(see attached / comments re Chapter 3 - Vision)

BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION
1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')
Introduction
2. The Parish Council is a statutory consultee and represents 350 households in
Blackmore village (population of only 943) included in a total population of 2,561
within the wider Parish with its three distinct separate settlements. This figure does
not include the many households in neighbouring villages who rely on Blackmore's
facilities.
3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150
active members but its newsletters are distributed to over 1,000 households.
4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites
R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece,
Blackmore) for housing development. The proposed allocation is for "around 40 new
homes" at R25 and for "around 30 new homes" at R26.
5. They say that the proposed allocations R25 and R26 are contrary to both National
and Local Policies.
6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1. Brentwood Borough Council has failed to demonstrate that the required housing
need cannot be met on existing previously developed land/sites in existing urban
areas or by increasing densities on proposed allocated sites.
6.2. Without prejudice to the above contention, if no such sites exist, that Brentwood
Borough Council has failed to demonstrate there are no or insufficient previously
developed sites available outside the existing urban areas.
6.3. In any event, there are greenfield sites available (for example adjoining existing
urban areas) in preferable and more sustainable locations.
6.4. Moreover, R25 and R26 are inherently unsuitable developments because of (1)
inadequate access, (2) flooding, (3) it will result in disproportionate increase in
the housing stock, and, (4) the development would not be sustainable.
7. The Parish Council and BVHA also take issue with the proposed allocation of
Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy
(see pages 21-25 of the Regulation 19 Draft Local Plan).
8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed
allocations R25 and R26 and the allocation of Blackmore as a "larger village", is
unsound in that it has not been positively prepared, is not justified, is not effective
nor consistent with the National Planning Policy Framework (February 2019
edition)('the NPPF').
Background
9. Blackmore is currently a village of approximately 350 dwellings which are home to
943 people (according to the Electoralcricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity
use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle.
In addition to the Anglican parish Church there is a Baptist Church in the village.
However, Blackmore has a very limited bus service and is thus remote. It is over 6
miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on
the motor car.
11. The village School is at capacity and local residents are having to send children to
neighbouring schools. There is limited scope for expansion. It is socially undesirable
for some village children to be able to attend the village school and others to be
"shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more
resident village children had to be "shipped out" to another school.
12. In respect of employment opportunities within Blackmore these are limited and, of
those of working age nearly all, if not all, commute out of the village. That commute
takes place, if not exclusively, almost exclusively by private motor car. Such further
evidences that Blackmore is an unsustainable location for new development.
13. Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both
are bordered (to the north) by Redrose Lane, a rare extant example of a "plague
detour route". Redrose Lane is narrow and with limited passing space for two motor
cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one,
or the other, stopping (see Appendix One). Development of 70 dwellings would
undoubtedly result in a significant number of vehicular movements - in the order of
600 to 700 per day - and, without suitable improvements (which would erode the
character of Redrose Lane), cause harm.
14. Both R25 and R26 are in the Green Belt. Both are on land classified as "very good"
agricultural land. Both sites have ecological value and, more importantly, local
residents have reported sightings of bats, owls and newts at, or in the vicinity of,
R25 and R26 (See Appendix Two).
15. Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25
and R26 have flooded historically - and both have an identified flood risk (see
Appendix Three).
16. The BVHA undertook a survey in July 2018 of local residents and visitors to the
Village. The BVHA survey confirms that residents are opposed to the proposed
allocation of R25 and R26. Of the responses received from village residents, over
300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be
noted that the response numbers (over 300 adult residents in the village) was
extremely good and evidences the strength of local feeling. It also outlines the
engagement of the local Community.
Issues concerning Consultation and Consistency
17. It is a maxim that "good planning is consistent planning".
18. The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and
tightly controls development in the Green Belt. Thus, development on R25 and R26 is
contrary to the current Local Plan policies absent "very special circumstances".
19. In a 2014 site assessment document, which was and is part of the current emerging
local plan process, sites R25 and R26 were discounted as they did not meet the
(then) draft Local Plan spatial strategy.
20. It is not clear why this assessment has changed - indeed, the constraints
surrounding site R25 and R26 remain unchanged.
21. More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated
that "No amendment is proposed to the Green Belt boundaries surrounding larger
villages [Blackmore is defined as a larger village] in order to retain the character of
the Borough in line with the spatial strategy" (para 5.33). That spatial strategy
seeking, insofar as it was necessary to do so, "limited release of Green Belt land for
development within transport corridors, in strategic locations to deliver selfsustaining
communities with accompanying local services, and urban extensions with
clear defensible physical boundaries". So even though Brentwood Borough Council
had identified a potential need for release of Green Belt land, no suitable land was
identified in Blackmore.
22. There has therefore been a significant shift of policy; namely from a position of no
development at R25 and R26 to now seeking to allocate these sites for residential
development. The Parish Council and BVHA say that the change in position is
inconsistent and wrong for reasons more fully set out below.
23. The Parish Council and BVHA also wish to record that the Council's planning Team,
represented by a Strategic Director and three other Senior Officers, confirmed at a
public meeting on 31 January 2019 that Blackmore's allocation was a result of
property developers promoting the development of land on which their companies
held options. The Parish Council and BVHA take the view that, not only would the
proposed allocation of R25 and R26 appear to be "developer-led" rather than planled,
it shows a lack of thorough and appropriate research, and understanding of the
unique character and circumstances of Blackmore. The Parish Council and BVHA
further take the view that developer pressure is not a good and sufficient reason for
Brentwood Borough Council to abdicate its duty to promote a sound, and consistent,
Development Plan.
Evidence Base
24. Paragraph 31 NPPF provides that the preparation and review of all policies should be
underpinned by relevant and up-to-date evidence.
25. Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan
- SA Report - January 2019" ('the SA'). The SA tells us that a number of
sustainability 'topics' inform the framework for assessing the sustainability of the
site. Flooding is one of those topics (see Table 3.1 of the SA).
26. Risk of flooding is important to any sustainability appraisal not only because the NPPF
and emerging policy NE06 seek to direct development away from areas of highest
risk of flooding but also because flooding can put lives and property at risk. It is
therefore surprising that, for all bar 21 potential sites, the SA does not consider flood
risk in assessing sustainability.
27. The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies
a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26
being potentially vulnerable to climate change and with a 1 in 100 annual probability
of surface water flooding (Table A6b). The findings appear at odds with the fact that
Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be
more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites
have consistently flooded as evidenced by the photographs in Appendix Two.
28. There are, of course, documents supporting housing need. However, there is no
evidence of local housing need for Blackmore, or any other villages. Whilst the Parish
Council and BVHA accept that there may be some demand for housing any such
demand should be properly evidenced with any housing allocation proportionate and
ensuring that houses are being built in the right places.
Sustainable Development
29. It is a core planning principle that plans should be prepared with the objective of
contributing to the achievement of sustainable development (para 16(a) NPPF).
Paragraph 8 NPPF outlines three objectives that the planning system should strive to
meet.
30. The proposed allocation of sites R25 and R26 meets none of these objectives in that:
30.1. Economic objective - any contribution arising from the construction of new
dwellings will be short-lived. There are no, or extremely limited, employment
opportunities within Blackmore and the likelihood of new residents driving a
demand for new services within the village would appear, at best, limited. In
short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school
is at capacity sending additional village children to school elsewhere will further
erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would
undoubtedly be reliant on private motor cars. The sites are at risk of flooding
(surface water at least) and require the release of high-grade agricultural land in
the Green Belt. Redrose Lane is narrow and infrastructure works would be
required to make necessary improvements which would harm the character of
this area but may also result in the loss of historic hedges and important
habitats.
31. There are other sites which are in far more sustainable locations which should be
allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring
for flood risk) with better scores than sites R25 and R26, good examples being in
Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but
not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280,
024A and 130.
32. Furthermore, development in less sustainable locations, such as R25 and R26, before
more sustainable locations, should be avoided.
Green Belt
33. Sites R25 and R26 are in the Green Belt. The Government attaches great importance
to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134
NPPF) which includes safeguarding the countryside from encroachment, preserving
the character of historic towns and assisting in urban regeneration.
34. The NPPF further confirms that, once established, Green Belt boundaries should only
be altered where exceptional circumstances are fully evidenced and justified (para
136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No
other exceptional circumstances are put forward by Brentwood Borough Council.
35. Regardless, the NPPF is clear in that before concluding that exceptional
circumstances exist to justify changing Green Belt boundaries Brentwood Borough
Council should be able to demonstrate that it has examined fully all other reasonable
options for meeting its identified housing need (para 137 NPPF). In this respect the
Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need
for the release of Green Belt land at sites R25 and R26. It should be remembered
that the proposed Green Belt release, per Figure 4.2, only 123 of those homes
are to be provided in the "larger villages" such as Blackmore which accounts for
1.5% of the total housing need (which includes a 20% buffer). This is a very
modest contribution to housing supply which, the Parish Council and BVHA say,
could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used
in preference.
35.3. There are also urban sites that should be used in preference, or
alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development
within its boundaries. The same may be true of other villages within the
Borough. Such "localised" development may reduce or negate the need for sites
R25 and/or R26.
36. In consequence of the above, the Parish Council and BVHA say that Brentwood
Borough Council has not demonstrated that it fully evidenced and justified a need to
alter Green Belt boundaries nor that it has examined fully all other reasonable
alternatives before doing so.
37. Further to the above, the notes to draft policy SP02 confirm that growth is prioritised
"based on brownfield land and land in urban areas first; and only then brownfield
land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of
R25 and R26 runs contrary to this - both being greenfield land in the Green Belt.
Whilst SP02 itself talks of the need to direct development to "highly accessible
locations" - sites R25 and R26 are in a rural area with poor transport links and
limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.
A Settlement Category 3 village?
38. As above the Parish Council and BVHA say that Blackmore should be classed as a
Settlement Category 4 village and not the higher Category 3. They say this because:
38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post
Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in
Doddinghurst (which is ~3 miles away and on roads not suitable for walking);
and
38.3. There are no, or very few, local jobs. Of those of working age nearly all
commute out of the village.
39. Accordingly, some of the key attributes of a Category 3 settlement are, in
Blackmore's case, missing. As a more general point the population of Blackmore is
modest and a considerable margin less than that of Doddinghurst and Kelvedon
Hatch which are also classified as Category 3 settlements.
40. Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and
Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for
housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by
population) than Blackmore - however its proposed housing allocation (total of ~53)
is less, by approximately 25%, than that proposed for Blackmore.
41. This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave
which have no proposed allocation for housing. Indeed, no allocation is proposed for
the other Category 3 settlements of Herongate and Mountnessing.
42. Simply put, the Parish Council and BVHA say that the classification of, and proposed
housing allocation in, Blackmore is incorrect.
Other
43. The Parish Council and BVHA support the strategy within the plan. Indeed, in the
main they recognise and support the policies within the draft plan. However, they
take issue with allocations of sites R25 and R26; not only for the reasons above but
when considered against the policy which Brentwood Borough Council are promoting.
For example, sites R25 and R26 perform poorly against, or conflict with, draft policies
SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the
case that, in applying the NPPF, the Parish Council and BVHA say that development
should be directed elsewhere in preference to sites R25 an R26.
44. The Parish Council and BVHA also take issue with the fact that of the 123 net homes
allocated for "larger villages" 70, or approximately 56% of the total allocation, are
met by these two sites. Thus, a disproportionately large amount of the allocation is
from sites R25 and R26.
45. The above is notwithstanding the Parish Council and BVHA's primary contention that
sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger
villages (i.e. settlement category 3), can and should be removed from the Plan.
46. The evidence of working with adjoining planning authorities is limited with a general
statement that "adjacent planning authorities [have] confirmed that they [are]
unwilling and unable to take any of the Brentwood identified housing need". The
Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the
extent and nature of discussions that have been held with neighbouring authorities.
Summary/Conclusion
47. The Parish Council and BVHA represent the residents of Blackmore village - an
overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.
48. Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances
justifying their removal from the Green Belt. There is no evidence to demonstrate
that all other reasonable alternatives have been explored - those alternatives
including increasing densities or brownfield land and land in more urban/sustainable
locations. The removal of sites R25 and R26 from the Green Belt is contrary to both
local and national planning policies.
49. Development on R25 and R26 has historically been discounted, most recently as
2016. There is no change in local circumstances justifying development on sites R25
and R26 now.
50. Sites R25 and R26 are in an unsustainable location served by a constrained access
(Redrose Lane) and with an identified risk of flooding. The development of R25 and
R26 does not represent sustainable development.
51. The restricted access that Redrose Lane affords is inconsistent with Brentwood
Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted
access. At the Extraordinary Brentwood Council Meeting of 8th November a site
known as Honeypot Lane, included in the Plan since inception, was withdrawn. This
allocation, designed to include social and low-cost housing within 500m of the Town
Centre, was removed due the narrowness of a small section of the road access that
created a 'pinch-point', despite being bordered by open land providing opportunity
for road widening. Unlike the continuously narrow and unpaved Redrose Lane,
Honeypot Lane enjoys a double-width carriageway for all but a short section and is
split between 20mph and 30mphs limits. Redrose Lane, where the national speed
limit applies, is posted with weight restriction warning; whereas Honeypot Lane is
not.
52. There is no evidence of a need for housing in the village of Blackmore. If there is a
need then it has not been quantified by reference to number of type/size of property.
Regardless, the proposed allocation accounts for a disproportionately large amount of
development in "larger villages" within the Borough (i.e. >50% of the proposed
Green Belt release in larger villages comes from Blackmore alone).
53. The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites
R25 and R26 cannot be justified owing to the absence of proportionate evidence and
a failure to assess all reasonable alternatives. The inclusion of these sites is contrary
to national policy, particularly with regards to sustainable development and Green
Belt land policies within the NPPF.
54. The Parish Council and BVHA believe that the change in approach, i.e. in seeking to
allocate R25 and R26 now, is a result of developer pressure rather than a true
assessment of the planning merit (or lack of) of sites R25 and R26 for residential
development.
55. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green
Belt and not allocate them for housing.
HOLMES & HILLS LLP

