See supporting statement - In summary, we believe our clients site at Hatch Road has been soundly tested at appeal and represents a more logical green belt allocation for growth

See supporting statement

remove the Dunton Hills Garden Village development. Add development along the A12 corridor instead.

Brentwood Council have justified concentrating their green belt development in Dunton Hills and West Horndon by saying that it will make it possible to fund infrastructure. The opposite is true. The amount of money that can be obtained from CIL can only pay for schools, health centres, flood mitigation and other normal requirements.

The A127 was de-trunked in 1997 and has since been underfunded by Essex County Council. It is now a very low quality road with numerous low quality side exits. The fortune of war roundabout which has remained an obstacle for decades is symptomatic of this failure along the whole route from Gallows Corner to Southend. It supports levels of traffic which anywhere else would justify a three lane motorway, yet only modest junction improvements have been proposed. With 90,000 new homes planned for South Essex it can only get a lot worse, yet nothing is on the horizon to sort it. Even if funding were to be made available it would take twenty years to plan and implement any major improvements.

The situation with the A12 which remained a national trunk route could not be more of a contrast. It is a high quality route with a high standard of junctions all along. Widening through Brentwood is already funded and planned for the near future. Much widening has already been done.

Brentwood should be looking to take advantage of these improvements which unlock housing development along the A12 corridor. Building a garden village at Dunton Hills will only make the problem there more acute over the next 20 years before anything can be put in place to upgrade the A127.

Other roads present similar problems. The A128 is a low quality congested road but Dunton Hills Garden Village will rely on it for residents heading South towards the Lower Thames Crossing or North towards Brentwood. If Dunton Hills is to provide the affordable housing required for the rest of Brentwood then a new major North-South bypass would be needed to replace the A128 and must be funded and planned for rapid construction. I do not believe this will happen. Development around the A12 corridor nearer to where the affordable housing is needed for teachers and other key workers in the area would not require this.

The same situation exists for rail networks. The C2C line in the South near Dunton is just one pair of tracks with one station in Brentwood Borough at West Horndon. The line through Brentwood has stations in Brentwood Town, Shenfield and Ingatestone. It has four tracks and incorporates the new Elizabeth Line for Crossrail. Brentwood Council seems happy to accept the benefit of this line for its existing affluent residents but it does not want to allow the huge investment in Crossrail to unlock the economic and housing development that its cost justifies.

Even with schools we see the same pattern. Brentwood wants to keep hold of its surplus of secondary schools around Brentwood Town, yet it does not want to welcome new families who could send their children there without long bus and train journeys from far away. The new school proposed for Dunton Hills will not materialise for many years if at all because the development is not big enough to justify it and schools in Brentwood will need to be filled by pupils travelling along the A128 from Dunton Hills to the Brentwood schools.

These considerations make the Dunton Hills development unsustainable in numerous respects described in the National Planning Policy Framework. The Plan is therefore unsound.

This site should be included as part of the site allocations within the Local Plan.

