amended to reflect the publication of the revised NPPF, or the Standard Methodology. The paper still refers to making provision for 'slightly above 380 dwellings per annum'; in fact, this number will need to increase significantly, for reasons set out below.
On this basis, we believe that the Plan is unsound. It is not positively prepared because it does not make provision for the Borough's objectively assessed needs and it is not justified because the evidence base on which it is based is not proportionate.
The Plan should be updated so that the housing need is calculated based on the Government's standard methodology for calculating housing need, as well as reflecting the findings of the Housing Delivery Test. This will significantly increase the housing numbers and the number of sites required. Further consultation should then take place on a revised draft Plan, before it is submitted for Examination.

RE: Policy R01 (i) Garden Village Strategic Allocation
Dunton Hills Garden Village Strategic Allocation: Policy R01 (I)
Land at Dunton Hills (east of the A128, south of the A127 and north of the C2C railway line, approximately 259.2 ha in size) is allocated for residential-led development to deliver Dunton Hills Garden Village (DHGV).
The policy states that development will deliver a mix of uses to comprise around 2,700 homes in the plan period (as part of an overall indicative capacity of around 4,000 homes to be delivered beyond 2033 - subject to further feasibility and assessment of impact). This number has increased from 2,500 homes stated in the Preferred Site Allocations Consultation document of March 2018.
We object to this policy to propose a new settlement to deliver 2,700 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged.
We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF.
It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example Braintree District, Tendring District and Colchester Borough councils in relation to the North Essex Garden Communities.
Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings.
The housing trajectory suggest that DHGV will deliver 750 dwellings by 2026. However, given the recent research, adopting the lag of seven years from a Plan adoption date before the end of 2019 (which we consider highly ambitious) would mean there would be no deliveries on site until after 2026.
Paragraph 9.33 states that of the 6,700 homes, 4,000 are to be delivered after 2033. However, this is caveated by the statement 'subject to further feasibility and assessment of impact', calling into doubt whether 4,000 can in fact be delivered on site.
The Plan places significant reliance on the timely delivery of Dunton Hills Garden Village. This is not a positive strategy for meeting housing need and does not provide the flexibility required to address changes in circumstances. The allocation should be complemented by the allocation of small sites, to improve deliverability.
We wish to participate in the Examination to set out the case that additional smaller sites should be allocated, to ensure the Plan's deliverability and to ensure a constant delivery of new homes.

RE Policy SP02 - Managing Growth
Housing Delivery
The Plan proposes that as 'the high proportion of designated Green Belt within the Borough makes it extremely difficult to achieve a five year supply' (Paragraph 4.19), a greater proportion of the required homes are forecast to be delivered in the period beyond 2023. Policy SP02 therefore sets out a stepped trajectory of delivery of 310 homes per annum to 2023, followed by a higher target of 584 per year to 2033.
We do not believe that Policy SP02 is sound because it does not provide an appropriate strategy to comply with the requirements of the NPPF, which states in paragraph 23 that:
'Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development.'
The strategy does not result in the delivery of housing throughout the Plan period. Paragraph 73 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the Plan period. Appendix 1 of the Plan sets out this housing trajectory, which demonstrates that no units will be delivered in 2019/2020 from the site allocations, and only 66 units are proposed to be delivered in 2020/2021, with 318 in 2021/2022 and 632 in 2023/2024.
We question whether this is an appropriate strategy, and believe that on this basis, Policy SP02 is unsound because it is not justified.
To set out the case that the Plan should allocate additional, smaller sites, to enable the Plan to deliver homes throughout the Plan period.

RE Local Housing Need - Paragraphs 4.11 - 4.21
Housing Need
In October 2018, the Government consulted on technical changes to its proposed Standard Methodology to calculate housing need based not on the 2016 household projections published by the Office for National Statistics, but on the 2014 household projections published by the Department for Communities and Local Government (DCLG). These revised projections result in a housing figure for the Borough of 456 dwellings per annum.
In February 2019, the Government published a summary of the responses to its October 2018 technical consultation and its view on the way forward, in which it confirmed that its proposed approach provided the most appropriate approach 'for providing stability and certainty to the planning system in the short term' and that Local Planning Authorities should not use the 2016 household projections, which resulted in lower housing numbers, as a reason to justify lower housing need.
The Plan states that the Borough's annual housing requirement is still 380 homes per annum, based on the findings of the Strategic Housing Market Assessment (2016). However, paragraph 4.16 of the Plan sets out the intention to make provision for an additional housing supply buffer, which provides a 20% uplift to the annual housing figure of 380 units, resulting in provision of 456 dwellings per annum, resulting in a requirement for 7,752 dwellings from 2016 - 2033. This is the same figure as required by the Government's Standard Methodology for Calculating Housing Need.
However, Brentwood Borough Council was recently identified in the publication of the Government's Housing Delivery Test as an authority which has delivered less than 85% of its housing requirement, and therefore has to add a 20% buffer to its housing land supply figure.
We therefore object to the housing requirement set out in the Plan on the basis that it is insufficient to meet the Borough's needs. Paragraph 59 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The Plan does not do this; it only makes provision for the OAN and does not provide for the additional 20% buffer, as required under the Housing Delivery Test.
It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.
The Plan should be updated to make provision for the Borough's objectively assessed need, to take account of the figure in the Government's Standard Methodology for Calculating Housing Need, with an additional 20% buffer to reflect the Housing Delivery Test.
If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary. To set out why the Plan is not making adequate provision for new housing.