Remove site R26 from plan

1. Plan unsound: no clear strategy. R25/R26 previously deemed 'unsuitable for development'

2. No prior consultation with affected Blackmore residents

3. Plots R25 & R26 Greenbelt. Unsuitable for development owing to flooding, poor access road, extra strain on services

4. Village services already overloaded (e.g. health, education, parking). Developments will exacerbate

5. Poor transport links will suffer further by additional dwellings

6. No evidence of effect developments in adjacent areas will have on Blackmore services, or of Brentwood's consultation with those Councils

7. No evidence of proper examination of alternative sites (brownfield or in other parishes). LDP proposals appear developer-led

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.

Allocation of the Roman Road Site for Housing and or Specialist accommodation for older people

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.

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

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.

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

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

Site 073 at Mountnessing should be allocated.

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.

Land at Hillcrest Nurseries should be allocated to deliver retirement housing to meet the needs of older people and allow them to stay in their local community in housing suited to their needs, with the further benefit of releasing typically family housing back into the housing market.

1.0 Introduction
1.1 These representations are submitted on behalf of Clearbrook Group PLC to Brentwood Borough Council's (the Council's) Regulation 19 consultation on the Pre-Submission Local Plan (PSLP).
1.2 Clearbrook Group have an interest in land adjacent to Hillcrest Nurseries, located within Herongate and Ingrave. A location plan showing the boundaries of the site is provided at Appendix A. The site has been promoted throughout the plan process for retirement housing.
1.3 As a consultation response to a Regulation 19 iteration of the Local Plan, the focus of this representation is the soundness and legal compliance of the PSLP.
1.4 We raised a number of concerns with the proposed approach being taken by the Local Plan, especially in relation to the provision of suitable and sufficient accommodation to meet the needs of the Borough's aging population, and put forward options to address this in our response to consultation on the Regulation 18 iteration of the Local Plan. However, these points do not appear to have been considered or addressed.
1.5 We do not consider that the PSLP as currently drafted can constitute a sound Local Plan in respect of its approach to specialist accommodation as per the requirement of the National Planning Policy Framework (NPPF), and paragraph 35 in particular. However, we are of the view that defects in the PSLP can be cured, as explained within this representation.
meeting this need, the NPPF (paragraph 50) requires Local Planning Authorities to plan for a mix of housing having regard to the needs of different groups, including older people. It goes on to state that Local Planning Authorities should identify the range of housing required in particular locations.
2.3 The importance of this is further emphasised within the Planning Practice Guidance (PPG), which describes the need to provide housing for older people as critical given the increase in this part of the population.
2.4 Within the Borough itself there is an ageing population, with the ONS projecting those aged over 65 as a percentage of the total population will increase from 20% in 2014 to 26% in 2037. This results in an increase of the population aged over 65 from 15,000 in 2014 to 23,000 by 2037. The ageing population is recognised within the PSLP at paragraph 6.6.
2.5 The NPPF and PPG are clear that Local Planning Authorities should seek to meet the needs of all residents, including older people. They further recognise that older people range from active people approaching retirement to the very frail elderly, having different housing needs.
2.6 Traditionally it has been sought to meet older persons housing needs through the provision of extra care housing falling within the C2 Use Class. As set out within the NPPF and PPG, older people require a range of housing and not just extra care, with providers of different products now active within the housing market to meet this need.
2.7 This is reflected within research by McCarthy & Stone, Retirement Housing: Integral to an ageing Britain (2017), which found that of those aged over 65, approximately 5.7 million people in the UK were potentially looking to downsize. This figure is projected to rise to 11 million by 2036.
Land at Hillcrest Nurseries, Herongate and Ingrave
3
2.8 In relation to the Borough specifically, Clearbrook Group commissioned their own research in respect of the need for retirement housing, as part of a previous planning application1. This confirmed such a need exists within the Borough and that there was a particular need for private sector retirement housing. The planning application was refused and appealed. The appeal2 was dismissed, but the Inspector noted (paragraph 31) that a significant amount of evidence had been provided to demonstrate a need for accommodation of the type proposed; that the need was not disputed by the Council; and concluded that the proposed development would clearly make a contribution to meeting local need.
2.9 The research undertaken by Clearbrook also identified that a high percentage of the population within Ingrave and Herongate are over 65 years of age, demonstrating a clear need within the local area.
2.10 There is a clear need for a range of housing suitable for older people within the Borough, which should be addressed through the Local Plan in accordance with the NPPF and PPG.
2.11 However, we consider that the current approach within the PSLP does not meet the range of housing needs and in this respect is not positively prepared or consistent with national policy.
2.12 The PSLP's current proposed approach is through Policies HP01 and HP04.
2.13 Policy HP01 requires each dwelling to be constructed to meet M4(2) accessible and adaptable standards, with 5% of dwellings to be M4(3) on schemes of 60 or more. Where other Councils have sought to require all dwellings to meet M4(2) there have been multiple objections due to viability implications, with the requirement generally being significantly reduced. We are therefore concerned that the actual amount of housing meeting accessible and adaptable, and wheelchair user standards will be significantly below this level.
2.14 Policy HP01 also sets out the Council will seek the provision of specialist accommodation on strategic residential schemes of 500 dwellings or more, with paragraph 6.13 stating this will ensure there will be sufficient housing to accommodate identified local need as set out in Policy HP04 Specialist Accommodation.
2.15 Given the high level of Green Belt within the Borough, any schemes over the 500 unit threshold will be the strategic allocations only. The PSLP sets out that the strategic allocations of West Horndon Industrial Estate, North of Shenfield and Ford Headquarters and Council Depot should all include the delivery of 60-bed care homes within Use Class C2, being a total of 180 beds of C2 accommodation.
2.16 Further specialist accommodation is also to be provided on Dunton Hills Garden Village, with Policy R01 seeking specialist accommodation in accordance with Policy HP04. No indication of the size or type of this specialist accommodation is given so it is unclear whether this will be another care home or a different form of accommodation.
2.17 With all of the specific provision within the PSLP being on large strategic sites, there will inevitably be a longer lead-in time for development to commence. There is also the challenge that major house builders do not deliver care homes themselves so will need to get an alternative provider involved, likely resulting in further delay to the care homes being delivered.
2.18 There is not only the risk that no care homes will be delivered until the medium/long term part of the plan period but also that through this approach a range of housing for older people will not be provided, contrary to paragraph 50 of the NPPF.
2.19 Policy HP04 states the Council will 'encourage and support proposals which contribute to the delivery of Specialist Accommodation' subject to various criteria being met.
2.20 However, it is not clear how much specialist accommodation, where, or how, this will be delivered. Paragraph 6.25 states the Council will 'work with Essex County Council to secure provision of suitable sites' for independent living schemes, strongly suggesting that the Council themselves are not clear where independent living or specialist housing will be located.
2.21 Furthermore, as part of the PSLP a review of site capacity has been undertaken which identified that development needs in general cannot be met within the existing developed areas, with the Council considering exceptional circumstances exist to amend Green Belt boundaries in accordance with paragraph 136 of the NPPF.
2.22 With Policy HP04 still requiring proposals to comply with Green Belt policies, we question where additional sites can be identified within the Borough on non-Green Belt land. The Council have already identified that development needs cannot be met without amending Green Belt boundaries so it therefore logically follows that to provide additional specialist accommodation, Green Belt boundaries should similarly be reviewed. Under the current PSLP approach, it is difficult to see where a new site within the existing built up area will come forward for specialist accommodation, casting further doubts on the effectiveness of Policy HP04.
2.23 Without amendments, the PSLP is considered unsound in relation to its approach to meeting the accommodation needs of an ageing population. The approach is neither positively prepared, consistent with national policy, nor effective.
2.24 In order to make the approach to the needs of the ageing population sound, we suggest the Council should allocate deliverable sites to meet the diverse needs of older people. Such sites should include those that can come forward in the early part of the plan period to meet immediate needs, and should be distributed across the Borough to meet local needs and allow people to remain within their existing communities if they wish.
3.0 Land at Hillcrest Nurseries, Herongate and Ingrave
3.1 As set out above, the Council should allocate sites specifically to provide housing for older people within the Local Plan. The site promoted by Clearbrook Group is suitable for such development and can help meet local needs within Ingrave, allowing elderly residents to remain within the existing community.
3.2 The site (reference 146 in the Council's plan-making process) is located outside of, but immediately adjacent to the existing settlement boundary of Ingrave in the current Development Plan.
3.3 The site assessed by the Council measures 0.74 ha and forms the northern part of Hillcrest Nurseries, which in total measures approximately 1.6 ha. It is rectangular in shape and was previously a paddock with the main stables sited on the northern edge of the nursery.
3.4 The site contains a number of trees (generally in poor condition, as identified through previous planning application work) and is characterised by scrub. In terms of topography, the site is relatively flat.
3.5 The site is on land which is currently allocated as Green Belt in the now out-of-date Development Plan (the Brentwood Replacement Local Plan (2005), which will be superseded by the new Local Plan currently being prepared. Land to the north, south, and east is outside of the Green Belt and forms part of the designated residential area.
3.6 Ingrave Johnstone Church of England Primary School is located immediately to the north of the site, beyond which are existing residential properties. The existing school access is via a narrow track adjoining the northern boundary of the site, which is understood to date back from the early 20th century, when the village school was considerably smaller.
3.7 To the west of the of the site is the existing village playing field, used by the residents of Herongate, Ingrave and the neighbouring school; to the south-west residential dwellings. To the east is Brentwood Road - the main road running through the village on a north-south axis. On the eastern side of this are, again, residential dwellings. The locality is very much residential in character.
3.8 The site is in a sustainable location, with regular bus routes available on the adjacent A128 Brentwood Road. Numerous services and facilities are also easily accessible from the site, including a convenience store, Marks and Spencer simply food, two public houses/restaurants, grocers, dentist and a church. Such facilities are within easy walking distance of the site.
3.9 The location of the site and its proximity to a range of services and facilities demonstrate its suitability for retirement housing, with elderly people highly likely to walk to such facilities or utilise public transport. We are not aware of any other site in the locality which is as well placed for such development.
3.10 Furthermore, as set out, residents of a retirement development have different travel patterns to those of a traditional market housing development. Elderly residents are significantly less likely to be travelling in peak hours and can provide footfall throughout the day to local services and facilities. The retirement housing proposed will not therefore add to traffic congestion and can help maintain the vitality of the area.
3.11 The Council assessed the site through the Housing and Economic Land Availability Assessment (HELAA) (October 2018), finding it to be suitable, available and achievable and able to deliver housing within the first five years of the plan period. This further highlights the deliverability of the site.
3.12 The site has a planning history which includes an application for 27 retirement flats with communal facilities; separate staff, visitor and coach parking for Ingrave Johnstone Church of England Primary School and an extended school playground (application reference 14/01024/FUL). The application was refused and was subject to an appeal, which was subsequently dismissed.
3.13 The reasons for the dismissal of the appeal can be summarised as follows:
* Inappropriate development in the Green Belt, which would harm openness;
* Harm to the character and appearance of the area;
* Failure to provide sufficient affordable housing.
3.14 In respect of the concerns relating to harm to the character of area and lack of affordable housing, these are functions of the details of the specific proposal that was subject to appeal; as opposed to potential fundamental concerns as to whether the site could be suitable for development.
3.15 In respect of the development being inappropriate development in the Green Belt, it is very much relevant to note that whilst this is of course very much relevant to a Section 78 appeal; in respect of plan-making, and given that the Council acknowledges the new Local Plan must release some Green Belt in order to meet development needs, it is necessary to consider the site's contribution to the purposes of the Green Belt.
3.16 As per the NPPF, the Green Belt serves five purposes:
* 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.
3.17 A revised Green Belt assessment has been published as part of the consultation, which assesses the site under reference 146. Overall this found the site to have a moderate/high contribution towards the Green Belt purposes.
3.18 This is in part due to the consideration that development would reinforce and lead to coalescence of Ingrave and Herongate. It should be recognised that there is existing residential and retail development along the eastern side of Brentwood Road which runs south, past the southern boundary of the site being promoted for allocation and closer to Herongate than the proposed allocation. A gap between Ingrave and Herongate would be maintained by the village playing field, the southern part of the nursery site, and Ingrave Common (cricket pitch). It is not considered that the development of the site proposed would materially alter the separation between the two settlements insofar as it currently exists.
3.19 Looking at this specific site's contribution to the purposes of the Green Belt, its relationship with the existing residential envelope is considered particularly relevant. To the north is existing residential development and a school. To the east, south and south-west is also existing residential development. As such, the site is surrounded by existing residential development. The site does not represent open countryside, and as such its development would not entail encroachment into the countryside. Furthermore, given the site's relationship with existing development, it development could not constitute unrestricted sprawl. The site is very much contained by surrounding features.
3.20 In terms of impact on historic setting of a settlement, the scale of the proposed development is considered to result in nominal impact in this sense, as it would appear a proportionate and unobtrusive addition to the existing settlement. Herongate Conservation Area is the nearest Conservation Area, but is located some distance to the south of the site and is very much functionally separate from it. This is confirmed in the Green Belt assessment, which sets out the site has limited relationship with a Historic Town (the lowest score possible).
3.21 Overall we consider that the scoring given to the site within the Green Belt assessment is overly high, with the site being in an area characterised by residential development and not representing countryside.
3.22 The site has further been considered by the Council within the Sustainability Appraisal. We have some concerns with the scores given to the site, with the site assessed as performing poorly in relation to Conservation Areas. However, the site is functionally separated from the Herongate Conservation Area and development of the site can provide landscaping benefits compared to existing poor quality trees.
3.23 Furthermore, the site is assessed as performing well in relation to criteria 8 (Primary school) by virtue of it being located less than 800m from the nearest primary school. However, this overlooks the site's potential to contribute to enhancements to the school, as described elsewhere in this representation. Essex County Council's Commissioning School Places in Essex 2017-2022 projects the School will be close to capacity by 2021/22, even before additional growth is accounted for, and the potential for land to be made available (which could include improvements to access) should be considered a significant positive.
3.24 The SA report considers all sites as providing general housing and it does not appear that the Council have considered the distinct benefit of the provision of housing for older people at any stage of the site assessment and selection process. The Council should have considered the specific use of the site alongside the outcomes of the HELAA, Green Belt Assessment and SA, with the provision of housing for older people and other benefits outweighing any harm to the Green Belt and justifying the release of the site from the Green Belt.
3.25 As identified through the previous application and appeal, the site can provide apartments for the elderly with communal facilities. Other benefits could also be provided that are unique to the site, including staff, visitor and coach parking for the nearby Ingrave Johnstone Church of England Primary School and an extended school playground.
4.0 Conclusion
4.1 Whilst the PSLP recognises the growing ageing population within the Borough, it fails to provide suitable policies to facilitate the delivery of a range of suitable housing to meet this need.
4.2 The current approach within the PSLP is to provide a total of 180-beds within care homes on strategic sites plus an unquantified amount of specialist accommodation within Dunton Hills Garden Village. With long lead-in times for strategic sites, this will not provide housing for older people within the short term and does not provide a range of housing to meet differing needs.
4.3 The other approach within the PSLP is through Policy HP04, which supports the provision of specialist accommodation but does not specifically set out sites to provide such housing. Furthermore, with the Council having already identified suitable sites for housing outside the Green Belt within the Local Plan and subsequently confirmed that land needs to be removed from the Green Belt to meet general housing need, we question where additional sites will be identified that are not within the Green Belt. With sites still needing to comply with Green Belt policies, we consider it very unlikely that sites will come forward that will not conflict with Green Belt policies.
4.4 For the reasons set out it is considered that Policy HP04 is not currently effective or consistent with national policy as it will not allow the housing needs of older people to be met over the plan period. Policy HP04 and the approach of the Local Plan to meeting the housing needs of older people is therefore unsound under paragraph 35 of the NPPF.
4.5 Land at Hillcrest Nurseries, as promoted by Clearbrook Group, can deliver retirement housing to meet the needs of older people and allow them to stay in their local community in housing suited to their needs, with the further benefit of releasing typically family housing back into the housing market.
4.6 Development of the site is suitable, available and achievable, as confirmed through the Council's HELAA. It could also deliver other benefits including the provision of a car park and additional playground for the nearby school.
4.7 Overall we consider the allocation of the site and its release from the Green Belt is justified and would assist the soundness of Policy HP04 and the Local Plan in its strategy for meeting the range of housing needs for older people.
4.8 As we have raised concerns with the soundness of parts of the PSLP and suggested modifications, we welcome the opportunity to explore these further with the Council and Inspector at the Examination Hearing sessions.

