The Council supports Brentwood Borough Council's commitment to planning to meet its identified housing needs in full, plus the incorporation of a 20% buffer in supply. The incorporation of a buffer is considered to be a prudent and sensible approach to providing flexibility and contingency in supply and is considered to broadly align with national policy and government objectives.
The Council acknowledges the difficulties expressed by Brentwood Borough Council with regard to delivering homes at the significant higher rate in the short term and raises no objection, in principle, to the stepped delivery rates proposed, provided that Brentwood Borough Council satisfies itself and the Inspector that such a stepped approach is deliverable.
The Council suggests that an early review of the Plan will be necessary to reflect the emerging housing strategy of the South Essex Joint Strategic Plan and to reflect any implications this has on the delivery of housing within Brentwood Borough

The Local Plan must be amended to reflect the most up-to-date approach to assessing the local housing need, and take into account unmet housing needs from neighbouring areas when establishing its housing requirement.

The total housing supply must demonstrate that it provides a sufficient supply and mix to meet the requirement, including for the first five years of the Plan period.

The stepped trajectory must be consistent with the evidence as to when strategic Green Belt allocations will start delivering.

The Local Plan should plan for a minimum of 15 years from adoption.

Establishing Local Housing Need and Requirement

The Pre-Submission Document (February 2019) (BBDP) defines an annual housing need of 350 dwellings per annum (dpa) using the standardised method based on the 2016 based household population projections.

Since the BBDP was drafted, the Framework has been amended to make clear that the 2014 household population projections are the baseline for calculating the standard housing need. On this basis, the annual housing need in the BBDP should be adjusted to 452 dpa.

In addition, an allowance may be necessary for unmet housing needs arising from neighbouring areas (see representations made by Hallam Land Management in relation to the Duty to Co-operate). Any figure would need to be added to the annual housing requirement.

The BBDP also proposes a housing supply buffer of 20% to allow for flexibility in meeting the requirement. This is supported in order to ensure the requirement is achieved. Without planning for a buffer to the housing requirement, there is the potential that housing needs will not be met. This is particularly necessary within Brentwood on the basis that the majority of Borough is Green Belt, and therefore there is very limited capacity for speculative windfall development to address any shortfall arising during the plan period.

Notwithstanding this has yet to be demonstrated, on the assumption that there are no unmet needs arising from neighbouring authorities, the housing requirement with a 20% buffer would be 542 dpa. If there are unmet housing needs, this figure would clearly be greater.

Provision should therefore be made in Policy SP02 for at least a minimum of 9,214 dwellings (based on 542 dpa) in the plan period 2016 to 2033.

On this basis, and setting aside the issue of unmet needs, the total housing supply in Figure 4.2 does not show a sufficient supply and mix of sites to meet the minimum number of homes required. It also does not demonstrate a five year supply on adoption of the Plan.


Stepped Trajectory

Policy SP02 proposes a stepped trajectory in housing supply due to existing Green Belt boundaries currently constraining growth. However, the increase in housing supply starts at 2023/24, which is a year after the housing trajectory assumes delivery starts on a number of the strategic Green Belt allocations (2022/23). The two dates should be consistent with each other.

Plan Period

It is assumed that adoption of the BBDP will be at the earliest in 2019/20. The Plan will therefore fall short by 1 year in ensuring the Plan looks ahead over a minimum 15 year period from adoption (NPPF paragraph 22).

Hallam Land Management have identified in these representations (and representations made in relation to Duty to Co-operate and Housing Need and Requirement), that the housing supply identified in the Plan will not meet the housing required to be provided for within the Plan. This is both in terms of the Plan period as a whole, and in terms of the first five years of the Plan period.

Additional Site Allocations are therefore necessary to make the Local Plan sound. Further, given the absence of non-Green Belt alternatives, the requirement to meet housing needs would be the exceptional circumstances for the further release of land and alterations to the Green Belt boundary as set out within the Local Plan.

Hallam Land Management are of the strong view that there is a suitable site adjoining the Brentwood Urban Area that would not undermine the purposes and importance of the Green Belt if it were to be released.

The site is referred to as Calcott Hall Farm, Brentwood, which is under the control of Hallam Land Management and could start delivery within five years of adoption of the Plan. The HEELA, October 2018 recognises the site as suitable, available and achievable (Site Ref 302c). Furthermore, the Sustainability Appraisal has already deemed the Site as a reasonable alternative (Table 5.2, SA of Brentwood Local Plan, January 2019).

Notwithstanding the Council's position that the site is suitable, available, and achievable, Hallam Land Management have submitted with these representations a suite of technical documents that demonstrate the site is both suitable and that its development would align with the Vision, Spatial Strategy and Strategic Objectives of the Plan. The key points to note are below:

Location

* As illustrated on the attached plan, the site is immediately adjacent to the Brentwood Urban Area (Settlement Category 1) as defined in the Settlement Hierarchy (Figure 2.3);
* The site lies to the immediate south of Pilgrims Hatch, and to the west of Brentwood and the A12;
* The site does not perform a role in maintaining separation between the already connected settlements of Brentwood and Pilgrims Hatch as evident from the plan and when viewed on the ground;
* The site falls within the Central Brentwood Growth Corridor; and,
* Its allocation would therefore be consistent with the Settlement Hierarchy and Spatial Strategy for the Borough.

Green Belt

* The site is already bounded on two sides by the Urban Area (to the north and east);
* The site has clear, physical defensible boundaries to the Green Belt to the south and west, namely Weald Road and Weald Country Park (a Local Authority owned parkland which is also a Registered Park and Conservation Area);
* These physical features are readily recognisable, and are permanent in accordance with paragraph 139 of the Framework, and an amended boundary for the Green Belt is appended to these representations;
* Any development would therefore be contained and the site has limited intervisibility with the wider Green Belt due to the presence of the urban area, and woodland and tree cover within the site;
* Paragraph 138 of the Framework requires first consideration to be given to releasing Green Belt land which has been previously developed or is well served by public transport. The site is well served by public transport as explained below under Accessibility and should therefore be a first consideration;
* Paragraph 138 also requires removing land from the Green Belt to be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. The environmental quality and accessibility of Weald Country Park can be improved through the release of this land as explained below under Transport and Connectivity; and,
* The site's release from the Green Belt would therefore be consistent with National Green Belt Policy and would not undermine the integrity of the Green Belt within the Borough.
Accessibility

* The site is within 2km or 10 minute cycle distance/20 minute walking distance of local services within Brentwood Town Centre, and closer still to day-to-day facilities within Pilgrims Hatch;
* Brentwood Train Station is a 12 minute cycle distance/25 minute walking distance, with Shenfield Train Station around 15 minute cycle distance/30 minute walking distance;
* Safe, direct and convenient routes to the town centre and train stations from the site are achievable; and,
* Existing bus routes already pass the northern entrance to the site, and a public transport strategy has been agreed with the Bus Operator to improve connections from the site with the train station and town centre.