We write in response to the consultation currently being undertaken by Brentwood Borough Council (BBC) in relation to the Draft Local Plan Pre-Submission Document (February 2019). We write on behalf of our client, MM Properties (London) Ltd, to promote the site above for residential uses within the Plan period. This follows pre-application discussions with the Council on the site in respect of it being brought forward for residential development. The site is located within the Green Belt, but in-part comprises previously developed land. It is the intention of our client to bring forward the site at the first available opportunity. The site is available now, and can make an immediate contribution to the Borough's housing supply. As a general comment, we note that the National Planning Policy Framework (NPPF) requires all Local Plans to apply the presumption in favor of sustainable development. It states that local planning authorities should positively seek opportunities to meet the development needs of their area and Local Plans should meet objectively assessed needs with sufficient flexibility to adapt to rapid change. They should be consistent with the principles and policies of the NPPF, and should be aspirational, but realistic. Paragraph 35 of the NPPF identifies the criteria on which Local Plans are assessed on to determine whether they are 'sound'. Plans are 'sound' if they are: 1. Positively Prepared - be based on objectively assessed development requirements, consistent with achieving sustainable development; 2. Justified - be the most appropriate strategy based on proportionate evidence; 3. Effective - be deliverable over its period and based on effective joint working; 4. Consistent with National Policy - enable the delivery of sustainable development in accordance with the policies of the NPPF. The site is located to the south east of Wyatts Green, and north of Swallows Cross, and accessed by Wyatt's Green Road. A copy of the site location plan enclosed with this letter. The site is roughly rectangular in shape, and measures approximately 1.3 hectares in area. Wyatt's Green Road forms the southern boundary of the site, and the eastern boundary is defined by Mountnessing Road. The site is well screened by mature trees at the northern boundary, beyond which is an existing residential dwelling set within a large plot. The surrounding area is predominantly residential in character. There are two storey dwellings opposite the site on Wyatt's Green Road and bungalows immediately east of the site. Chivers Farm is located to the south east of the site and Swallows Cross Farm is located to the west of the site off Wyatt's Green Road. This farm is subject to a full planning application for 18 dwellings which is pending determination (LPA reference 18/01579/FUL). This follows the grant of outline planning permission in April 2017 for 9 dwellings (LPA reference 17/00211/OUT). In recommending this application for approval, officers concluded that the redevelopment of the site for residential would not be locationally unsustainable. The site is within close proximity to existing bus stops along Wyatt's Green Road, including the 436, 431, and 689 which serve Ongar, Blackmore, and Shenfield, the latter of which is currently part of the TfL Rail/Elizabeth Line underground service. Part of the site has been previously assessed in the 2011 SHLAA as a discounted brownfield site under site reference B023. A site location and extract from this assessment is below (refer to attached document for image and table included). Since this assessment was undertaken, the site boundary has been extended to include additional land located immediately adjacent. MM Properties have developed Masterplan for the site supported by necessary technical work to address the key matters associated with the site. This demonstrates that the site has capacity for between 30-35 dwellings, including an element of affordable housing. The Regulation 19 pre-submission Local Plan seeks to make provision for 7,752 new residential dwellings to be built in the Borough over the Plan period 2016-2033. A stepped trajectory is proposed, which will be implemented as follows: 2016/17 - 2023/24: 1,912 dwellings at an annual average rate of 310 dwellings per year; 2024/25 - 2032/33: 5,840 dwellings at an annual rate of 584 dwellings per year. The consultation document justifies the stepped trajectory through forecast rate which demonstrate a significant proportion of new homes being delivered beyond 2023. The housing numbers are also justified on the basis of the standard methodology for calculating housing need. Whilst this is the correct approach, it is evident from the calculations in the consultation document, and the accompanying Strategic Housing Market Assessment, that the inputs into the methodology used in determining a need for 350 net dwellings per year are incorrect. These amendments, against the direction and guidance of national policy, have result in a deflated housing needs figure. The Strategic Housing Market Assessment, to which the consultation documents reference, has undertaken the standard methodology calculation on the basis of the 2016-Household Projections. The MHCLG in February 2019, however confirmed that the 2014-based household projections should be used in such calculations (as they are higher). In case of Brentwood, the use of the incorrect household projections deflates the housing need figure by circa 24%. In addition, the 2019 median workplace based affordability ratio has been used to calculate the adjustment factor. The PPG is explicit that the most recent median workplace-based affordability ratios should be used in this calculation. At the time of writing, this is the 2017 data, although it is accepted that an update to this data is imminent. In any case, the data used for the purposes of the consultation is based on projected data that is inherently unreliable and unjustified by policy. On the basis of 2014-based household projection data, coupled with the use of the most recent affordability ratios the housing need figure is 454 dwellings per annum (inclusive of a cap), and not 350 dwellings per annum, as stated in the consultation document. The Council has correctly identified that a 20% buffer is required in addition to the local housing needs assessment. This has been qualified by the MHCLG in their recent publication of the Housing Delivery Test which demonstrates that over the preceding three years, Brentwood