The allocation of and north of Wyatts Green Lane could furthermore provide housing to enhance the vitality of the rural area.

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

Site of less importance to the Green Belt, such as Salmonds Grove should be allocated.

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

The Local Plan should allocate Land at 41 Shenfield Road for 24 dwellings.

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.

To ensure the Local Plan is sound, further suitable sites within Ingatestone should be allocated to ensure the sustainable growth, including Site 078.

This representation on the Brentwood Borough Proposed Submission Local Plan
(February 2019) (PSLP) is submitted by Strutt & Parker on behalf of Barnoaks
Management Ltd. The representation is made in relation to Land south of the B1002,
Ingatestone. The site is referenced as 078 in the Council's plan making process. A location plan showing the site is provided at Appendix A of this representation. The site has previously been submitted through the Council's Call for Sites (2011) and
the Strategic Housing Land Availability Assessment (SHLAA) (Ref: GO20). In the
SHLAA, the site was defined as a 'greenfield parcel with potential'. More recently, the site was submitted through the Housing and Economic Land Availability Assessment (HELAA) (2018) (Ref: 078). The site was defined in the HELAA as a suitable, achievable and available site for residential development, which could come forward within 1 - 5 years. Representations were also submitted to Brentwood Borough Council through the Regulation 18 Consultation (2018). The site measures at approximately 1.8ha and could support the delivery of up to 54 dwellings. The site is located adjacent to the eastern edge of the settlement boundary of Ingatestone, on land, which is currently allocated as Green Belt. Currently, the site is not proposed to be allocated for residential development. The
rejection of the site for allocation is considered unjustified. The allocation of land south of the B1002, Ingatestone, for residential development would represent a sustainable and deliverable proposal to help meet housing needs over the coming plan period. The proposed plan period runs until 2033. Assuming - optimistically - 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. 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). 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). 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. 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. 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). 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. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The 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'. 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. 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. 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 the PSLP that even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. The Council is required to demonstrate a five-year housing land supply at any point in the plan period. 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. 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. 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. 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. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five year requirement of 2,712 dwellings. 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. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. 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. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings). 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. Furthermore, and in respect of the projected supply, we are concerned to note that
Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan. 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. 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 before development has even begun. 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. 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. The strategic sites are expected to deliver 1555 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. 078 to provide for more homes which have a far greater prospect for short term delivery, to ensure the plan is Sound. Ingatestone is defined as a Category 2 Settlement. The Borough defines Category 2
settlements as larger villages in a rural setting, with high levels of accessibility and public transport provision, including rail services. These settlements provide a range of services and facilities to the immediate residential areas and nearby settlements. The PSLP states that appropriate urban extension and brownfield development
opportunities will be encouraged to meet local needs. In 2011, Ingatestone had a population of 4,812 (Census; 2011). It is the Borough's largest village, with a modest level of facilities, including a secondary school. Furthermore, Ingatestone Railway Station is located within the village, and provides frequent railway services to London Liverpool Street, Stratford (London), Chelmsford, Colchester and other surrounding settlements. The PSLP confirms that although Ingatestone has relatively good facilities, a modest level of development is envisaged, due to infrastructure constraints and a lack of suitable sites. As such, only two sites have been allocated for residential development in the PSLP -R21 and R22. This results in a total of 218 dwellings for Ingatestone over the plan period. Site 078 has previously been defined in the HELAA (2018) as suitable, available and achievable site for residential development. The PSLP in this case is flawed, as it doesn't appropriately consider Site 078 as a suitable site for residential development. It is considered that the PSLP fails to support the sustainable growth of Ingatestone. The
failure to thoroughly consider Site 078 for residential development is unjustified. To ensure the Local Plan is sound, further suitable sites within Ingatestone should be
allocated to ensure the sustainable growth of Ingatestone. The site measures at approximately 1.8ha and could support the development of up to 54 dwellings. The site is located adjacent to the eastern edge of the settlement boundary, on land,
which is currently allocated as Green Belt. The site is bounded by existing residential development to the north and south and the B1002 to the west. To the eastern boundary of the site are agricultural fields. A considerable amount of technical work has been undertaken in respect of land south of the B1002 and has previously been submitted to the Council through previous stages of the plan-making process. The technical work undertaken demonstrates that the site is sustainable, suitable, available and achievable and its development would help meet the Borough's housing need. Work undertaken, and previously provided is included in this representation for completeness: * Proposed Site Plan prepared by Grafik (Appendix B); * Landscape and Visual Issues Scoping Report prepared by Nigel Cowlin (Appendix C); * Landscape Advisory Plan prepared by Nigel Cowlin (Appendix D); * Access Appraisal by Ardent Engineers (Appendix E). In previous representations submitted to the Council, we have commented specifically on the proposals for layout and landscaping, providing that the site would be allocated for residential development by the Council. A Feasibility Layout prepared by Graffik Architecture has previously been submitted to the Council and is included within this representation for completeness. The feasibility study demonstrates how 54 dwellings could be accommodated on the site. The layout illustrates how the site could provide infill development to the already existing settlement of Ingatestone, without adversely harming the landscape character of the area or the character of Ingatestone itself. The Feasibility Layout also shows the potential proposals for landscaping on site. These proposals have been formed through careful consideration of the existing landscape character of Ingatestone and in line with the Landscape and Visual Issues Scoping Report and Landscape Advisory Plan which has been prepared by Nigel Cowlin. The report and plan also accompany this representation. As set out above, a Landscape and Visual Issues Scoping Report and Landscaping Advisory Plan has been prepared by Nigel Cowlin and accompanies this representation. It is proposed that there is to be retained and enhanced landscaping on site, specifically to the eastern and southern boundaries. This landscaping proposal takes into account the Grade II Listed Building - Rays - which is located beyond the eastern boundary of the site. By proposing dense planting at this boundary, it will ensure that the development proposal has no adverse effect on the nearby listed building. The Feasibility Layout also illustrates that planting will be retained at the western boundary of the site at the High Street, where access to the site is proposed. Furthermore, it is illustrated that the existing oak tree at the western part of the site will be retained to provide a substantial area of open space on the site. The Scoping Report suggests that these simple design controls and landscape mitigation measures, such as the protection of existing field boundary hedgerows, along with retaining an open space around the mature Oak Tree at the front of the site, would help to ensure that the proposed development would be as successful as possible in landscape and visual terms. The Scoping Report found that the visual influence of the site to surrounding locations was found to be limited due to the built up nature of the surrounding area, for example the ribbon development to the north and the settlement edge of Ingatestone to the south. The report states that development of the site should be considered as a logical area for infill development along the B1002. The Environmental Assessment of Plans and Programmes Regulations (2004) requires SA/SEAs to inter alia set out the reasons for the selection of preferred alternatives, and the rejections of others, be made set out. In addition, the Planning Practice Guidance4 makes clear that the strategic
environmental assessment should outline the reasons the alternatives were selected,
the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. Sustainability Appraisal of the PSLP has been published: the Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA). Paragraph 5.5.31 of the SA confirms that Site 078 is listed as 1 of 5 omission sites in the HELAA as it is "deliverable or developable". The SA confirms that the two sites with the greatest potential for allocation are the adjacent "Parklands" Sites (Ref: 078 and Ref: 243), at the northern boundary of the village. The SA states that the accompanying Green Belt Review found that both sites contribute to the purposes of the Green Belt to a 'moderate' extent, however neither site is fully contained in the landscape. The SA concludes that the option of adding one or more omission sites was determined as "unreasonable", for the purposes of establishing reasonable spatial alternatives. No details are provided to explain in what way Site 078 is considered not to be fully contained in the landscape. Furthermore, as per Section 3 of this representation, the accompanying Landscape and Visual Issues Scoping Report confirms that further planting can be provided on site at all boundaries, thus ensuring it is a contained site. The proposed planting would be effective in appropriately screening the proposed development and ensuring the village character of Ingatestone is retained. In short, the SA does not provide a justified reason for the rejection of the site. Turning to the specifics of the SA assessment of the site, these are set out in Table C of the SA. This provides a 'traffic light' assessment of sites' sustainability. Green indicates sites perform well; amber - poorly; red- particularly poorly; against specific criteria. Our first point in relation to the approach taken is that it is very simplistic - the assessment of site appears to be based purely on physical distance to various features / facilities / designations. For example, in relation to criteria 10 (Conservation Area), our site is considered to score 'poorly'. Part of Ingatestone High Street is defined as a Conservation Area, however site 078 is not within this designation and is located at least 400m from the defined Conservation Area. As such, it is considered that the proposed development of the site would not unacceptably impact the Conservation Area. Furthermore, in relation to criteria 1 (Air Quality Management Area (AQMA)), the site is considered to score 'poorly'. The site is located approximately 1 mile from AQMA BRW6 at the A12/Fryerning Lane. It is considered that the AQMA will not be adversely impacted by the site, given the distance between the two. In relation to criteria 8 (Primary School), the site is considered to score 'poorly'. The site is located 0.5 miles from both an infant and junior school. It is considered that the primary school provisions within Ingatestone are within walking distance to the site and the site should not be scored as 'poorly' in relation to this criterion. As per the reasons above, we therefore consider the SA's assessment to be flawed. A Green Belt Study and Assessment has been undertaken by Crestwood Environmental
Ltd as part of the Regulation 19 Consultation. The Assessment looks to assess specific green belt parcels in relation to the 4 purposes of the Green Belt. These are: Purpose 1 - To check the unrestricted sprawl of large built-up areas; Purpose 2 - To prevent neighbouring towns merging in to one another; Purpose 3 - To assist in safeguarding the countryside from encroachment; Purpose 4 - To preserve the setting and special character of historic towns. Following this assessment, the parcel is given an overall assessment rating. The ratings are; Low; Low-Moderate; Moderate; Moderate - High; High. Site 078 is within Parcel 9A of the Green Belt Assessment. Parcel 9a includes land to the northeast of Ingatestone. The parcel size is 41.94ha. Purpose 1: Parcel 9a is defined by the Council as 'Partly Contained', as it abuts a large built up area. The assessment states that the 'Partly Contained' sites have weak/degraded/unclear boundaries. This is an overall assessment of the parcel and not specifically of Site 078. Site 078 has clear natural boundaries at the east and to the south. Furthermore, as detailed at Section 3, further planting is proposed at the site in order to contain the proposed development. Purpose 2: Parcel 9a has been assessed as an 'Important Countryside Gap'. The Assessment
states that the parcel forms either a large proportion of countryside gaps between towns or the development of the site would result in the physical narrowing of the gap and potential visual coalescence. As per the accompanying Landscape and Visual Issues Scoping Report, it is considered that the site would result in a coherent infill development between two existing areas of developed land. The Scoping Report also confirms that the proposed development of the site wold not result in the coalescence of Margaretting and Ingatestone. Purpose 3: Parcel 9a has been assessed as 'Functional Countryside' (FC). This again, is an overall assessment of the parcel and not specifically of Site 078. As such, we do not agree that Site 078 can be defined as Functional Countryside. The site is between existing development and can therefore be considered as an infill site. Purpose 4: The assessment states that Parcel 9A has a 'limited relationship with Historic Town'. We agree with this assessment. Overall Brentwood Borough Council have assessed Parcel 9a, as having a 'moderate' contribution to the 4 purposes of Green Belt. The above review of Parcel 9a recognises that this assessment is not necessarily reflective of the qualities of every site within the parcel. In respect of this, we wish to highlight the findings of the Inspector in the Welwyn Hatfield Local Plan Examination, which we consider helpful in the consideration of the PSLP. Following the Stage 1 and 2 hearing sessions at Welwyn Hatfield, the Inspector provided a note to the Council in December 2017 on its approach to review of the Green Belt (EX39 of the Welywn Hatfield Local Plan Examination). Within this note, the Inspector stated: "The Council has suggested that it is unable to meet its housing need because of
Green Belt restrictions among other concerns. In my concluding remarks ... I pointed
out that I did not consider the development strategy put forward in the plan to be sound, in part because there was insufficient justification for the failure to identify sufficient developable sites within the Green Belt. That is largely because the phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas." "Additionally, the phase 2 Green Belt Review, which did look at a finer grain of sites,
does not appear to have examined all of the potential development sites adjacent to
the urban areas..." "The actual development strategy finally arrived at is a matter for the Council... However, if that strategy fails to meet the FOAHN and assuming that all realistic development opportunities outside of the Green Belt have been put forward in the plan, then it is effectively saying that there are no exceptional circumstances justifying a further release of additional land from the Green Belt and that presumably means for as long as current national green belt policy and its interpretation prevails. That may be the case but unless all of the Green Belt has been forensically analysed in some detail then it is difficult to prove." Having regard to all of the above, key issues to consider include: * Whether all potential sites' impact on the Green Belt has been assessed; * Whether such assessment was undertaken at a sufficiently fine grain to properly consider individual sites' impact on the Green Belt.In respect of the PSLP, it is clear that not all potential development sites were subject to a sufficiently detailed analysis which could enable BBC to justifiably conclude it has identified a reasonable strategy to meet its housing needs, particularly where the plan is not meeting those needs in full. At the very least, there was one site that was not properly assessed: Land to the South of the B1002, Ingatestone. The Council's own evidence base states that Site 078 is suitable, available and achievable for residential development. Development of the site is supported by technical evidence that confirms its suitability, including in relation to the lack of harm to the landscape and Green Belt. The reasons given for the rejection of the Site are based on erroneous conclusions in the evidence base and should be re-examined. The rejection of Site 078 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 in Ingatestone. The allocation of Site 078 for development will assist in curing defects in respect of the
Local Plan, enabling it to be a sound plan.

The written text of the Plan could provide for specialist housing for School purposes/key worker accommodation. Publish Policies and Proposals Map and release land around Mill Hill House and Millman Lodge from the Green Belt.

Chapter 7 Community Infrastructure Policy PC15:Education Facilities
It is recommended that there is minor changes to the wording within the Policy. Under Policy B delete the word demonstrable before need. It is also considered unnecessary to have the additional wording that relates to the ECC's Developer's Guide to Infrastructure Contributions. If the proposals are clearly associated with educations requirements which will be a matter of fact and degree then there is no need to turn to other schedules. Furthermore the link to the Essex County Council document does not provide a clear schedule of criteria to which the decision maker or applicant can turn. It is confusing and should be deleted. We would recommend that the policy should now read "Where there is a need for new educational facilities, planning permission will be granted for appropriate and well-designed proposals."
As explanation for such minor change it will generally be the education provider whether independent school, religious order or County Education Authority who will know what is needed to improve their overall education facilities either through direct education floorspace or ancillary or associated floorspace.
Comment is also made on Policy PC16: Buildings for Institution Purposes In Policy A delete demonstrable before need. The Policy now reading "A. Where there is a need for the facilities.........." Comment is also made in relation to the general text of paragraph 7.105. This is an unnecessary inclusion within the Plan. There may from time to time be need for minor loss of existing residential accommodation to facilitate a bigger objective of educational community facilities. An example given is the recent redevelopment of the Brentwood Prep School Site where the demands for new form of entry and enlarged educational facilities necessitated the loss of an existing caretakers house. The Local Plan will not be effective with respect to the policy issue raised as it creates an unnecessary hurdle by reference to using the word demonstrable and is confusing and not necessary to relate to another document such as the Essex County Council Developers Guide to Infrastructure Contributions. I have set out the modification to PC15 Education Facilities above but for ease of reference repeat here:
B. "Where there is a need for new educational facilities, planning permission will be granted for appropriate and well-designed proposals."

The provision of educational facilities is an important part of the Local Plan and subject to any response of the Local Authority the point is best made orally.