Transport and Connectivity

* The site has the ability to deliver a Community Link Road (CLR) connecting Ongar Road to the north, with Weald Road to the south. The Transport Feasibility Study prepared states that the CLR would provide an alternative route for traffic from Pilgrims Hatch heading south to the A12/M25 that avoids Brentwood Town Centre and the Air Quality Management Area;
* The CLR would also improve the environmental quality of the Weald Country Park through enabling the downgrading of Sandpit Lane that runs along the site's western boundary by preventing through traffic; and,
* The site also has the ability to provide safe, direct and convenient pedestrian and cycle routes from the Brentwood Urban Area to the Weald Country Park that do not currently exist, and thereby improving its accessibility to the local population.

Environment

* There are no environmental features of interest that would prevent development of the site as evidenced within the suite of technical documents appended to these representations covering arboriculture, drainage, ecology, heritage, noise and air quality;
* There is the ability to deliver environmental benefits on the site, including ecological benefits arising from the management of the High Wood Local Wildlife Site and provision of green infrastructure that would enhance habitat connectivity with the Weald Country Park;
* Benefits to the setting of nearby designated heritage assets through the downgrading and reduction in vehicular traffic along Sandpit Lane;
* The site has limited inter-visibility with the wider landscape, and its visual envelop is primarily limited to points along the boundaries of the site; and,
* The retention of landscape features within the site, and locating development within the lease sensitive areas will ensure the landscape and visual impact is limited.

More specifically, with reference to the suite of technical documents, the site can be developed in accordance with relevant national and local planning policies as summarised below:

* A Desk Based Heritage Assessment has been prepared which demonstrates how harm to the setting of nearby designated assets, including Weald Country Park and South Weald Camp Iron Age Hillfort, can be avoided through the incorporation of suitable buffers from built development which are incorporated into the Capacity Plan;

* A Landscape and Visual Statement has been prepared which demonstrates how development of the site would not result in any sense of greater coalescence between Pilgrims Hatch and Brentwood than exists today, and how the site has limited intervisibility with the countryside to the south and west such that its visual impacts would be limited. Key landscape features have also been incorporated into the Capacity Plan;

* A Preliminary Acoustics Review has been prepared which demonstrates that potential sound sources, including from traffic on the A12, can be mitigated to acceptable levels through consideration being given to layout and the relationship of dwellings to the noise source, and incorporation of an acoustic bund which has been incorporated into the Capacity Plan;

* A Preliminary Air Quality Review has been prepared which demonstrates the effects of sources of air pollution near to the site, including the A12, on development can be mitigated through incorporating sufficient buffers within the layout which have been incorporated into the Capacity Plan;
* A Preliminary Arboricultural Assessment has been prepared which demonstrates how the woodland and trees of high quality within the site can be retained through the indicative layout incorporated into the Capacity Plan;

* A Preliminary Ecological Appraisal has been prepared which demonstrates how valuable ecological habitats on site will be protected and enhanced through the indicative layout incorporated into the Capacity Plan; and

* A Surface Water and Foul Water Feasibility Study has been prepared which demonstrates that surface and foul water can be appropriately managed in conjunction with onsite measures including attenuation ponds within the layout which have been incorporated into the Capacity Plan.

Infrastructure

* The site has the ability to accommodate a primary school should this be necessary to serve the development; and
* There are no constraints to development in terms of utilities infrastructure as illustrated on the appended Utilities Constraints Plan.

Delivery
* Hallam Land Management control the site, and as outlined above there are no impediments to early delivery;
* They have a strong track record of securing deliverable outline planning permissions that are attractive to the market. It is therefore considered that delivery could start within five years from plan adoption;
* In addition, as there are two points of vehicular access (at either end of the site) with a central spine road (CLR) that in part could accommodate sales outlets on either side, two to three sales outlets are achievable. On this basis the following trajectory is assumed:

Year: Dpa: - 22/23: 25 23/24: 75 24/25: 100 25/26: 100 26/27: 100 27/28: 100 28/29:100 29/30: 100 30/31: 100 - Total: 800


Review of the Draft Local Plan Evidence Base
Hallam Land Management have undertaken a review of the evidence base relevant to the above site.

As noted above, the HEELA, October 2018 recognises the site as suitable, available and achievable (Site Ref 302c). Furthermore, the Sustainability Appraisal deemed the Site as a reasonable alternative (Table 5.2, SA of Brentwood Local Plan, January 2019).
The site has also been assessed within the various Green Belt Studies that have been undertaken for the Council.

The Green Belt Studies Part 2 (January 2018) and Part 3 (November 2018) both assessed the site as making a moderate-high contribution to the purposes of the Green Belt.

However, this assessment changed when a new Green Belt Study Part 3 (January 2019) was published in February 2019 which assessed the site as making a high contribution to the purposes of the Green Belt. The reason for the changes to the evidence base after publication of the Draft Local Plan are unclear and should be explained.

Furthermore, there are a number of inaccuracies in the January 2019 assessment of the site as follows:

* The study considers the site as having clear separation from the urban area based on the A12 and A128, and limited association with the urban area.

In response, Pilgrims Hatch extends to both sides of the A128 and therefore the A128 does not separate the site from the urban area. The site, and features such as High Wood, sports pitches, and Calcott Hall Farm, have close association with Pilgrims Hatch which forms part of the Brentwood Urban Area in accordance with the Council's Settlement Hierarchy.

* The study assesses the site as 'not contained'.

In response, it is evident from the plan and on the ground that the site is contained on two sides by built development. The site abuts the built-up area, would be an urban extension, and should be regarded as 'partly contained'.

* The study considers the site would lead to a physical narrowing of the gap and 'potential' visual coalesence between Pilgrims Hatch and Brentwood. The study also refers to 'perceptual' coalescence.

In response, the A12 is the only gap between Pilgrims Hatch and Brentwood and this would not change. The boundary of the site is pulled back from the Ongar Road adjacent to the A12 to reflect the existing sports pitches such that there would be no change to visual coalescence as perceived on the ground than that which already exists as a result of development on the opposite side of Ongar Road.

* The study assesses the site as having 'significant separation reduction'.

In response, there is no reduction in the separation between Pilgrims Hatch and Brentwood, and they both form part of the Brentwood Urban Area.

* The study assesses the site as having a moderate relationship with a historic town.

In response, the site does adjoin Weald Country Park which is a Registered Park and Garden. However, Weald Country Park is not a historic town and therefore the assessment has unfairly considered the site.

These inaccuracies have led to the conclusion that the site has a high contribution to the purposes of the Green Belt. The weight to be given to this evidence in informing the Draft Local Plan is therefore diminished.

There is not clear or sufficient evidence to demonstrate that the housing trajectory for the following sites in Appendix 1 is justified as required by the Framework to demonstrate a site is deliverable. This undermines the evidence within Figure 4.2 Demonstrating Housing Provision which therefore results in Policy SP02 being ineffective and not justified.