delivered only 51% of the homes required in the Borough. On the basis of the above, the local housing needs assessment should be recalculated to reflect changes in policy. This should include a 20% buffer. At the time of writing, this figure is 545 dwellings per annum, although it is accepted that the impending affordability ratio result in minor amendments to this figure. There is therefore a need to substantially increase the Council's housing requirement in the first part of the plan period. This will required additional sites to be identified and our client's site at Swallows Cross is considered to be available, suitable, and would contribute to the additional housing need identified. Paragraph 136 of the NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation of local plans. The Council have prepared a Green Belt study prepared by Crestwood (November 2018) which forms part of the Local Plan evidence base. The study reports that 89% of the Borough is currently designated as Green Belt, and as such, allocated land currently designated as Green Belt is unavoidable in order to meet the development needs of the Borough in respect of housing requirements. The Green Belt study review assessed sites being considered as part of the SHLAA assessment that were located within the Green Belt, and their relative contribution to the purposes of the Green Belt designation. Despite the suitability of the site for housing, the site did not form part of the Green Belt Assessment, however it is our submission that considering the site comprises part developed land; it has no recreational value; there is no public access; and it is physically and visually constrained by the existing treeline. It therefore makes a very limited contribution to the Green Belt. In assessing whether the release of the site from the Green Belt would conflict with the five general purposes of the designation, the following should be considered: 1. To check the unrestricted sprawl of large built-up areas. The site is contained by a thick and mature line of trees that prevent an unrestricted sprawl beyond the confines of the site. To the south the site is Wyatt's Green Road which is abutted by development on both its northern and southern perimeter, and to the north of the site is an existing property. The closest built-up area is Wyatt's Green itself which is separated from the site by over 1km of open fields, which are also designated Green Belt. Of particular relevance is the brownfield nature of the site which contrasts the open fields that surround the immediate built-up area. A significant proportion of the site is hardstanding and built form, and so any encroachment into the countryside will be minimal. 2. To prevent neighbouring towns merging into one another. As mentioned above, the site is well contained by the existing road infrastructure and three line on the northern boarder. Furthermore, the site is over 1km from the settlement of Wyatt's Green and over 1.3km from the village of Doddinghurst. As such, there is no prospect of neighbouring towns merging into on another. 3. To assist in safeguarding the countryside from encroachment. The application site as it stands makes a very limited contribution to the open countryside. It is completely enclosed with no public access, and adds little to the rural landscape character or quality. The site's contained nature, and the existing development accommodated on the site means that the prevailing open character of the wider countryside will not be materially altered. 4. To prevent the setting and special character of historic towns. The site is not located within or adjacent to a Conservation Area. There are two historic buildings associated with Ray Place Farm to the north, however the line of trees and vegetation that exists between the two sites means that it is not possible to view the adjacent listed buildings from the site. Development on the site would therefore not impact upon the setting of any historic assets. 5. To assist in urban regeneration by encouraging the recycling of derelict and other urban land. The eastern part of the site is occupied by commercial buildings and activities. The allocation, and development of this site, would therefore recycle this brownfield land in terms of urban regeneration and as part of the wider redevelopment of the site. Of particular relevance in this case, is the number of alternative sites being removed from the Green Belt which do not constitute previously developed land. In this respect, the site is considered sequentially preferable in terms of Green Belt objectives than other Green Belt sites considered deliverable by the Council. As a means of meeting the uplift to the Council's housing requirement, BBC has allocated a number of sites in the Green Belt where it has been determined that harm to the landscape and openness will be minimised. The Council states that the sequential land use test, in line with guidance and best practice has been undertaken to prioritise growth based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate. Despite this, a number of Green Belt sites have been allocated in the plan for residential purposes that are entirely greenfield, or comprise some brownfield elements that make up a small proportion of the site. The site The site at Wyatts Green Road accommodates a significant proportion of brownfield land, despite its Green Belt designation, and therefore should be released from the Green belt and allocated for residential uses. This is especially relevant given the need for an uplift to the housing requirement given the required amendments to standard methodology calculation as identified earlier in this representation. Overall, this site is a sustainable urban extension within the Green Belt that can make a contribution to the borough's housing land supply over the life of the Plan. The majority of the site is brownfield land, with the greenfield element of the site well contained by existing roads and tree lines. The site also has good access to Wyatt's Green Road, including the bus services that operate on this route. It is suitable and available, and a development of between 30-35 dwellings is achievable. It is therefore respectfully requested that the site is allocated for residential development in the emerging Local Plan. We look forward to receiving confirmation of receipt of these representations and would welcome the opportunity to discuss matters further with officers in due course.