Should any part of the Brentwood Community Hospital site be declared as surplus to the operational healthcare requirement of the NHS in the future, then the site should be considered suitable and available for alternative use, and considered deliverable within the period 5-10 years. These representations identify the sites potential for future development, in accordance with the realignment of the Green Belt so that this significant area of development land is no longer included. It is evident, that the site does not make a positive contribution towards the purposes of the Green Belt set out in the NPPF. Accordingly, redevelopment of the site could provide a key contribution to Brentwood's housing need, which the Council have failed to justify, given the reliance on key strategic sites, and the lack of acknowledgement for unmet need arising from neighbouring authorities (Basildon and Havering). These representations therefore promote and identify parts of the Brentwood Community Hospital site as a suitable site to contribute towards these requirements. This site presents an excellent opportunity for a high quality residential redevelopment on previously developed Green Belt land. This could be achieved without compromising the character of the area as the development can act as an infill site to the existing residential development surrounding it, and without the need for significant infrastructure. Furthermore, the site is also available to accommodate further health related development should the CCG seek to expand their services in this location, including the possible expansion of the hospital to provide more comprehensive services for the community. However, the site's Green Belt designation would make it difficult for any planning application proposing additional built form to provide further healthcare services to be considered acceptable. The subject site is considered available, suitable and deliverable within the 5-10 year period of the plan.

These representations seek to comment specifically on Housing Requirements, Housing Allocations, and relevant evidence base documents identified and referred to in the draft Local Plan. In addition to this, these representations will also comment on specific parts of the Spatial Strategy and Strategic Objectives provided in the emerging plan. Housing Requirements This Consultation document outlines that the Council commit to delivering 7,752 new net additional dwellings over the Plan period 2016-2033 using a stepped trajectory that would see 310 dwellings per annum until 2022/2023, following by 584 dwellings per annum from 2023/24-2033. Overall, this represents an average of 456 dwellings per annum over the Plan period. The minimum housing need for Brentwood based on the standardised methodology is 452 dwellings per annum. In addition to the Council's minimum requirement, there are 3,508 dwellings that are unmet in Basildon and 5,650 dwellings that are unmet in Havering. Basildon and Havering both adjoin Brentwood, therefore the Council should consider contributing to their housing needs through outlining and planning for a higher housing target. The Council should also consider the arrival of Crossrail, which is set to unlock further demand for housing in the area. The Council's approach to a stepped trajectory is also not justified, and should look to deliver housing in the short term. Housing Allocations
The Council's Local Plan Consultation document identifies a number of residential allocations on Green Belt land located at the edge of the Brentwood Urban Area. Policy NE13 (Site Allocations in the Green Belt) states that sites allocated within the Green Belt will be expected to provide "significant community benefits", and will be de-allocated from the Green Belt to allow development to take place. This identifies that the release of Green Belt land in these areas is being pursued as part of their Spatial Strategy. Green Belt land is also proposed for release in a number of other settlements in the Borough. Of the Council's allocations, there are four Strategic Housing Allocations. The largest allocation is Dunton Hills Garden Village Strategic Allocation (Policy R01), which is allocated for a residential-led development to deliver around 2,700 homes, with a potential overall capacity of 4,000 beyond 2033. This allocation was also located within the Green Belt. The variable housing target outlined by the Council is substantially reliant on this Garden Village commencing delivery in 2023/24 (within the first five years of the Plan), and delivering at a rate of 100 homes per annum from thereon, reaching 300 homes per annum from 2026. Housing Allocation- Land off Crescent Drive: The land adjoining Brentwood Community Hospital to the east benefits from a draft allocation in the Local Plan consultation document. Although this site has similar characteristics to the Brentwood Community Hospital site, including being a previous NHS site, it is not designated as Green Belt. The allocation on site 186, Land at Crescent Drive, Shenfield, identifies that the 1.54ha site can provide for around 55 dwellings, anticipated to be delivered between 2021/2022 and 2023/2024. It will provide a mix of size and type of homes including affordable in accordance with the Council's policy requirements. This outlines the development potential of the area. Loss of Community Use Policy PC14 (Protecting and Enhancing Community Assets) states that existing community assets will be protected from inappropriate changes of use or redevelopment. Policy PC14 (e), states that development proposals that would result in a loss of community assets will be discouraged unless it can be demonstrated the following; i. There are realistic proposals for re-provision that continue to serve the needs of the neighbourhood and wider community; or ii. the loss is part of a wider public service transformation plan which requires investment in modern, fit for purpose infrastructure and facilities to meet future population needs or to sustain and improve services. To confirm, a property can only be released for disposal or alternative use by NHSPS once Commissioners have confirmed that it is no longer required for the delivery of NHS services. Furthermore, NHSPS estate code requires that any property to be disposed of is first listed on "e-PIMS", the central database of Government Central Civil Estate properties and land, which allows other public sector bodies to consider their use for it. The ability of the NHS to continually review the healthcare estate, optimise the use of land, and deliver health services from modern and fit for purpose facilities is crucial. Given that there is very careful oversight from NHS England and CCGs to ensure sufficient services are re-provided, and that the estate is fit-for-purpose, additional protection through planning policy should be unnecessary in relation to public healthcare facilities. Therefore, if all or part of the site is declared as surplus to the operational healthcare requirements of the NHS by health commissioners, this should be considered sufficient to satisfy Policy PC14 and any subsequent replacement policy. Furthermore, any marketing period (in addition to service re-provision) should not be required. Evidence Base Documents - Since the last consultation on the Brentwood Local Plan, the Council have published a suite of evidence base documents to inform the Regulation 19 Local Plan and to address the Council's main concerns. Evidence base documents of relevance consist of the following; * Green Belt Study (November 2018); and * Infrastructure Delivery Plan. Green Belt Study (2018) - The Council's Green Belt study (February 2018), identifies that around 89% of the Borough is designated as Green Belt; it then splits all the Green Belt in the district into various parcels which are assessed against a number of criteria including the NPPF's five Green Belt purposes. The land at Brentwood Community Hospital is entirely located within Parcel 55: East of Middleton Hall Lane. This Parcel spans over 26.1ha of land which is identified as being wholly / largely contained by large built up areas. In summary, the entire parcel is considered to be well-contained, but is located within a Critical
Countryside Gap (CCG), operates as Functional Countryside (FC), and has a moderate relationship with a Historic Town. The Parcel is therefore identified as performing a moderate - high contribution towards the Green Belt's purposes. The Green Belt Stage 2 Review (February 2018) sub-divided a number of sites assessed in Part 1 for further detailed assessment. Parcel 55 had not been sub-divided in Part 2 for further assessment and thus there was no further assessment of the site against the Green Belt's purposes in this round of assessment. The Council's most recent Green Belt Study (November 2018), assesses the site under Site Assessment 186. To note, only the car parks to the western extent of the site fall within the Green Belt, therefore as such, the assessment only related to 25% of the site. The site was assessed as follows; * The car parks are strongly associated with surrounding buildings, albeit protruding in to the Green Belt. The site is assessed as Partly Contained (PC); * The site is small scale and contained within the town (e.g. infilling). The site is bounded by mature dense woodland to the west. Whilst development would mass housing on the site, there would be no appreciable reduction in the gap. The site is assessed as Separation Retained (SR); * The area of the site located within the Green Belt is car parks and woodland areas so therefore is assessed as being Mixed Functions within Countryside (MFC); * The site is assessed as having a limited relationship with the historic town (LRHT). Overall, the site was assessed as having low-moderate contribution to the Green Belt. The site was considered as a "partly developed site" due to the hardstanding car parks and was associated with the settlement boundary to the east. Infrastructure Delivery Plan - The Council's Infrastructure Delivery Plan (IDP) provides a schedule of infrastructure requirements to help support new development growth planned within the Brentwood Local Plan. Paragraph 10.6 outlines that Brentwood has a slightly higher proportion of over 65s compared to Essex county as a whole, although a 17% increase is expected between 2015 and 2025 equating to 2,600 more people. Given the foregoing, there is a clear need for a higher proportion of homes which are capable of accommodating people's changing needs. Paragraph 10.19 of the IDP also states that hospitals will need to be redesigned to treat the patients of the future. The site could be suitable for housing for older people as it is located in a sustainable location close to services, facilities and to transport links. The IDP also highlights that there is an ongoing programme to improve the utilisation of Brentwood Community Hospital, to reduce the void costs associated with the building and to make better use of the opportunity for providing a range of health and care services. Strategic Objectives - This sub-section provides a review of the Spatial Strategy, and the Strategic Objectives and how they are of relevance to the subject site. Chapter 2 (Borough of Villages), Figure 2.3 sets out the borough's settlement hierarchy categories, to identify their role for delivering sustainable growth. Figure 2.3 outlines Brentwood as a "large town", alongside Shenfield with 4 urban neighbourhoods, 2 large villages, 1 garden village, 6 