R01 Dunton Hills Garden Village

It is noted that a Scoping Opinion has been submitted for R01. However, the Council has yet to reach a determination and it is understood that it does not intend to grant planning permission for any subsequent application until the adoption of the Local Plan.
Assuming the Plan is adopted in 2019/20 and a decision is taken shortly thereafter, this would give at best three years before the first 100 homes are completed on the site in 2022/23. No evidence has been provided to demonstrate the site is deliverable in accordance with the Framework, and one would expect a timetable with key milestones to reach a start date for construction and the completion of 100 dwellings.

Further, R01 is expected to achieve another 2,600 homes over the remaining 10 years of the Plan period (an average of 260 dpa). This average per annum is greater than the average identified in recent studies examining the delivery of large scale development. For instance, the Start to Finish Study (NLP, 2016) noted the annual average build for sites over 2,000 dwellings was 161 dpa. More recently the Letwin Review (Independent Review of Build Out, MHCLG, 2018) noted an average build rate of 6.5% of the total site for sites over 1,500. If the average was applied to R01, this would equate to 175dpa. No evidence is provided as to why a substantially greater build out rate will be achieved.
As evidenced by the length and detail of Policy R01, and the infrastructure requirements set out in the Plan, R01 is a complex site with a number of physical and policy constraints that need to be addressed. It is also a critical component of the housing supply and therefore the strategy to meet housing need. By way of example, if the start date for construction was delayed and the first 100 dwellings were not completed until 2024/25, this would result in 500 less dwellings being built within the Plan period. This equates to over a year worth of housing need not met.

In the absence of any evidence on delivery, Hallam Land Management do not believe the trajectory will be achieved.
R02 Land at West Horndon Industrial Estate

As it stands, the site is currently occupied by various commercial enterprises all of which would need to be vacated for the site to be developed in full. The Housing Trajectory (Appendix 1) assumes these uses are all relocated in order to facilitate the completion of 65 dwellings in 2021/22. There is no evidence the current occupiers have found alternative premises such that they could relocate their businesses within the next 12 to 18 months in order to enable completions in Spring 2021.

There is therefore not clear evidence that housing completions will begin on site within 5 years as required by the Framework to demonstrate deliverability.

Further, the estimated number of units achievable on the site is considered over-optimistic with a net density of 57 dwellings per hectare contrasting sharply with the established character of the West Horndon village. The final capacity of this site may therefore be less than suggested in the Local Plan.

Finally, given the close proximity of R01 and R02, evidence should be provided on market saturation and the ability of the level of housing completions to be achieved. The Housing Trajectory suggests at their peak in years 2026 to 2029, 365 dwellings per annum would be achieved in the A127 corridor from these two sites alone. This is a significant proportion of the annual housing need for the Borough (over 80%) being delivered in one location.

R03 Land North of Shenfield
There is no clear evidence that housing completions will begin on site within 5 years (2023/24) as required by the Framework to demonstrate deliverability.

Furthermore, the Trajectory assumes 155 dwellings to be completed in the first year of the development (2023/24). This is a significant rate of delivery for the first year of a development, and notably higher than other sites in Borough (e.g. R01 is 100 dwellings). The figure appears unrealistic in the absence of any evidence.

R04 & R05 Ford Headquarters and Council Depot

As it stands, Ford have stated an intention to move but there is no certainty over when this will occur. The Trajectory assumes 40 dwellings being completed in 2024/25. In the absence of any certainty on the timescales as to when the site will be available for development, placing reliance on this site delivering housing completions in this year of the Plan period (which could well fall within the first five years of the Plan period) is not sound.

R07 Sow and Grow Nursery, Ongar Road

This site is identified to have delivered 18 dwellings by April 2021. As the site is in the Green Belt, this will only be achievable if the Plan is to be adopted in 2019/2020. It is therefore questioned whether this site will deliver housing as quickly as proposed within the Housing Trajectory.

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

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

1. Legal Compliance
Brentwood Borough Council (BBC) has worked closely with Castle Point Borough Council (CPBC) through the production of the emerging Pre-Submission Local Plan (PSLP).
In January 2018 a Memorandum of understanding was signed by Brentwood, Castle Point, Essex County, Rochford, Southend-on- Sea and Thurrock to form the Association of South Essex Local Authorities (ASELA). The Council has worked closely with BBC and other South Essex authorities to produce joint evidence base documents and through the emerging Joint Strategic Plan for South Essex (JSP).
From CPBC's perspective, the production of the PSLP has included joint working which meets the requirements of the Duty to Cooperate. There is no reason for the Council to question the legal compliance of the PSLP.
2. Test of Soundness
2.1 Positively Prepared
To be positively prepared, the PSLP should seek to meet the areas objectively assessed needs (OAN).
The PSLP makes provision for 7,752 new residential dwellings to be built over the plan period. The housing target is in excess of the level of need calculated through the Standard Method within the Planning Practice Guidance, and is based on recommendations in the SHMA which seeks to meet objectively assessed housing needs in the Borough. CPBC supports this approach.
It is acknowledged that BBC has undertaken extensive work to identify suitable sites, review the urban land capacity, seek additional land capacity through windfall, town centre and brownfield sites, review urban densities, seek to limit the loss of the Green Belt, and consider the practical realities of phasing development alongside infrastructure delivery. CPBC commends the approach taken by BBC in seeking to deliver high housing requirements in an area with significant environmental, Green Belt and infrastructure challenges. In relation to Policy SP02, CPBP has no reason to believe that the PSLP has not been prepared positively.
2.2 Justified and effective
The PSLP provides for an uplift in the amount of homes that will be delivered over the Plan period. The PSLP identifies that the majority of homes will be delivered after the first five years of the plan period. Where the majority of allocations within the Plan are on Green Belt sites, it is acknowledged that these sites will require longer lead in times before new dwellings can be delivered. The PSLP has therefore set out a phased rate of housing delivery which they consider to be realistic and deliverable, allocating a higher level of development later in the Plan period. CPBC has no reason to believe that the approach to housing delivery within the PSLP is not justified and effective.
2.3 Consistent with national planning policy
The PSLP will be assessed against the requirements of the 2018 National Planning Policy Framework (NPPF). Based on an assessment of some of the key elements of the PSLP, CPBC has no reason to believe that the Plan is inconsistent with national planning policy.
From CPBC's perspective, the production of the PSLP has included joint working which meets the requirements of the Duty to Cooperate. CPBC has not identified any reasons why the PSLP should not be considered positively prepared, justified, effective, and consistent with national planning policy.

