* 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.

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

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

Redrow Homes propose: 1- A new policy to follow on from Policy SP02, in Chapter 4 (Managing Growth): Alteration of Green Belt Boundaries The areas of land covered by the following policies are removed from the Green Belt: RO3, (and all others concerned) The Council has arrived at these alterations on the basis of a sequential examination of brownfield and other sites not in the Green Belt, of a review of densities of development and of discussions with neighbouring local authorities to test the scope for them meeting some of the need for housing arising in Brentwood. The exceptional circumstances that justify the alterations are the severe shortage of land not within the Green Belt and suitable for development, making it impossible for the Council to meet its housing need other than through limited alterations of Green Belt boundaries. The Council has selected sites for boundary alterations where there will be least harm to the purposes of the Green Belt. 2- A new line to be added in the sequential test set out in para 3.23 Using Land Sequentially and the table revised to focus on land types: - Brownfield land within urban areas - Greenfield land within urban areas - Brownfield land within the Green Belt - Greenfield land within the Green Belt3- Policy NE13 (Site Allocations in the Green Belt) is altered as follows: These sites are de-allocated from the Green Belt to allow development to take place... 4- Para 8.117 is deleted.

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