rural villages, and 7 rural villages in sparse settings. Paragraph 2.11 of the Consultation document outlines that Brentwood is the borough's largest settlement and offers the most scope to develop in, in accordance with sustainable development objectives as set out in the NPPF. Chapter 3 of the consultation document outlines the Borough's Spatial Strategy and Strategic Objectives. The Council have highlighted four strategic objectives and how the policies align to help deliver these policies. These are the following; * SO1: Manage Growth Sustainably; * SO2: Deliver a Healthy and Resilient Built Environment; * SO3: Deliver Sustainable Communities with Diverse Economic & Social-cultural Opportunities for All; and * SO4: Deliver Beautiful, Biodiverse, Clean and a Functional Natural Environment. The subsequent chapters outline the policies that sit within each strategic objective. These representations specifically comment on both: Managing Sustainable Growth (SO1) and Sustainable Communities (SO3). SO1: Managing Sustainable Growth - The Council aim to direct development to the most sustainable locations, ensuring that the characteristics and patterns of the settlements are protected and enhanced. The redevelopment of the site would aid the Council in delivering most of these objectives and policies. Although currently designated as Green Belt, the brownfield nature of the site and its location within the existing built up area of Brentwood means it can significantly aid in intensification. The site is also easily accessible by existing public transport modes as outlined in the 'site context' section of these representations. The site is highly sustainable and helps contribute towards delivering the Strategic Objectives including having no unacceptable effect on visual amenity; having no unacceptable impact on health; and causes no unacceptable effects on adjoining sites. The intensification of this site would also increase the critical mass of customers/users of existing services and facilities. This can help to ensure the viability of existing services and amenities in the local area. The site could also be optimised for retention in its current use with the provision of additional built form to provide additional health services or an extension to the current facilities. SO3: Sustainable Communities - The Council aim to highlight opportunities which flexibly respond to the changing economic climate and employment sector trends making citizens feel economically empowered to enjoy and benefit from the necessary community/social infrastructure that sustains inclusive, informed, vibrant, active and cohesive communities. The potential for the provision of residential development at the site would help the Council to meet their identified and growing need for housing over the plan period. The sustainable location of the site in relation to the existing built form and settlement of Brentwood means that should the site ever become surplus to the requirements of the NHS, it would be a great location for residential development. The site is adjoined to the settlement, so therefore can help contribute towards creating a cohesive community. Furthermore, as outlined above, the site is also capable of accommodating further healthcare-related development, including the possible expansion of the hospital to provide better and more comprehensive services for the local community. The site is located in a sustainable location and is easily accessible by public transport, cycling and walking and could therefore make a good location for the expansion of the existing healthcare facilities should this be required by the CCG in the near future. Chapter 3 also outlines the Council's spatial development principles, stating that development proposals in the borough will follow the following principles; 1. Urban Areas- Prioritise brownfield sites, making efficient use of land; 2. Brownfield Green Belt Land- Use of previously developed land in the Green Belt; 3. Strategic Sites- Use opportunities created by larger housing development; 4. Urban Extensions- deliver new homes in areas close to existing transport and local facilities; and 5. Windfall- an allowance for small scale development that will come forward in the future. The site is Brownfield Green Belt land (Tier 2) so therefore should be favoured for development over strategic sites and urban extensions. The Role and Extent of the Green Belt Policy NE9: Green Belt sets out that the Green Belt will continue to be preserved from inappropriate development so that "it continues to maintain its openness and serve its key functions". The redevelopment of this site would only seek for the removal of a small element of existing Green Belt land which is currently a mix of hardstanding car parking and woodland. This removal would enable efficient and maximum redevelopment of a brownfield site, without contradicting the purposes of the Green Belt. The NPPF states that Green Belt boundaries should only be amended in "exceptional circumstances". The Housing White Paper seeks to clarify this further and states that land which has been previously developed should be considered first. Accordingly, it is sites such as Brentwood Community Hospital which should be removed from the Green Belt. This is further outlined below, which highlights the sites suitability. a. Site Suitability The site is located adjoining the existing settlement and residential area of Shenfield, and a proportion of the site within the Green Belt is currently an existing hardstanding forming a car parking area. The site is located in close proximity to public transport connections which provides links to a variety of everyday services and amenities. As previously identified, the site is currently partially located (25% of the site) within the Green Belt. However, due to the existing built form within and surrounding the site, and as evidenced in the Green Belt Study, the site provides little or no contribution towards the purposes of the Green Belt. The Council undertook a Green Belt Study (November, 2018) which assessed various parcels of Green Belt land within the district. The site fell within Site Assessment 186, which concluded as having low-moderate contribution to the Green Belt. Although considered as having a low-moderate contribution to the Green Belt, a Green Belt assessment is provided below to outline the development potential of the land at Brentwood Community Hospital. The assessment is based on the Green Belt purposes identified in the NPPF. This assessment is to enable the Council to determine the importance of the site in Green Belt terms, and to demonstrate that the site does not meet the five purposes of the Green Belt, so therefore should be removed. 1. to check the unrestricted sprawl of large built-up areas - The site is bounded on three sides by the existing built form of Brentwood. The surrounding built form includes residential dwellings to the north and west, and a draft residential allocation to the east. - The built up area would not spread further than the site's boundary due to the presence of a significant area of woodland adjacent. 2. to prevent neighbouring towns merging into one another - The site falls between the settlements of Shenfield and Brentwood. Although the site falls between these two settlements, the built form of Shenfield and Brentwood already links through the existing built form on Shenfield Road and it is not this site that forms any gap rather the playing fields adjacent. - The site's built form also limits its purposes in restricting the two settlements from merging as it is clear that it is an existing built up area. 3. to assist in safeguarding the countryside from encroachment - The site is bounded to the north, east, and west by the existing built form of Brentwood. - The site is bounded to the south by existing woodland. - Due to the site not being located in the countryside, its contribution toward this aim is limited. 4. to preserve the setting and special character of historic towns - The site is not located within a historic town.5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The site is located within an existing settlement and promotes the intensification of an existing community facility which already has its own facilities, amenities, and day-to-day services, or, the site could equally be redeveloped for the provision of residential dwellings should the land become surplus to the NHS's requirements. b. Sustainability The golden thread running through the NPPF is a presumption in favour of sustainable development. This means that developments which accord with the Local Plan should be approved without delay. The three pillars of sustainability within the NPPF are identified as Social, Environmental, and Economic; the definitions of these terms and the ways the proposals at Brentwood Community Hospital conform to these pillars are identified below. Social The NPPF defines socially sustainable development as those which contribute toward supporting a strong, vibrant and healthy community by providing the supply of housing required to meet the needs of present and future generations, through a high quality built environment with accessible services and support of health, social and cultural wellbeing. The redevelopment of Brentwood Community Hospital would accord with the social pillar of sustainable development through the provision of an increased number of residential dwellings on a sustainably located site in order to help meet the Council's identified and growing need for housing. Should the Council fail to meet their identified housing target, there could be serious social instability caused including overcrowding of existing housing stock and undersupply of housing. In addition to this, the site could represent the opportunity for the delivery of affordable housing towards the Council's identified need, representing a further opportunity to deliver a socially sustainable development. Environmental The NPPF defines environmentally sustainable development as development which contributes to protecting and enhancing the natural, built and historic environment through improving biodiversity, using natural resources prudently, and minimising waste and pollution. A scheme at Brentwood Community Hospital could provide sustainably located residential dwellings within walking distance of existing services and amenities, reducing the need for future residents to travel long distances and reducing pollution and the use of finite resources. Alternatively, should the CCG seek to expand their existing facilities on site, the intensification of the existing healthcare services could help to ensure the healthcare facilities continue to be provided in a sustainable location. Economic The NPPF defines economically sustainable development as development which contributes toward building a strong, responsive, and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation. A residential scheme at Brentwood Community Hospital would accord with this pillar through the introduction of an increased number of residents into an existing urban area. These new residents will help to secure the economic viability and vitality of the existing local businesses and services through an increased customer base. The redevelopment of the site would also ensure that a higher provision of land is available for a land use which is identified as being highly demanded at this point in time ensuring that a sufficient supply of land is available in a sustainably located site.