1. Legal Compliance
Brentwood Borough Council (BBC) has worked closely with Castle Point Borough Council (CPBC) through the production of the emerging Pre-Submission Local Plan (PSLP).
In January 2018 a Memorandum of understanding was signed by Brentwood, Castle Point, Essex County, Rochford, Southend-on- Sea and Thurrock to form the Association of South Essex Local Authorities (ASELA). The Council has worked closely with BBC and other South Essex authorities to produce joint evidence base documents and through the emerging Joint Strategic Plan for South Essex (JSP).
From CPBC's perspective, the production of the PSLP has included joint working which meets the requirements of the Duty to Cooperate. There is no reason for the Council to question the legal compliance of the PSLP.
2. Test of Soundness
2.1 Positively Prepared
To be positively prepared, the PSLP should seek to meet the areas objectively assessed needs (OAN).
The PSLP makes provision for 7,752 new residential dwellings to be built over the plan period. The housing target is in excess of the level of need calculated through the Standard Method within the Planning Practice Guidance, and is based on recommendations in the SHMA which seeks to meet objectively assessed housing needs in the Borough. CPBC supports this approach.
It is acknowledged that BBC has undertaken extensive work to identify suitable sites, review the urban land capacity, seek additional land capacity through windfall, town centre and brownfield sites, review urban densities, seek to limit the loss of the Green Belt, and consider the practical realities of phasing development alongside infrastructure delivery. CPBC commends the approach taken by BBC in seeking to deliver high housing requirements in an area with significant environmental, Green Belt and infrastructure challenges. In relation to Policy SP02, CPBP has no reason to believe that the PSLP has not been prepared positively.
2.2 Justified and effective
The PSLP provides for an uplift in the amount of homes that will be delivered over the Plan period. The PSLP identifies that the majority of homes will be delivered after the first five years of the plan period. Where the majority of allocations within the Plan are on Green Belt sites, it is acknowledged that these sites will require longer lead in times before new dwellings can be delivered. The PSLP has therefore set out a phased rate of housing delivery which they consider to be realistic and deliverable, allocating a higher level of development later in the Plan period. CPBC has no reason to believe that the approach to housing delivery within the PSLP is not justified and effective.
2.3 Consistent with national planning policy
The PSLP will be assessed against the requirements of the 2018 National Planning Policy Framework (NPPF). Based on an assessment of some of the key elements of the PSLP, CPBC has no reason to believe that the Plan is inconsistent with national planning policy.
From CPBC's perspective, the production of the PSLP has included joint working which meets the requirements of the Duty to Cooperate. CPBC has not identified any reasons why the PSLP should not be considered positively prepared, justified, effective, and consistent with national planning policy.

1. Legal Compliance
Brentwood Borough Council (BBC) has worked closely with Castle Point Borough Council (CPBC) through the production of the emerging Pre-Submission Local Plan (PSLP).
In January 2018 a Memorandum of understanding was signed by Brentwood, Castle Point, Essex County, Rochford, Southend-on- Sea and Thurrock to form the Association of South Essex Local Authorities (ASELA). The Council has worked closely with BBC and other South Essex authorities to produce joint evidence base documents and through the emerging Joint Strategic Plan for South Essex (JSP).
From CPBC's perspective, the production of the PSLP has included joint working which meets the requirements of the Duty to Cooperate. There is no reason for the Council to question the legal compliance of the PSLP.
2. Test of Soundness
2.1 Positively Prepared
To be positively prepared, the PSLP should seek to meet the areas objectively assessed needs (OAN).
The PSLP makes provision for 7,752 new residential dwellings to be built over the plan period. The housing target is in excess of the level of need calculated through the Standard Method within the Planning Practice Guidance, and is based on recommendations in the SHMA which seeks to meet objectively assessed housing needs in the Borough. CPBC supports this approach.
It is acknowledged that BBC has undertaken extensive work to identify suitable sites, review the urban land capacity, seek additional land capacity through windfall, town centre and brownfield sites, review urban densities, seek to limit the loss of the Green Belt, and consider the practical realities of phasing development alongside infrastructure delivery. CPBC commends the approach taken by BBC in seeking to deliver high housing requirements in an area with significant environmental, Green Belt and infrastructure challenges. In relation to Policy SP02, CPBP has no reason to believe that the PSLP has not been prepared positively.
2.2 Justified and effective
The PSLP provides for an uplift in the amount of homes that will be delivered over the Plan period. The PSLP identifies that the majority of homes will be delivered after the first five years of the plan period. Where the majority of allocations within the Plan are on Green Belt sites, it is acknowledged that these sites will require longer lead in times before new dwellings can be delivered. The PSLP has therefore set out a phased rate of housing delivery which they consider to be realistic and deliverable, allocating a higher level of development later in the Plan period. CPBC has no reason to believe that the approach to housing delivery within the PSLP is not justified and effective.
2.3 Consistent with national planning policy
The PSLP will be assessed against the requirements of the 2018 National Planning Policy Framework (NPPF). Based on an assessment of some of the key elements of the PSLP, CPBC has no reason to believe that the Plan is inconsistent with national planning policy.
From CPBC's perspective, the production of the PSLP has included joint working which meets the requirements of the Duty to Cooperate. CPBC has not identified any reasons why the PSLP should not be considered positively prepared, justified, effective, and consistent with national planning policy.

Unsound because: 1. Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village. 2. Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingriths of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account. 3. Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services. 4. Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health service, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development. 5. Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development. 6. The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states @When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is 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. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land." 7. Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence. 8. There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence. 9. The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable. 10. The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposal because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable. 11. Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy

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.
It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

The overall approach of the Brentwood Local Plan remains the same as the previous consultations of the draft 2016 plan and 2018 Preferred Site Allocations consultation with Brentwood Council proposing to accommodate all of the identified objectively assessed need for housing and employment within the Borough Boundary during the plan period. However the period of the plan now covers 2016-2033. The Local Plan includes a revised housing requirement of 7,752 dwellings (up from 7,240 dwellings in the 2016 Local Plan consultation and up from 7600 dwellings in the 2018 consultation) and a provision of approximately 47.4ha of net employment land.

Brentwood Council intends to plan for housing numbers and land supply above its assessment of identified Objectively Assessed Housing Need of 350 dwellings per annum to allow some degree of flexibility and to make a contingency for future housing requirements. Furthermore it is noted that Brentwood Council considers that there is potential to accommodate the housing numbers proposed by the Government standardised methodology with further capacity at Dunton Hills Garden Village.

Thurrock Council seeks further clarification as to whether level of growth proposed for Brentwood could be accommodated in the plan in light of the concerns with regard to the assessment of housing need being required to be altered to meet Government policy at 452 dpa and due to the current concerns regarding the proposed strategic location at Dunton Hills Garden Village to accommodate this growth. Thurrock Council would wish to further engage with Brentwood Council to discuss other alternative options in the borough including at West Horndon.

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.

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.

* 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.

It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

The Plan should demonstrate in more detail, through a tool such as a Topic Paper, how its site selection choices have been informed by the Green Belt Study 2018 and should any inconsistencies occurs the Plan's land use allocations and justification should be changed.