RE Figure 2.3 - Settlement Hierarchy
Settlement hierarchy
To promote sustainable growth in rural areas, the NPPF (2019) paragraph 78 states that housing in rural areas should be located where it will enhance the vitality of rural communities, to ensure villages grow and thrive. To ensure the Local Plan responds to this, a broad Settlement Hierarchy Assessment has been undertaken to understand the role, function and relationship of Brentwood's dispersed settlements.
The Plan sets out the settlement hierarchy in the Borough. Ingrave is classed as a Category 3 settlement. Whilst we support the classification of Ingrave as a "Category 3 - Large Village", we object to the inconsistent treatment of this settlement in comparison to other settlements occupying the same level in the hierarchy.
For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave.
The moratorium of growth in these villages is contrary to the NPPF, which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. The NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 78).
As drafted, the Plan is not sound. It identifies Ingrave as a Category 3 settlement but does not allocate housing in or near the settlement. This is not an appropriate strategy and therefore the Plan is not justified in this respect.
Additional land for housing should be allocated at Ingrave to meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.
Paragraph 2.16 of the Plan notes that, in relation to Category 3 settlements;
'Brownfield redevelopment opportunities will be encouraged to meet local needs, and policies in this Plan will help to bring forward nearby redevelopment of brownfield sites in the Green Belt where appropriate.'
This emphasis on bringing forward brownfield sites 'nearby' Category 3 settlements is supported. This approach would provide a more flexible approach and would enable sites such as our client's site to come forward.
We wish to participate in the Examination to set out the case that additional sites should be allocated in and near to Ingrave, a sustainable, Category 3 settlement.

RE: Site Assessment Methodology and Summary of Outcomes - Working Draft (2018)
The spatial strategy, as set out at paragraph 3.13, focuses upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with paragraph 137 of the NPPF, which requires that:
'Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.'
However, we do not consider that the capacity of brownfield sites has been fully explored. The Stage 2 assessment process discounts sites where they are considered to be in an unsustainable location, (which included sites in the Green Belt with no connecting boundary to an existing urban area,) before considering the potential to use brownfield land. This has resulted in sites such as site 183, our client's site, being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable.
Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. Residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail.
Paragraph 103 of the NPPF acknowledges that:
"opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision taking.'
Paragraph 102 also states that:
'Transport issues should be considered from the earliest stages of plan-making and development proposals, so that c) opportunities to promote walking, cycling and public transport use are identified and pursued.'
Figure 4.2 of the Plan sets out how different types of land use will contribute to how the overall housing need will be met. The Plan's spatial strategy is unsound because it excluded all sites which do not meet the distance thresholds from existing settlements, and has not fully taken into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
In light of the higher housing numbers required, the Plan should be revised to re-assess all sites which do not meet the distance thresholds from existing settlements, and to take into account opportunities offered by smaller sites in the Green Belt, which could offer sustainable transport modes, and make a small but important contribution to meeting housing need.
We wish to participate in the Examination to set out the case that a further assessment of sites is required, and the opportunity should be taken to re-assess sites which were previously excluded.


RE Spatial Strategy
The draft Plan relies on the delivery of strategic sites, to meet a significant proportion of its housing requirement. Figure 4.2 of the Plan identifies that the Dunton Hills Garden Village strategic allocation will provide 35% of the total housing requirement. We note that in the Regulation 18 document, three strategic sites were proposed; this has now increased to five.
We object to the strategy relying on several large developments to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. As set out in Appendix 1, this strategy results in the delivery of no new housing in the early years of the Plan.
Paragraph 68 of the NPPF notes that:
'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare.'

The Plan should be reviewed and sites identified to meet the higher housing number of 547 dwellings per annum, through the addition of smaller site allocations. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have fewer complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver.
Allocating additional smaller sites will have multiple benefits; it will increase the flexibility of the Plan, it will contribute to the five year housing land supply, it will enable sites which do not require significant infrastructure provision to come forward quickly, and it will attract smaller house building companies who will not be present upon larger strategic sites.
To set out the case that the Plan should allocate additional, smaller sites, to improve the flexibility of the Plan, to ensure that the Plan complies with the NPPF, and to enable the Plan to deliver homes throughout the Plan period.