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

To ensure the soundness of the Local Plan, land should be allocated in Hutton to protect the future of this settlement and ensure sustainable growth.

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

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

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 agrees 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. Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3. It is considered that land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA is an appropriate site for residential development and should be allocated for appropriate new residential development.

This Regulation 19 Local Plan representation has been prepared by Phase 2 Planning and Development Ltd on behalf of Mr Terry Haynes, on behalf of the freehold owner of the subject site on land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA as outlined by the Site Location Plan included at Appendix 1. This submission is made under the Provisions of Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations (2012) and relates to the following sections of the Council's Pre-Submission Draft Local Plan: - Section 4: Managing Growth, Specifically Policy SP02: Managing Growth - Section 9: Site Allocations
Representation summary: In summary, the landowner wishes to highlight the sustainability of the proposed site south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality. Please see the remainder of this supporting statement for further consideration in support of the subject site's inclusion in this emerging Local Pan strategy. Soundness: As the attached representation form confirms the landowners representations relate specifically and solely to the soundness of the draft Submission Local Plan in respect of being positively prepared, justified, effective, and consistent with national policy in relation to the following sections of the emerging Local Plan: - Section 4: Managing Growth Specifically Policy SP02: Managing Growth - Section 9: Site Allocations - Soundness - Section 4: Managing Growth. Draft Policy SP02: Managing Growth - Although on the whole it is generally considered that the Council's Pre-Submission Local Plan is sound there is some concern that the Council's Housing Requirement is not fully robust. Planning Practice Guidance (PPG) on 'Housing and economic needs assessment', which was updated on the 20th 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. Paragraph 4.13 of the Council's Pre-Submission Draft 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. 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) with this assessment confirming 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 fully sound on this basis. 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. 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. 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. With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan-Pre-Submission Document can be considered to be robustly sound as, in accordance with paragraph 35 of NPPF3, the Plan is not fully 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 in full as it will not, as a minimum, meet its objectively assessed needs. Section 9: Site Allocations - The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Pre-Submission draft 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). Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not fully sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation. The following section of this representation provides support for land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA, to be allocated for residential development. 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 fully agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears ambitious. 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. This level of growth from such a strategic allocation does not appear realistic and no evidence has been put forward to date to support this forecast. 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). 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 up to two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission. 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. 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. 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. Furthermore, it is considered that the Local Plan is not entirely sound as it does not comply fully with paragraph 68 of the National Planning Policy Framework (NPPF3) (February 2019). 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. 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. 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. Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land south of Hook End Road) should be identified for allocation. 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. Necessary modifications to make the Pre-Submission Draft Local Plan robustly sound: 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 - 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 agrees 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. Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3. It is considered that land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA is an appropriate site for residential development and should be allocated for appropriate new residential development. The site itself includes land directly south of Hook End Road which would continue the existing pattern of ribbon development in this location as well as extend south comprising a logical and well-contained urban extension to the village with existing residential development already neighbouring the site on 3 sides. Despite this the subject site still remains of a greenfield nature situated within the Metropolitan Green Belt. Although noted that Hook End is proposed to be classified as a smaller village within the Borough's Settlement Hierarchy the importance of allocating appropriate growth throughout the Borough cannot be underestimated. The subject site itself would be well-placed to assist in enhancing the vitality of this rural community allowing the village to grow and thrive, especially where there are groups of smaller settlements, with development in one village able to support services in villages nearby as advocated by para 78 of NPPF3. This is particularly relevant in this instance given Hook End's physical relationship to the nearby villages of Stondon Massey, Doddinghurst and Wyatts Green as well as the village of Blackmore which itself includes some planned growth under the current Local Plan strategy. Importantly NPPF3 also highlights at para 84 that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. It adds at para 103 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-making. Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed Hook End Road lying on the southern edge of 'Parcel 49a Stondon Massey and Hook End'. The report when assessing the parcel as a whole, confirms that it makes a 'moderate' overall contribution to Green Belt Purposes. 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. 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 rural area of Hook End and is well contained by existing built development and mature trees. Development would be seen as a logical extension to the physical extent of the village 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 Hook End and nearby villages. Such countryside separation would be retained. Purpose 3: to assist in safeguarding the countryside from encroachment: The site has no specific countryside function and would utilise a well-contained parcel of land surrounded by residential development. Purpose 4: to preserve the setting and special character of historic towns: The site has no physical relationship with any historic town. Accordingly, it is considered that the site is suitable to be released from the Green Belt. 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 Hook End 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). Those sites listed above are located within villages and the rural area comparable to that at Hook End Road. Accordingly, we would request that the Local Plan be modified to allocate land south of Hook End Road for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas. Conclusions - Based on the information set out above, it is considered that the inclusion of the subject site within the Council's proposed housing growth strategy or as an alternative reserve site would be sustainable and fully deliverable early within the Local Plan period, improving the overall soundness of the emerging Local Plan itself. The possible low density nature of the allocation gives scope to provide a sensitively designed scheme which can be designed to integrate within and enhance the existing landscape having appropriate regard to local features and surrounding land uses, including existing neighbouring residential development. Subsequently, the landowner contends that the relevant sections of the emerging Local Plan referred to within would be sound but could be improved further with the inclusion of this site ensuring the emerging Plan is positively prepared, effective and justified, and would be fully consistent with national policy including 'boosting significantly' the delivery of new homes within a borough that is heavily constrained by the Metropolitan Green Belt. Participation at Hearing: The landowner reserves the right for them or their representative to participate at the associated Local Plan hearings (Examination in Public (EiP)) in relation to this emerging Local Plan process. This may be necessary to provide continued support for the inclusion of land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA within the emerging Local Plan's proposed housing growth strategy helping to secure its residential allocation.

we would request that the Local Plan be modified to allocate land south of Hook End Road for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas.