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

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Brentwood Borough Council (BBC) Regulation 19 Pre-submission Local Plan prior to its submission to the Secretary of State for examination.
Officers at CCC have been working collaboratively with BBC through the Duty to Co-operate as outlined in paragraph 1.11 of the Pre-Submission document. CCC has responded to previous iterations of the Brentwood Local Plan including the Draft Local Plan in 2016 and Draft Local Plan Preferred Site Allocations in 2018.
CCC has the following comments on the consultation document:
Duty to Co-operate
BBC and CCC have engaged on strategic cross boundary matters. A Protocol for dealing with unmet housing needs requests has also been agreed between Essex Local Planning Authorities through the Essex Planning Officers' Association which has resulted in an effective joint mechanism being put in place. Furthermore, both Councils have also been involved in a joint the Gypsy, Traveller & Traveller Showpeople Accommodation Assessment with relevant other Essex Local Planning Authorities. CCC consider that the Duty to Co-operate has been fulfilled and will continue to work collaboratively where appropriate with BBC through the Duty to Co-operate.
Housing
It is noted that as a starting point the Local Plan sets out a housing requirement figure for Brentwood, as calculated using the standard method in the SHMA of 350dpa. CCC welcomes Brentwood Borough Council's commitment to significantly boost the supply of housing to meet the needs of the area and the decision to adopt a higher figure of 456dpa in anticipation of MHCLG intention to adjust the standardised methodology to safeguard against any potential uplift. When taking the supply buffer into account, the Local Plan provides for a total of 7,752 new homes over the plan period 2016-2033 setting a housing target of 456dpa. This is set out in Policy SP02:
Managing Growth which sets the housing delivery targets of an annual average rate of 310 dwellings per year to 2022/23, followed by 584 dwellings per year from 2023/24-2033. BBC proposes to meet its own housing need within its administrative boundaries and has not approached neighbouring authorities under the Duty to Co-operate to request other authorities help accommodate any unmet needs. This is supported by CCC. Is it noted that the Brentwood Gypsy and Traveller Accommodation Assessment (GTAA) identified that there is a requirement of 13 additional Gypsy and Traveller pitches to be developed by 2033. With no current need identified for accommodation for travelling showpeople, a criteria-based
Policy HP11 Proposals For Gypsies, Travellers and Travelling Showpeople would deal with any need that arises over the life of the Plan on windfall sites. Overall, the need is being met with the authority's administrative area.
On transit sites, CCC acknowledges the GTAA's recommendations to engage, through the Duty to Cooperate, with other Essex authorities in the future to review the need for transit sites. Further work on this is also being undertaken by Essex County Council to consider the need for these sites across Essex as a whole.
Overall CCC is supportive of the approach to housing need in the BBC Local Plan and do not raise any objections under soundness or legal compliance.
Employment
The Functional Economic Market Area (FEMA) for Brentwood is the same as the Housing Market Area. Policy PC02: Job Growth and Employment Land makes provision for 5,000 additional jobs to be provided in the borough over the plan period. CCC is supportive of BBC approach to meeting the forecasted employments needs through allocating 47.39ha employment land as set out in Policy PC03 Employment Land Allocations. The Local Plan allocates additional strategic employment land at Brentwood Enterprise Park. In addition, further employment land is allocated and policies in the Local Plan seek to protect existing employment land providing a mix and range of employment sites. Overall CCC is supportive of this approach and do not raise any objections under soundness or legal compliance.
The Spatial Strategy and Relevant Site Allocations
The Spatial Strategy primarily focuses growth within two key growth areas (Central Brentwood Growth Corridor and South Brentwood Growth Corridor) together with more limited growth outside these growth areas in Village Service Centres and larger villages (including Ingatestone and Blackmore in proximity to Chelmsford City Council's administrative area).
The growth areas comprise:
Central Brentwood Growth Corridor - brownfield land in Brentwood and Shenfield together with wider urban extensions in places around the Brentwood Urban Area and opportunities to grow Ingatestone Village through urban extension to the south, providing new housing and supporting employment.
South Brentwood Growth Corridor - strategic allocation at Dunton Hills Garden Village, a strategic allocation at M25 junction 29 (Brentwood Enterprise Park) providing most of the new employment land needed, together with brownfield opportunities through the redevelopment of existing industrial land in West Horndon.
Section 9 of the Local Plan identifies the locations at which new development will be located. For Chelmsford, sites of local in proximity to the Chelmsford area are around 161 dwellings (R21) and around 57 dwellings (R22) to be provided on new Local Plan allocations in Ingatestone, together with around 40 dwellings (R25) and around 30 dwellings (R26) allocated on sites in Blackmore. CCC supports BBC's proposed approach to housing and employment allocations which are unlikely to
have any obvious adverse cross-boundary impacts on Chelmsford.
However, it is crucial that the allocations are supported by the appropriate infrastructure, in particular highway and transportation schemes due to Brentwood's location on the A12/Greater Anglia road and rail corridor. It is noted that the Infrastructure Delivery Plan is a 'live' document and would be reviewed and published annually. To conclude, CCC is supportive of the Local Plan and does not raise any objections under soundness or legal compliance.

