1.Introduction/Background
1.1.We write to set out an objection to the Brentwood draft Local Development Plan 2019 (The Plan), on behalf of BJ Read Associates.
1.2.BJ Read Associates have land interests at Roman Road, Mountnessing.
1.3.This representation is a formal objection to the Council's approach to the Local Plan process on the following basis:
*The approach to housing is fundamentally flawed and unsound; the Plan is not positively prepared; justified; effective; or consistent with national policy. This approach is in direct conflict with the National Planning Policy Framework (The Framework).
*Delivering a wide choice of high quality homes; the Plan fails to identify available land in its draft site allocations. This is contrary to the Framework.
*The preferred strategy results in an unsustainable pattern of development. This is due to the fact that a number of the proposed strategic housing allocations are less sustainable and appropriate than un allocated alternatives; and
*Land at Roman Road Mountnessing would be a far more sustainable option for development. This is due to the clear locational/sustainability advantages of the site.
2.The Principles of Plan making
1.4.The Local Plan should be progressed in accordance with the National Planning Policy Framework (The Framework) and in particular;
"be prepared with the objective of contributing to the achievement of sustainable Development; and
be prepared positively, in a way that is aspirational but deliverable;"
1.5.The Framework states that, crucially Local Plans should be sound. They are "sound" if they are:
Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs19; 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 this Framework.
3.The Plan's approach
1.6.The draft Plan fails in its approach to housing for the following reasons:
1.7.SP02: Fig 4.2 Too great an emphasis is placed on Dunton Hills Garden Village to provide for housing growth. .An annual housing rate of 310 per year to 2023 reflects poor and unrealistic housing site choices. This strategy will have an adverse effect on affordability in the short term which will in turn increase land prices in the longer term.
1.8. HP04 BE14 Specialist accommodation for older people. The Draft Plan acknowledges the aging population but fails to plan for any increase in accommodation. In effect policy HP04 creates un-justified negative criteria against which to consider proposals. This approach is contrary to NPPF and NPPG guidance.
4.Roman Road Mountnessing as an alternative site
1.9.The Roamn Road, Mountnessing site is available for development, free from constrains and there is a clear commitment to provide affordable housing and or specialist housing for older people on this site. The delivery of this site is more certain than any other local site given that:
*it is in a single ownership;
*it has immediate and appropriate existing access to the main highway network (Roman Road);
*it is free from significant constraints or factors which would give just to additional, abnormal development costs;
*it is located within Mountnessing; and
*the land is not of any particular outstanding quality.
1.10.The allocation of Green Belt sites for housing confirms the principle that the release of Green Belt Land to meet the defined need for housing in the local plan is a "very special circumstance". It follows that if this is to be acceptable the chosen sites for release must be the most appropriate.
1.11The Mountnessing Site is clearly the most sustainability location at which to meet, at least in part, the housing needs of Brentwood. The Site is not of high landscape value and any development would be distant from heritage assets in the area and public parks. The only point against the option is its location in the policy defined Green Belt.
5.Conclusions
1.12.The conclusion to the above analysis is that the draft Plan is unsound. The Mountnessing site has been incorrectly analysed by the Council and if were correctly so, would be a leading site to meet the housing needs of the Plan.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed to reflect that housing provision reflects a 'minimum'. This also ensures consistency with national policy and guidance, and Local Plan Policy R01.
To ensure that the plan is positively prepared and consistent with the NPPF criterion A should be updated to reflect that "provision should be made for a minimum of 7,752 new residential dwellings...".

CEG supports the inclusion of Figure 4.2 to explain how housing provision will occur. The column entitled 'Net homes' should either be retitled 'Minimum net homes' and/or a footnote should be included relating to DHGV to the effect that 2,700 is the minimum to be provided, consistent with the wording of Local Plan Policy R01.

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

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

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

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

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

The Pre-Submission Document relies very heavily on the Dunton Hills Strategic Allocation. If it were not accepted, or only partially accepted, a review of all the Plan's allocations would be needed and alternatives, like our client's site at Pilgrims Hatch, be reconsidered to make up the deficit.