This Regulation 19 Local Plan representation has been prepared by Phase 2 Planning and Development Ltd on behalf of Mr Terry Haynes, on behalf of the freehold owner of the subject site on land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA as outlined by the Site Location Plan included at Appendix 1. This submission is made under the Provisions of Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations (2012) and relates to the following sections of the Council's Pre-Submission Draft Local Plan: - Section 4: Managing Growth, Specifically Policy SP02: Managing Growth - Section 9: Site Allocations
Representation summary: In summary, the landowner wishes to highlight the sustainability of the proposed site south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA (as illustrated by the Site Location Plan included at Appendix 1) to deliver much-needed new rural housing for Hook End enhancing its vitality. Please see the remainder of this supporting statement for further consideration in support of the subject site's inclusion in this emerging Local Pan strategy. Soundness: As the attached representation form confirms the landowners representations relate specifically and solely to the soundness of the draft Submission Local Plan in respect of being positively prepared, justified, effective, and consistent with national policy in relation to the following sections of the emerging Local Plan: - Section 4: Managing Growth Specifically Policy SP02: Managing Growth - Section 9: Site Allocations - Soundness - Section 4: Managing Growth. Draft Policy SP02: Managing Growth - Although on the whole it is generally considered that the Council's Pre-Submission Local Plan is sound there is some concern that the Council's Housing Requirement is not fully robust. Planning Practice Guidance (PPG) on 'Housing and economic needs assessment', which was updated on the 20th 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. Paragraph 4.13 of the Council's Pre-Submission Draft 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. 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) with this assessment confirming 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 fully sound on this basis. 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. 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. 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. With regards to Strategic Policy SP02, therefore, it is not considered that the Brentwood Local Plan-Pre-Submission Document can be considered to be robustly sound as, in accordance with paragraph 35 of NPPF3, the Plan is not fully 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 in full as it will not, as a minimum, meet its objectively assessed needs. Section 9: Site Allocations - The sites that the Borough Council have identified for residential development are detailed at Chapter 9 of the Pre-Submission draft 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). Accordingly, should the Inspector agree with our assessment that Brentwood's housing requirement is not fully sound, and the housing requirement thus increases, it would therefore be necessary to identify additional sites for allocation. The following section of this representation provides support for land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA, to be allocated for residential development. 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 fully agree with. The Council's calculations of when sites will be delivered, and how many dwellings will be delivered each year, appears ambitious. 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. This level of growth from such a strategic allocation does not appear realistic and no evidence has been put forward to date to support this forecast. 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). 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 up to two years, from adoption of the plan in 2020, for an outline planning application to be granted planning permission. 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. 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. 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. Furthermore, it is considered that the Local Plan is not entirely sound as it does not comply fully with paragraph 68 of the National Planning Policy Framework (NPPF3) (February 2019). 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. 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. 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. Accordingly, it is considered that, as identified above with the Dunton Hills Strategic Allocation, that a greater percentage of smaller sites (such as land south of Hook End Road) should be identified for allocation. 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. Necessary modifications to make the Pre-Submission Draft Local Plan robustly sound: 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 - 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 agrees 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. Furthermore, the Local Plan does not allocate a sufficient number of 'small sites' to contribute towards the housing requirement, as per paragraph 68 of NPPF3. It is considered that land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA is an appropriate site for residential development and should be allocated for appropriate new residential development. The site itself includes land directly south of Hook End Road which would continue the existing pattern of ribbon development in this location as well as extend south comprising a logical and well-contained urban extension to the village with existing residential development already neighbouring the site on 3 sides. Despite this the subject site still remains of a greenfield nature situated within the Metropolitan Green Belt. Although noted that Hook End is proposed to be classified as a smaller village within the Borough's Settlement Hierarchy the importance of allocating appropriate growth throughout the Borough cannot be underestimated. The subject site itself would be well-placed to assist in enhancing the vitality of this rural community allowing the village to grow and thrive, especially where there are groups of smaller settlements, with development in one village able to support services in villages nearby as advocated by para 78 of NPPF3. This is particularly relevant in this instance given Hook End's physical relationship to the nearby villages of Stondon Massey, Doddinghurst and Wyatts Green as well as the village of Blackmore which itself includes some planned growth under the current Local Plan strategy. Importantly NPPF3 also highlights at para 84 that planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. It adds at para 103 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-making. Brentwood Borough Council published parts 1 & 2 of its Green Belt study in January 2018. These initial parts showed Hook End Road lying on the southern edge of 'Parcel 49a Stondon Massey and Hook End'. The report when assessing the parcel as a whole, confirms that it makes a 'moderate' overall contribution to Green Belt Purposes. 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. 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 rural area of Hook End and is well contained by existing built development and mature trees. Development would be seen as a logical extension to the physical extent of the village 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 Hook End and nearby villages. Such countryside separation would be retained. Purpose 3: to assist in safeguarding the countryside from encroachment: The site has no specific countryside function and would utilise a well-contained parcel of land surrounded by residential development. Purpose 4: to preserve the setting and special character of historic towns: The site has no physical relationship with any historic town. Accordingly, it is considered that the site is suitable to be released from the Green Belt. 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 Hook End 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). Those sites listed above are located within villages and the rural area comparable to that at Hook End Road. Accordingly, we would request that the Local Plan be modified to allocate land south of Hook End Road for appropriate new residential development in line with the prevailing character and density of neighbouring residential areas. Conclusions - Based on the information set out above, it is considered that the inclusion of the subject site within the Council's proposed housing growth strategy or as an alternative reserve site would be sustainable and fully deliverable early within the Local Plan period, improving the overall soundness of the emerging Local Plan itself. The possible low density nature of the allocation gives scope to provide a sensitively designed scheme which can be designed to integrate within and enhance the existing landscape having appropriate regard to local features and surrounding land uses, including existing neighbouring residential development. Subsequently, the landowner contends that the relevant sections of the emerging Local Plan referred to within would be sound but could be improved further with the inclusion of this site ensuring the emerging Plan is positively prepared, effective and justified, and would be fully consistent with national policy including 'boosting significantly' the delivery of new homes within a borough that is heavily constrained by the Metropolitan Green Belt. Participation at Hearing: The landowner reserves the right for them or their representative to participate at the associated Local Plan hearings (Examination in Public (EiP)) in relation to this emerging Local Plan process. This may be necessary to provide continued support for the inclusion of land south of Hook End Road, Hook End, Brentwood, Essex, CM15 0HA within the emerging Local Plan's proposed housing growth strategy helping to secure its residential allocation.

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.

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.

St. Faith's site to be released from the Green Belt and allocated for residential-led development in this Local Plan.
Given the likely need for additional housing to support sustainable economic growth in the sub-region, coupled with the historically constrained nature of Brentwood due to the Green Belt, it is considered "necessary" to identify sufficient "safeguarded land" to meet longer-term development needs and ensure that Green Belt boundaries will not need to be altered at the end of the plan period as per NPPF2.

These representations have been submitted on behalf of Clearview Residential & Lardpam Ltd. in response to consultation on the Brentwood Local Plan: Pre-Submission Document (February 2019). They should be read in conjunction with our previous representations - including the Development Framework Document for St. Faith's, London Road (LPA ref. 299).
St Faith's, London Road
Despite being discounted by the Council at Regulation 18, Clearview & Lardpam remain committed to the site's development for a high-quality residential-led scheme capable of supporting:
+ Enhanced green spaces for sport and recreation with improved connections to surrounding infrastructure;
+ Approximately 750 new and deliverable homes (including 35% affordable) to meet demonstrable needs;
+ Integration of the existing office building for BT and/or other businesses; and
+ An element of local needs retail and leisure facilities to serve both new and existing communities.
As stipulated in previous representations, St. Faith's provides a strategic development opportunity for the Council - and the South Essex sub-region - offering a logical and sustainable location for an urban extension to Brentwood:
+ It is demonstrably deliverable with no major physical or legal constraints to development;
+ It comprises part previously developed land and is located close to Brentwood Town Centre and Railway Station - providing Crossrail services;
+ It performs poorly against the five purposes of the Green Belt and is a well contained site - the removal of which would represent only a 0.1% reduction in Brentwood's Green Belt; and
+ Only 25% of the land would have a built footprint, with the remaining land operating as enhanced open and green spaces.
It therefore remains Clearview & Lardpam's position that the site be released from the Green Belt and allocated for residential-led development in the emerging development plan.
South Essex Joint Strategic Plan
The South Essex authorities of Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea and Thurrock, together with Essex County Council, have agreed to prepare a new Joint Strategic Plan to ensure that future opportunities for sustainable economic growth are maximised:
"By 2050, the ambition is that all new development will be located in the most sustainable locations, will be of the highest quality, will support the emerging local industrial strategy priorities, and will be wellconnected by a fully integrated transport system and framework of green spaces. The current estimated need for housing across South Essex is 90,000 dwellings over the next 20 years, but with the right conditions to support growth, more could be achieved ..."
The combined authorities have set an ambitious timetable for preparing the Joint Strategic Plan, with adoption targeted for Autumn 2020. Ultimately, this will provide the strategic planning framework for South Essex with each authority then able to provide detailed local plans to help guide its delivery. In the interim, there is a commitment from all combined authorities to meet the full housing needs of the sub-region, with sufficient allocations to be determined through the Joint Strategic Plan. Identifying suitable sites will require ongoing engagement with key stakeholders, including landowners and developers such as Clearview & Lardpam. Whilst Brentwood Borough Council will continue to prepare its own Local Plan, it has committed to support the Joint Strategic Plan as it progresses. This means that Brentwood will likely require an early review of its Local Plan to ensure consistency with the Joint Structure Plan - including identification of additional sites to help meet the economic ambitions of the sub-region. St. Faith's provides a strategic development opportunity within the Crossrail / A12 corridor - one of five "Strategic Areas of Opportunity" identified in the South Essex Joint Strategic Plan: Statement of Common Ground (June 2018) - that should be identified to support sustainable economic growth in the sub-region.
Safeguarded Land
In this context, it is considered that - as a minimum - St. Faith's should be identified as "safeguarded land" in the Brentwood Local Plan to help ensure that a sufficient quantum of land is identified to meet future development needs. This would accord with NPPF2 which states at paragraph 139:
"When defining Green Belt boundaries, plans should:
a) ensure consistency with the development plan's strategy for meeting identified requirements for sustainable development;
b) not include land which it is unnecessary to keep permanently open;
c) where necessary, identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;
d) make clear that safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following an update to a plan which proposes the development;
e) be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period; and
f) define boundaries clearly, using physical features that are readily recognisable and likely to be permanent."
Designation of St. Faith's as "safeguarded land" satisfies all of these criteria as follows:
+ It is a logical and sustainable extension to Brentwood, as recognised in the Council's Sustainability Appraisal (January 2019);
+ Large areas of public open space and important ecological habitats can be retained and enhanced;
+ It provides a limited contribution to the Green Belt, as recognised in the Council's Green Belt Study (November 2018);
+ It can deliver a minimum of 750 new homes, employment and recreational opportunities to meet longerterm development needs (to be established through the Joint Strategic Plan and subsequent Brentwood Local Plan review);
+ It helps to ensure that Green Belt boundaries do not need to be altered at the end of the plan period; and
+ There are clear physical and defensible boundaries that define the site.
Given the likely need for additional housing to support sustainable economic growth in the sub-region, coupled with the historically constrained nature of Brentwood due to the Green Belt, it is considered "necessary" to identify sufficient "safeguarded land" to meet longer-term development needs and ensure that Green Belt boundaries will not need to be altered at the end of the plan period. This is a requirement of NPPF2 and until sufficient land is identified, the Brentwood Local Plan cannot be considered "sound" within the terms of NPPF2 paragraph 35.
We trust that these representations will be taken into account when preparing the Local Plan for submission to the Secretary of State for Independent Examination. Clearview & Lardpam welcomes the opportunity to continue working positively with Officers at Brentwood Borough Council to ensure that the Local Plan can be adopted at the earliest opportunity.
Should you require anything further, please do not hesitate to contact hgh Consulting.

The rejection of Site 219 is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton. The allocation of Site 219 for development will assist in curing defects in respect of the Local Plan, enabling it to be a sound plan.