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Brentwood Borough Council (BBC) Regulation 19 Pre-submission Local Plan prior to its submission to the Secretary of State for examination.
Officers at CCC have been working collaboratively with BBC through the Duty to Co-operate as outlined in paragraph 1.11 of the Pre-Submission document. CCC has responded to previous iterations of the Brentwood Local Plan including the Draft Local Plan in 2016 and Draft Local Plan Preferred Site Allocations in 2018.
CCC has the following comments on the consultation document:
Duty to Co-operate
BBC and CCC have engaged on strategic cross boundary matters. A Protocol for dealing with unmet housing needs requests has also been agreed between Essex Local Planning Authorities through the Essex Planning Officers' Association which has resulted in an effective joint mechanism being put in place. Furthermore, both Councils have also been involved in a joint the Gypsy, Traveller & Traveller Showpeople Accommodation Assessment with relevant other Essex Local Planning Authorities. CCC consider that the Duty to Co-operate has been fulfilled and will continue to work collaboratively where appropriate with BBC through the Duty to Co-operate.
Housing
It is noted that as a starting point the Local Plan sets out a housing requirement figure for Brentwood, as calculated using the standard method in the SHMA of 350dpa. CCC welcomes Brentwood Borough Council's commitment to significantly boost the supply of housing to meet the needs of the area and the decision to adopt a higher figure of 456dpa in anticipation of MHCLG intention to adjust the standardised methodology to safeguard against any potential uplift. When taking the supply buffer into account, the Local Plan provides for a total of 7,752 new homes over the plan period 2016-2033 setting a housing target of 456dpa. This is set out in Policy SP02:
Managing Growth which sets the housing delivery targets of an annual average rate of 310 dwellings per year to 2022/23, followed by 584 dwellings per year from 2023/24-2033. BBC proposes to meet its own housing need within its administrative boundaries and has not approached neighbouring authorities under the Duty to Co-operate to request other authorities help accommodate any unmet needs. This is supported by CCC. Is it noted that the Brentwood Gypsy and Traveller Accommodation Assessment (GTAA) identified that there is a requirement of 13 additional Gypsy and Traveller pitches to be developed by 2033. With no current need identified for accommodation for travelling showpeople, a criteria-based
Policy HP11 Proposals For Gypsies, Travellers and Travelling Showpeople would deal with any need that arises over the life of the Plan on windfall sites. Overall, the need is being met with the authority's administrative area.
On transit sites, CCC acknowledges the GTAA's recommendations to engage, through the Duty to Cooperate, with other Essex authorities in the future to review the need for transit sites. Further work on this is also being undertaken by Essex County Council to consider the need for these sites across Essex as a whole.
Overall CCC is supportive of the approach to housing need in the BBC Local Plan and do not raise any objections under soundness or legal compliance.
Employment
The Functional Economic Market Area (FEMA) for Brentwood is the same as the Housing Market Area. Policy PC02: Job Growth and Employment Land makes provision for 5,000 additional jobs to be provided in the borough over the plan period. CCC is supportive of BBC approach to meeting the forecasted employments needs through allocating 47.39ha employment land as set out in Policy PC03 Employment Land Allocations. The Local Plan allocates additional strategic employment land at Brentwood Enterprise Park. In addition, further employment land is allocated and policies in the Local Plan seek to protect existing employment land providing a mix and range of employment sites. Overall CCC is supportive of this approach and do not raise any objections under soundness or legal compliance.
The Spatial Strategy and Relevant Site Allocations
The Spatial Strategy primarily focuses growth within two key growth areas (Central Brentwood Growth Corridor and South Brentwood Growth Corridor) together with more limited growth outside these growth areas in Village Service Centres and larger villages (including Ingatestone and Blackmore in proximity to Chelmsford City Council's administrative area).
The growth areas comprise:
Central Brentwood Growth Corridor - brownfield land in Brentwood and Shenfield together with wider urban extensions in places around the Brentwood Urban Area and opportunities to grow Ingatestone Village through urban extension to the south, providing new housing and supporting employment.
South Brentwood Growth Corridor - strategic allocation at Dunton Hills Garden Village, a strategic allocation at M25 junction 29 (Brentwood Enterprise Park) providing most of the new employment land needed, together with brownfield opportunities through the redevelopment of existing industrial land in West Horndon.
Section 9 of the Local Plan identifies the locations at which new development will be located. For Chelmsford, sites of local in proximity to the Chelmsford area are around 161 dwellings (R21) and around 57 dwellings (R22) to be provided on new Local Plan allocations in Ingatestone, together with around 40 dwellings (R25) and around 30 dwellings (R26) allocated on sites in Blackmore. CCC supports BBC's proposed approach to housing and employment allocations which are unlikely to
have any obvious adverse cross-boundary impacts on Chelmsford.
However, it is crucial that the allocations are supported by the appropriate infrastructure, in particular highway and transportation schemes due to Brentwood's location on the A12/Greater Anglia road and rail corridor. It is noted that the Infrastructure Delivery Plan is a 'live' document and would be reviewed and published annually. To conclude, CCC is supportive of the Local Plan and does not raise any objections under soundness or legal compliance.

Section 09: (Site Allocation)
- Policy R25, 9.197 - 9.200
- Policy R26, 9.201 - 9.204



Section 04: (Managing Growth)
- Policy SP01 - D (a) and D (f)
- Para 4.9
- Para 4.2
- Policy SP02

Section 08: (Natural Environment)
- Policy NE06, 8.5 - 8.64
- Para 8.85 (iv)
- Para 8.90
- Para 8.101
- Policy NE13

The Local Plan is not compliant per the below:
* NPPF Sect 2 8.a.b.c - to meet local need, accessible services -does not comply
* NPPF Sect 3 28 - local community has been ignored rather than included
* NPPF Sect 5 77/78 - decisions should be 'responsive to local circumstances' and 'reflect local needs'. There is no proven need for these houses
* NPPF Sect 9 103 - Development should be focused on locations, limiting the need to travel and offering a genuine choice of travel modes. Blackmore is approximately 7 miles form the nearest train station so private cars will have to used to commute via narrow country lanes
* NPPF Sect 14 -the area floods (my next door neighbors house flooded in June 2016). No focused flood risk assessment has been carried out
* NPPF Sect 15 174/175 - to protect and enhance biodiversity.
* NPPF 16 - Conserving the historic environment. R25 and R26 have two Grade 2 listed buildings on the boundary of the development. Red Rose Lane being the point of access for both developments was built as a local 'plague road' from the time of the Black Death
* Location needs to be re-assessed. There is no proven need that Blackmore need this number of houses being distant from transport links and there being hardly any local employment.
* Develop a strategic approach to the Villages north of Brentwood by consultation.
* Detailed flood risk analysis required.
* Assess smaller scale brownfield developments within the area to cater for local need if any is proven.
* Re-assess the development of sites around the transport hubs (Brentwood, Dunton, etc.) rather than rural villages not near mainline rail.

Section 09: (Site Allocation)
- Policy R25, 9.197 - 9.200
- Policy R26, 9.201 - 9.204
Section 04: (Managing Growth)
- Policy SP01 - D (a) and D (f)
- Para 4.9
- Para 4.2
- Policy SP02
Section 08: (Natural Environment)
- Policy NE06, 8.5 - 8.64
- Para 8.85 (iv)
- Para 8.90
- Para 8.101
- Policy NE13

Remove sites R25 and R26 from plan

Section 09: (Site Allocation)
- Policy R25, 9.197 - 9.200
- Policy R26, 9.201 - 9.204



Section 04: (Managing Growth)
- Policy SP01 - D (a) and D (f)
- Para 4.9
- Para 4.2
- Policy SP02

Section 08: (Natural Environment)
- Policy NE06, 8.5 - 8.64
- Para 8.85 (iv)
- Para 8.90
- Para 8.101
- Policy NE13


Unsound; Not compliant with Duty to Cooperate; all reasons unsound.
Written representation only.

* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum.
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue.
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.

Main submission: REPRESENTATIONS TO BRENTWOOD LOCAL PLAN
APPENDIX A: SITE LOCATION PLAN
APPENDIX B: CONCEPT MASTERPLAN
APPENDIX C: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS MAP
APPENDIX D: HIGHWAYS TECHNICAL NOTE (ON PROPOSALS)
APPENDIX E: CONCEPT MASTERPLAN REPORT (separate attachment)
APPENDIX F: LANDSCAPE ASSESSMENT (separate attachment)
APPENDIX G: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS REPORT (separate attachment)