We write further to the above consultation on the above on behalf of our clients, Hermes Investment Management and Hermes Property Unit Trust ("Hermes"), the asset manager and owner of the West Horndon Industrial Estate, Station Road, West Horndon (your site refs 021 & 022). You may recall, Hermes acquired Threadneedle's interest (approximately covered by your site ref 020) last year, so they now own the bulk of the larger West Horndon Industrial Estate which includes your site refs 020 and 021. Their discussions to acquire the land shown by your site ref 152 are well advanced and will be subject to planning permission for the residential-led, mixed use redevelopment of the land which is allocated by R02 in the Pre-submission draft of the Local Plan. As you know form the last consultation in March 2018, our preparation of a planning application for residential led mixed-use development on the western portion of the industrial estate (including land identified as site refs 152, 021 and part of 020) was well advanced, and we had expected to submit the planning application sometime last year. However, following the acquisition of Threadneedle's interest and taking account of the views of Brentwood's officers and West Horndon Parish Council, Hermes took the decision to expand the planning application to include the whole of the land identified as R02. This has resulted in additional work and will require further pre-application discussions and consultations (with Brentwood BC, Essex CC and West Horndon Parish Council). Our revised aim is to make the hybrid planning application for the whole site later this year (around September/ October). Hermes has made representations to the various drafts of the local plan over the time of its ownership. It is not our intention to repeat any of those in relation to the Pre-submission draft of the Local Plan. Instead, our representations will focus solely on matters that affect the draft allocation R02. Please note, in expressing support or comment on the matters set out below, Hermes is affirming they consider the Pre-submission draft of the Local Plan to be sound. Page 22 Settlement Category - SUPPORT: West Horndon as a large village within settlement Category 2. Page 24 para 2.14 - SUPPORT for improvements to access to West Horndon station arising from and facilitated by Dunton Hill Garden Village. Page 39 para 3.21 (b) - SUPPORT. Page 92 Policy BE11 (B ii) - SUPPORT Strategic Transport Infrastructure designed to improve access to West Horndon station; arising from and facilitated by Dunton Hill Garden Village. Page 95 para 5.96 (c) - SUPPORT Page 96 para5.105 - SUPPORT Page 103 para 5.121 - SUPPORT Page 114 para 5.155 - SUPPORT Page 177 Policy PC03 Employment Land Allocations include 2.0 hectares of R02 - SUPPORT & COMMENT: insofar as this includes the employment to be retained on the site, as well as the new employment opportunities created by the new village centre (which will include retail and non-retail uses). Page 181 para 7.30 - SUPPORT Page 185 Policy PC07 Retail and Commercial Leisure Growth - SUPPORT & COMMENT: it is important to note the Brentwood Retail and Commercial Leisure Study (Dec2014) by NLP. The emerging West Horndon master plan includes a new village centre which incorporates shops and non-retail uses, such as potential health facilities. NLP suggested an additional 2000sqm of retail may be appropriate as part of the redevelopment of the industrial estate. Our latest masterplan shows around 2700sqm, but this includes non-retail uses. Page 186 para 7.53 - SUPPORT Page 187 Policy PC08 - SUPPORT& COMMENT: the new village centre for West Horndon is likely to include an additional 2700sqm of retail and non-retail accommodation. Page 231 Policy NE10 Green Belt - COMMENT: West Horndon is not within green belt, so it is unclear what purpose reference to it in this policy serves. Page 244 para 9.7 - SUPPORT the reference to R02 on the list of Strategic Housing Allocations. Page 254 Policy R01 (II) d- SUPPORT Page 269 Policy R02: LAND AT WEST HORNDON INDUSTRIAL ESTATE & supporting paragraphs - SUPPORT & COMMENT: Hermes' draft masterplan for the whole site includes a variety of dwelling types, including flats (making up the proposed village centre, nearest to the Station Road entrance and West Horndon station) and 2, 3 & 4 bed houses. At present, the R02 site measures 17.6 hectares gross, which nets down to 15hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is nearer 750 dwellings, which is well over the figure of "around 580 new homes" set out in the policy. Page 309 Appendix 1 Housing Trajectory - SUPPORT & COMMENT: the timing of the supply of houses accords with the proposed phasing and Hermes' management of the existing leases on the estate. Please note comments in relation to the numbers of new dwellings the site can accommodate. Page 318 Residential Lead Sites - SUPPORT & COMMENT: it is unclear how Brentwood BC have worked out the gross (17.06ha) and net (10.23ha) figures as set out in the table accompanying the site allocation plan. It is also the case that the draft Local Plan's gross to net calculations given for all the larger residential allocation sites varies, sometimes considerably. At present, the R02 site measures 17.6 hectares in total, which nets down to 15 hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is showing the number of dwellings to be nearer to 750, well over the figure of "around 580 new homes" set out in the policy. It is also noted that the density of development is lower in the Hermes' latest masterplan (50dph) than that suggested by draft Local Plan (56.7dph), although it is accepted that this depends entirely on the chosen base. Please let me know if anything is unclear. We would ask that you acknowledge receipt of these representations.