Figure 4.2 sets out a total net new homes requirement of 7800 of which 6100 will be met on new land allocations. One strategic allocation, Dunton Hills Garden Village, accounts for 2700 or 44% of the total allocations. The Plan is therefore heavily dependent on the ability of this site to deliver within what remains of the Plan period, which is 12 years.
The Document's Appendix 1: Local Development Plan Housing Trajectory, notes a potential delivery start in 2022/23. This means the allocation will need to deliver 2700 homes over a nine year period, an annual build rate of 300, around the build rate for the whole District predicted during the Plan's first six years.
The 2018 consultation on the Preferred Sites Document said that delivery at Dunton Hills would start by 2021/2022. 2500 homes would be delivered over 10 years, a build rate of 250 per year.
The logical conclusion is that the longer it takes for the emerging Local Plan to be adopted, the shorter the time and the higher the build rate will need to be. The LDP Timetable suggests that adoption will be in Quarter 3 of this year. We believe adoption will more likely happen in Quarter 1 next year or beyond. This will squeeze delivery at Dunton Hills into an eight-year period with a resulting annual build rate requirement of nearly 340.
In commenting on the Preferred Sites Document in 2018, we referred to research carried out by Nathaniel Lichfield and Partnership on delivery from large housing sites. Their report calculated the average planning approval time for sites of 2000 or more dwellings was 6.1 years. The 'planning approval period' was calculated as the time between the validation date of the first application for the proposed development to the decision date of the first detailed application which permits the development of dwellings on site.
We believe the Local Development Plan Housing Trajectory's figures for Dunton Hills Garden Village are based more on wish fulfillment, rather than solid evidence of achievable build rates.
The Dunton Hills Garden Village proposal remains locally controversial. A number of local newspaper articles, published during 2018, highlight opposition to the proposal from two neighbouring Local Planning Authorities: Basildon Borough Council and Thurrock District Council.
Your Thurrock in an article dated 29 October 2018 quotes Thurrock as saying :
"The location does not have any public transport such as a railway station or other infrastructure or services compared to existing settlements", adding that the development will have "a much greater negative impact on the landscape than stated".
The same article quotes Basildon Borough Council as follows:
"The proposals in Basildon and Brentwood Boroughs could, without careful planning and site allocation choices, lead to settlement coalescence and inadequate access to appropriate infrastructure, which in turn could have implications on the amount of development that can be brought forward in this location on both sides of the boundary."
Basildon's website says that Dunton Garden Suburb:
"... was a potential cross-boundary development opportunity to the west of Laindon (Basildon Borough) and east of West Horndon (Brentwood Borough) for 4,000 to 6,000 homes."
It goes on to say:
"On 4 November 2014, Basildon Borough Council and Brentwood Borough Council each signed a Memorandum of Understanding (MOU) setting out the terms and conditions for the joint project to explore Dunton Garden Suburb in accordance with Section 110 of the Localism Act 2011, also referred to as the Duty to Cooperate. It expired on 4 February 2016 and has not been renewed."
Brentwood Borough Council's Dunton Hills webpage makes no reference to the expiration of the MOU, neither does it record any further progress with the project following January 2018's Preferred Sites consultation. CEG is the company promoting the Dunton Hills project; their website relating to the proposal is currently a holding page.
The Emerging Basildon Local Plan shows no proposals relating to the Dunton Hills project on its side of the border. Instead it shows the whole area as Metropolitan Green Belt land.
All the above indicates that there has been a lack of cross-border cooperation on the Dunton Hills proposed land allocation since 2016.
We believe both the quantity and timing of new housing delivery from this site, set out in the Pre-Submission Document, are not soundly based. Furthermore we believe the whole project is now mired in a controversy that involves two of the Borough's local authority neighbours. This must cast doubt on whether the Duty to Cooperate has been fully followed. Therefore at present the whole project is surely in jeopardy.

The Plan should be reviewed and sites identified to meet the higher housing number of 547 dwellings per annum, through the addition of smaller site allocations. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have fewer complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver.
Allocating additional smaller sites will have multiple benefits; it will increase the flexibility of the Plan, it will contribute to the five year housing land supply, it will enable sites which do not require significant infrastructure provision to come forward quickly, and it will attract smaller house building companies who will not be present upon larger strategic sites.
Paragraph 3.21c of the Plan states that:
'Brownfield opportunities will be encouraged where appropriate schemes help meet local needs and ensure that our villages remain thriving communities, in line with policies in the Plan. Where appropriate, this includes the redevelopment of previously developed sites in the Green Belt.'
This source of sites should be reviewed to provide smaller sites which increase the deliverability and flexibility of the Plan.

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

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

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

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

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

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


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

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

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