The above representations and supporting evidence can be summarised as followed:
The preparation of Brentwood Local Plan is supported and our comments aim to help it pass the NPPF (2019) test for soundness.
At present, we consider that the Local Plan is unsound and additional work is required to revise the Local Plan. Specifically it is:
* not positively prepared - objectively assessed development needs are not met, duty to cooperate doesn't consider unmet needs.
* not justified - reasonable alternatives are not suitably assessed and the preferred strategy is not suitably justified.
* not effective - the growth strategy is questionable, over ambitious completion rates and over reliance on strategic site.
* not consistent with national policy - Local Plan is not in conformity with NPPF (2019) e.g. objectively assessed development needs are not met, plan period is incorrect, no five year housing land supply is demonstrated etc.
This is a serious matter and we recommend that Brentwood Borough Council thoroughly reviews the approach to plan-making in order to prepare a sound Local Plan. Our main recommendations are summarised as follows:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum;
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer);
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue;
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment;
* Undertake updated Green Belt assessment;
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy.
Recommended modifications:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum. This is required to comply with the NPPF (2019).
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer). This is required to comply with the NPPF (2019).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue. This is required to comply with the NPPF (2019).
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.
Overall the benefits of the proposals represent "exceptional circumstances" in accordance with the NPPF (2019) - regardless of any increase in housing provision - which would allow for the site to be released from the Green Belt for housing.
* Significant community benefit by securing the future of Hopefield Animal Sanctuary. Hopefield will be granted long-term freehold for visitor centre.
* Opportunity to provide a great legacy for the town for recognised important community facility / Asset of Community Value;
* High quality and attractive new residential scheme within landscaped setting;
* New homes (including 35% affordable housing) to meet local needs.
* Significantly improved accessibility and connectivity through new footpath / cycleway connection between Doddinghurst Road and Sawyers Hall Lane and new drop off facility for car users.
* Limited impact on highways. As a result of highways / accessibility / connectivity improvements, the net effect of proposals in terms of vehicle movements for 450 dwellings, will be 285 dwellings, as the proposals will effectively remove trips equivalent to 165 units trips. Highways proposals are supported by Essex County Council.
* Suitable and sustainable location for development;
* Development proposals are developable;
* Proposals bring direct and indirect economic benefits to Brentwood town and the wider area;
* Proposals respect character and identity of Brentwood.
* No / limited impact on the overall role and function of the Green Belt and landscape.
GL Hearn (on behalf of Tesco) are working on a key site in Brentwood at Hopefield. The site is an important local community asset and therefore a solution for its future should be set out in the plan. We have been making Reps to the Local Plan since 2015. Therefore we expect to be part of the Local Plan examination discussions as we aim to help to produce a sound Local Plan.

Give JSP weight in plan to ensure local plans deliver JSP outcomes.

Brentwood Local Plan
Pre-Submission Document

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

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

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

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

Housing requirement number to be recalculated.

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.

Amend using 2014 household projections

Brentwood Local Plan
Pre-Submission Document

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

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

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

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

Remove stepped approach and release more small scale Green Belt locations.

Brentwood Local Plan
Pre-Submission Document

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

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

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

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

Housing requirement number to be recalculated.

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.

Housing Requirement should be recalculated. This will result in the requirement to identify additional site allocations.

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.

For the reasons explained above, the justification for the housing requirement figure will need to be reviewed and updated accordingly. The Council will need to ensure that it can robustly defend the figure that it has put forward. The current wording of the supporting text and the evidence base referred to does not currently provide a robust defense.

BE04
Criterion B(c) of this policy requires the application of the heat hierarchy to all development proposals. This is an unreasonable and unnecessary burden to apply to all developments that is not supported by national policy or the evidence base. Furthermore, it could limit the deliverability of proposals where existing CHP/CCHP facilities are not available and where the cost of developing an on-site facility is prohibitive. It is not reasonable to expect a developer to factor the cost of such an onerous requirement into the development economics for a site and to then have to demonstrate the viability issues surrounding it. It is suggested that such a feature is only justifiable on the largest of the strategic sites proposed in the district and is not relevant to the majority of the site allocations.
Amend criterion B(c) to clarify that such a requirement is only applicable to schemes of 500 residential units or more.
BE10
Criterion C of this policy requires the developer to make alternative arrangements for broadband provision where a provider has identified that superfast broadband is not practical. This shifts the burden of responsibility from the provider - who is paid to provide a service - to the developer. The developer is unlikely to be a broadband provider and as such this is an unreasonable requirement that is not supported by national policy. Furthermore, the viability work in the evidence base does not provide a sufficiently robust assessment of the likely costs of providing this and therefore the impact on the viability of the proposed allocation has not been adequately assessed. This is unsurprising as the likely work is unknown and this only serves to highlight the unreasonableness of the request.
For the reasons explained above, amend criterion C(a) to require a developer to ensure that the design of the development allows for the provision of broadband service via an alternative technology provider rather than require the developer to actually provide the facility.
BE16
The wording of criterion A does not reflect the wording of the NPPF at paragraph 109, which reads:
"Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe." It is therefore inconsistent with national policy.
For the reasons explained above, criterion A should be amended to read: Developments should not give rise to an unacceptable impact on highway safety and the residual cumulative impacts on the road networks should not be severe.
BE18
Criterion B(a) requires development proposals to dictate the decision-making process. It is assumed that this is an error in drafting and that it will be for the Council to ensure that the requirements referred to are factored into the decision-making process. Such a requirement is best-placed in the supporting text with clarification that it will be the way in which the Council will handle decision-making.
Criterion B(f) requires improvements to be made to the water environment. Such a requirement is not justified by national policy as it is not for development proposals to resolve existing issues - development proposals can only mitigate the impact of the development proposed.
Criterion B(g) requires development proposals to eliminate misconnections between foul and surface water networks. This can only be achieved where the whole site is being redeveloped and it cannot remove misconnections that are outside of the developers control. The wording of this criterion is not clear about the remit of the development proposal.
The concerns raised must be addressed as criterion C seeks financial contributions where the measures required are not possible. As worded, some of these requirements are not relevant to the development proposal or deliverable by the developer and therefore it would be unreasonable to seek financial contributions to such works.
For the reasons explained above:
* Delete criterion B(a) and add to the supporting text with clarification that this is how the Council will approach decision-making.
* Remove the reference to improving the water environment in criterion B(f) as a requirement for all development proposals
* Amend criterion B(g) to make it clear that the requirement relates the connections within the development site where the development proposals relate.
BE20
This policy, as written, requires the provision of allotments/growing space as part of any residential development. Neither the policy nor the supporting text identifies the scale of development where this policy would be applicable. Such a requirement will not be feasible on some allocated sites where site constraints mean that the area of developable land is reduced and where the scale of development does not support the provision of land for such a use.
It is considered an unreasonable and unnecessary requirement for any scale of residential development and should be restricted to the larger allocation sites of 500 units or more.
It is considered that this blanket requirement will reduce the development yield of individual allocation sites thereby creating a situation where the allocations do not deliver the number of units identified and contributing to the failure of the plan to meet the identified housing requirement. This would conflict with national policy.
For the reasons explained above, amend the policy to identify that the requirement relates to schemes of 500 units or more.
BE22
The policy identifies the potential for proposals to provide financial contributions towards new or improved facilities in the borough. Although it is noted that the sentence includes the phrase 'where appropriate' it is considered that the policy should make clear that the contributions will go towards facilities that are directly related to the development proposal to mitigate the impacts rising. It would not, for example, be appropriate or consistent with national policy if the contributions were for the improvement of play facilities that the residents of a proposed residential scheme would be unlikely - through proximity - to utilise or have an impact upon.
For the reasons explained above, amend criterion A to make it clear that the financial contributions will relate to facilities that are directly related to the development proposals and the impacts arising.
HP06
Footnote 46 of the NPPF is clear that the optional technical space standards can be used where there is clear need for the standards to be applied. This is reinforced by the PPG. The supporting text for the policy refers to the need being identified in the Council's AMR. The AMR available on the Council's website does not appear to make reference to any such need being identified and there is no other document in the evidence base to demonstrate the need for the application of these standards has been identified and tested.
Furthermore, there is no evidence that an assessment has been undertaken regarding the implications of delivering these standards on the density of development. This is significant as larger properties have the potential to reduce the likely yield achievable and/or result in the loss of land required to meet other standards, such as on-site open space requirements. This gives rise to the potential for the plan to fail to meet the identified housing needs and would render it ineffective.
For the reasons explained above, the Council must either delete the requirement to comply with the technical standards or else provide the evidence necessary to support the policy and demonstrate the implications for development densities. This evidence should be clearly referenced in the supporting text of the policy.
NE03
The wording of this policy is such that it would prevent the loss of any tree or hedgerow within the development site. This is significant as many of the allocated sites include existing trees/hedgerows that are arguably of some value and will have some ecological value. The loss of such trees/hedgerows may be necessary to secure the satisfactory development of the site and deliver the level of development envisaged by the allocation.
It is sensible therefore that the policy reflects the potential for the impact of the loss of some trees/hedgerows to be outweighed by other benefits arising from the development proposal.
This would be consistent with national policy and ensure that the plan can deliver the level of development that has been identified as necessary. Failure to recognise this could render the plan ineffective.
For the reasons explained above, amend the policy to acknowledge that the adverse impacts arising from the loss of trees, woodlands and hedgerows will be balanced against the benefits arising from the development, especially where allocated for development. The wording of the policy can still identify a preference to retain such features within development proposals but must acknowledge the potential for some losses to be inevitable in order to deliver the site allocations or secure an otherwise satisfactory development.
NE12
Criterion A(d) requires the provision of community benefits in order to redevelop PDL in the Green Belt. This is not a requirement set out in paragraph 145 of the NPPF and therefore it is inconsistent with national policy.
Criterion A(e) requires the provision of travel links. This is a potentially onerous requirement for the scale of development that may be proposed and again is not a requirement set out in paragraph 145 of the NPPF. It is therefore inconsistent with national policy.
Delete Criteria A(d) and (e) in order to comply with the NPPF.
NE13
Criterion A of this policy requires the delivery of significant community benefits and the wording of the supporting text advises that this is to 'repay' the loss of Green Belt land. The Council has identified Green Belt land for development as it does not have
sufficient non-Green Belt land to meet the identified housing need. The release of these sites is therefore required to meet these needs and by doing so will self-evidently provide significant community benefits. The requirement for additional provision above and beyond this suggests that the developer has a choice of sites to develop, which is clearly not the case as other non-Green Belt sites would be identified if it were.
This requirement is therefore unreasonable, unjustified and inconsistent with national policy.
Criterion B advises that allocated sites 'will be' deallocated from the Green Belt. As the removal of land from the Green Belt can only come about through the preparation of a development plan this de-allocation must happen upon adoption of the plan and not presented as a future intention.
For the reasons explained above, delete criterion A and amend 'will be' in criterion B to 'are'.
SP01
The wording of criterion D(d) does not reflect the wording of the NPPF at paragraph 109, which reads:
Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.
It is therefore inconsistent with national policy.
To reflect paragraph 109 of the NPPF, criterion D(d) should be amended to read:
d. ensures the proposal would not give rise to an unacceptable impact on highway safety, or give rise to a severe residual cumulative impact on the road network.
SP02
The housing requirement set out in the policy is based on an out-of-date method for calculating the LHN. The supporting text indicates a figure that relates to the 2016 HHP when the most recent advice is that the 2014 HHP should be used. This is significant as the Council has chosen to add a buffer to this figure to allow for the supply of housing to be maintained.
The 2014 HHP with the 2017 affordability ratios applied reveal that the base need is 452 rather than 350 as the Plan states. Although this is broadly similar to the 456 per annum figure allowed for in the policy, it does not allow for the buffer that the Council has considered necessary.
This raises potential consistency issues with national policy that may influence the ability of the plan to deliver the housing required to fulfil the identified need.
For the reasons explained above, the justification for the housing requirement figure will need to be reviewed and updated accordingly. The Council will need to ensure that it can robustly defend the figure that it has put forward. The current wording of the supporting text and the evidence base referred to does not currently provide a robust defense.
SP03
The policy presents an unnecessary burden on those developers bringing forward allocated sites where the infrastructure capacity on an area should have already been identified through the plan-making process, as required by the PPG. It is considered that HIA should be confined to strategic sites (500 units or more) to reflect the fact that, in line with the PPG, they are required where significant impacts are anticipated.
Other impacts referred to in the policy are a standard part of the development management process and do not warrant a further assessment to be included with the application. These are adequately summarised in criterion A of the policy.
Furthermore, the criterion C places the burden of delivery of health and social care facilities on the developer. The developer is unlikely to be a health and social care provider and therefore cannot reasonably be expected to deliver such facilities.
It is also important to acknowledge that the developer of an individual site cannot be expected to address existing deficiencies in an area. This is important as it may be that such facilities are entirely absent in any area where development is allocated despite the existence of an existing need. In such case, the wording of the policy means that a developer could be required to provide more than is necessary to mitigate the impacts arising from the development.
The issues identified above raise conflicts with national policy and could prejudice the deliverability of individual sites, thereby undermining the effectiveness of the Plan.
For the reasons explained above:
* Amend criterion C to raise the threshold to 500.
* Remove the requirement for the developer to deliver the necessary health and social care facilities
* Ensure that it is clear that the developer is only expected to contribute to improvements necessary to mitigate the impact of the development where such facilities are already in place.
SP04
Criterion A of the policy expects developers to guarantee the sustained provision of infrastructure. It is important to recognise that developers are rarely the infrastructure provider and therefore have no control over the sustained provision of the infrastructure that they contribute to.
The responsibility for sustained provision rests with the infrastructure provider and this should not be transferred to the developer. To do so conflicts with national policy.
Criterion F requires a Financial Viability Assessment where there is conflict with planning policy requirements. It does not specify which policy conflicts would trigger this need and so as currently written would apply to any such conflict. This presents an unreasonable and unnecessary burden for a developer where the conflict arises because it of feasibility issues rather than viability issues. There may also be sound material considerations for departing from a particular policy and those reasons may have nothing to do with viability. The blanket requirement for such an assessment is contrary to the PPG and national policy.
For the reasons explained above, remove the last sentence of criterion A and amend criterion F to confirm what policy conflicts trigger the need for a viability assessment.
SP06
The policy does not define what it considers to be a 'large complex allocation site' and as such could impose a blanket requirement for the submission of a masterplan and a design code as part of the submission for all allocated sites. This is considered to be an unreasonable and unnecessary burden that is not supported by the NPPF or the PPG and is not justified by the individual site allocations.
It also has the potential to slow down the delivery of sites, which for a borough with a poor track record of delivery is not sensible.
For the reasons explained above, clarify in the policy which of the allocated sites fall within the definition of a 'large complex allocation site'.
The issues raised are complex and would benefit from discussion at the Examination.

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.