Introduction and Background
1. These representations on the Brentwood Borough Proposed Submission Local Plan (February 2019) (PSLP) are submitted by Strutt and Parker on behalf of Turn2Us and in relation to land at Rayleigh Road, Hutton.
2. Land at Rayleigh Road, Hutton ('the Site') is also known as Land to the East of Hutton Village, Hutton as part of the Council's plan-making process, and is site reference 219.
3. The Site has been actively promoted by Turn2Us (including under their previous name of Elizabeth Finn Care Trust) throughout the plan-making process. Previous representations have been made at various stages of the Local Plan, including in relation to call for sites exercises and consultations on iterations of the Local Plan.
4. Turn2Us are the freeholder of the majority of the area of land between Hutton Village, Rayleigh Road and Church Lane. A small portion of this land, located immediately adjacent to the existing settlement and adjoining Rayleigh Road and Hutton village, measuring 2.4 ha is being actively promoted by Turn2Us for residential allocation in the Council's new Local Plan.
5. A location plan for this site is provided as Appendix A.
6. In addition, discussions with the Council through the plan-making process established that there is a need for the Local Plan to identify suitable sites to accommodate extra care accommodation (Use Class C2) to meet local needs. Consequently, a larger site within the location of Rayleigh Road, Hutton - suitable to accommodate both extra care accommodation (Use Class C2) and residential development (Use Class C3) was also put forward for consideration. This site was also submitted to the Council for consideration and was appended to our representations at the Regulation 18 stage. For completeness, a copy of this site plan is provided here again as Appendix B.
7. Neither the Site nor the wider land including potential for Use Class C2 accommodation are identified for allocation in the PSLP. Their rejection is considered unjustified, and to result in a PSLP which does not promote sustainable development.
8. By way of background, Turn2Us is a national, registered charity with a mission to fight poverty in the UK and Ireland, helping individuals who are struggling financially to gain access to financial help. Each year the charity assists several million people in a range of different ways. It has seen a steady increase in the number of people turning to the charity for help in recent years.
9. The charity receives no Government funding. It is through donations and legacies that it raises funds, and the charity is committed to ensuring long-term financial sustainability. Following careful implementation of its financial sustainability plan, in 2016/17 Turn2Us delivered its first deficit-free result in a decade. Turn2Us is a not-for-profit organisation, and net income is directed to providing assistance to those in need.
10. As part of efforts to ensure the financial sustainability of the charity, Turn2Us has been reviewing its assets and their potential to assist the charity. Such assets include land at Rayleigh Road, Hutton. The potential for this Site to sustainably help meet housing needs is considered mutually beneficial to the Council, Turn2Us, and the wider community.
11. The Charity's holdings have been promoted for residential development and an extra care scheme to complement the care home opposite the site. The extra-care facility would provide employment at a range of skill levels, benefiting the immediate area and the district. Further, the holdings are not proposed for allocation in full and a majority of the promoted site could be made available to a public body to safeguard the land as public space. This would be a significant benefit to Hutton but such possibilities have not been fully considered in the preparation of the PSLP and in regards to achieving its objectives.
Plan Period
12. The proposed period runs until 2033. Assuming - optimistically - 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.
13. This deficiency in the PSLP is of particular relevance given that the Borough is predominantly 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).
Total housing requirement
14. 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).
15. 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.1
16. 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.
17. 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).
18. 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.
19. 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.
20. 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'.
21. 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.
22. 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 year's 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.
23. 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 the PSLP 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
24. The Council is required to demonstrate a five-year housing land supply at any point in the plan period2.
25. 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.3
26. 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.
27. 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.
28. 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.
29. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.
30. 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 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.
31. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply.
32. 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.
33. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings).
34. 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.
35. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan.
36. 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.
37. 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 before development has even begun.
38. As such, it is totally 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.
Specialist accommodation for an ageing population
39. At paragraph 6.6, the PSLP rightly recognises that the Borough has an ageing population. At paragraph 6.7 it states that the Government position is that older persons should remain at home rather than enter residential facilities (Use Class C2) where appropriate.
40. However, what the PSLP fails to appropriately recognise and address is that for some people specialist accommodation or Use Class C2 accommodation will be more appropriate or necessary. It must be recognised that 'older people' is not a homogenous group, but a term that encompasses people with greatly varying accommodation requirements.
41. The NPPF (paragraph 50) requires Local Planning Authorities to plan for a mix of housing having regard to the needs of different groups, including older people. It goes on to state that Local Planning Authorities should identify the range of housing required in particular locations.
42. The PPG4 describes the need to provide housing for older people as critical, given the increase in this part of the population. It stresses that older people will have diverse needs, ranging from active people approaching retirement to the very frail elderly. The PPG confirms that Local Planning Authorities will need to determine the needs of people who will be approaching or reaching retirement as well as older people now. It suggests that future need for specialist accommodation for older people be broken down by tenure and type (e.g. sheltered, enhanced sheltered, extra care, registered care) may need to be assessed.
43. Notwithstanding the requirement of the NPPF and PPG, and the acknowledgment within the PSLP that this issue of accommodation for an ageing population is pertinent to the Borough, we have not been able to identify any evidence of how the accommodation needs for older people have been assessed as part of the plan-making process.
44. The PSLP proposes care homes through residential development within strategic housing allocations at Land at West Horndon Industrial Estate (Policy R02); Land north of Shenfield (Policy R03); Ford Headquarters and Council Depot (Policies R04 and R05). These are proposed to provide, in total, 180 beds of Use Class C2 accommodation.
45. In the absence of an assessment of need, it is unclear if this will meet need in quantitative terms.
46. Furthermore, we note that all of this provision is proposed on strategic allocations. As such, there will inevitably be relatively long lead-in times to their delivery. As such, we question whether the PSLP as currently drafted will ensure provision in the short-term.
47. The PSLP also suggests that there is "potential" for provision of a care home of around 40 beds as part of the proposed residential allocation at Policy R19 for 75 dwellings. However, the policy provides no certainty this will be delivered.
48. In respect of the allocations proposed to incorporate Use Class C2 development, it is unclear if the land is available for this type of development.
49. Policy HP04 of the PSLP states that the Council will "encourage" provision of specialist accommodation, subject to a number of criteria. However, it is not clear how much specialist accommodation, where, or how this will be delivered.
50. Without amendments, the PSLP is considered unsound in relation to its approach to meeting the accommodation needs of an ageing population. The approach is neither positively prepared, consistent with national policy, nor effective. In order to make the PSLP sound, we suggest the Council should identify the need for specialist accommodation, and allocation deliverable site to meet this.
Proposed Approach to Hutton
51. Hutton is the second largest settlement in the Borough.
52. In 2011, the town had a population of 15,578 and a total of 6,564 dwellings (Census 2011). It is a large, established community and a local centre which benefits from a range of services, facilities, access to public transport, and employment opportunities.
53. Hutton is situated approximately 30 kilometres from Central London, 12 kilometres from Chelmsford and in a position well related to regional and national infrastructure. Hutton lies in close proximity to Brentwood and Shenfield on the A12 corridor.
54. Hutton has strong service and education provision. The settlement benefits from excellent access to Shenfield High Street on the Hutton Road which adjoins Rayleigh Road and runs centrally through the settlement on an east-west axis. The High Street provides a variety of services, shops and businesses.
55. The PSLP sets out the Borough's settlement hierarchy. Hutton is identified as Category 1 - Main Town.
56. It is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. In addition, as an established community, it is important that the Local Plan manages the growth of the settlement to ensure the vitality of the community is sustained or enhanced.
57. However, notwithstanding the above, the PSLP proposes to direct no housing growth to Hutton. This contrasts sharply with the proposed approach to the other settlements identified as Category 1 - Main Towns. It is also notable that a considerable amount of growth is being directed to settlements below Hutton within the settlement hierarchy.
58. The PSLP fails to support the sustainable growth of Hutton. The proposal to direct none of the Borough's housing need to Hutton is unjustified, and inconsistent with national policy.
59. To ensure the Local Plan is sound, land should be allocated to ensure the sustainable growth of Hutton.
The Site
60. The Site measures 2.4 ha in area and is low quality grazing land used as paddocks. As such it principally comprises open pastoral grassland of low landscape value. It is located in the north-western corner of the Hutton Conservation Area, to which it could not be said that the site makes a positive contribution.
61. The Site is roughly triangular in shape, and constrained to the west, south-west, and east by existing development, and to the north by the A129 Rayleigh Road.
62. 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 Hutton.
63. A considerable amount of technical work has been undertaken in respect of land at Rayleigh Road, Hutton and previously submitted to the Council through previous stage of the plan-making process. This technical work demonstrates the Site is sustainable, suitable, available and achievable site to help meet the Borough's housing need. Work undertaken, and previously provided by included here again for completeness, includes:
* Green Belt Appraisal prepared by Lockhart Garratt (Appendix C)
* Heritage Assessment prepared by Terence O'Rourke Ltd (Appendix D)
* Site Opportunities and Constraints plan prepared by Go Planning Ltd. (Appendix E)
* Site Master planning prepared by Go Planning Ltd. (Appendix F)
* Landscape Assessment prepared by Lockhart Garratt (Appendix G)
* Tree Constraints and Opportunities Report prepared by Lockhart Garratt (Appendix H)
* Ecological Constraints and Opportunities Report prepared by Lockhart Garratt (Appendix I)
* Access Appraisal prepared by Journey Transport Planning (Appendix XX)
* Delivery Statement (Appendix J)
64. Within previous submissions to the Council, we have set out the sustainability of land adjacent to Rayleigh Road, Hutton for residential development, and an overview of these is provided again here, as follows.
65. There are three dimensions to sustainable development: economic; social and environmental.
66. In terms of economic impact, there is an inherent link between providing homes and the creation of jobs. Benefits of the site's development include additional local expenditure in and around Hutton from the additional residents. The intention for the land adjacent to Rayleigh Road, Hutton is to provide homes for people working in and around the Hutton area, assisting in local economic development.
67. The body of environmental consultancy work including detailed landscape appraisal, arboricultural investigations, ecological surveying and site master planning previously submitted to the Council have confirmed that the site can be brought forward for development without undue harm to the environment. Development of the site will reduce pressure to accommodate development on potentially more environmentally sensitive sites.
68. In respect of social impacts, the land adjacent to Rayleigh Road, Hutton is very well connected to local service provision with the majority of Hutton and Shenfield's services within a 2km radius of the site. In addition, the site benefits from excellent public transport links. The provision of homes to meet housing needs will have very significant social sustainability benefits.
69. Notably, the Council's evidence base supports the view that the Site is suitable, available and achievable for development, as confirmed by through by the assessment of the Site within the Brentwood Borough Council Housing and Economic Land Availability Assessment (October 2018) (HELAA). The HELAA projects the site can be delivered in years 1-5, and we concur with this view given the relatively small scale of the proposed development and the lack of constraints to delivery.
Strategic Environmental Assessment / Sustainability Appraisal (SEA/SA)
70. The Environmental Assessment of Plans and Programmes Regulations (2004) requires SA/SEAs to inter alia set out the reasons for the selection of preferred alternatives, and the rejection of others, be made set out.
71. In addition, the Planning Practice Guidance5 makes clear that the strategic environmental assessment should outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives.
72. Sustainability appraisal of the PSLP has been published: the Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA).
73. Site 219 is one of the 'shortlisted omission sites' in the SA, but did not progress to the final shortlist.
74. The SA explains that a number of sites were identified through the HELAA that were considered developable or deliverable, but are nevertheless not proposed to be allocated in the PSLP.
75. Table A of the SA provides commentary on these shortlisted omission sites. Of relevance to Site 219 it states:
"Hutton Village Conservation Area (CA) comprises the land to the south of the A129, stretching as far south as Hutton Hall and All Saints Church. Two shortlisted omission sites (HELAA 219, 317) comprise the areas of open land; however, both are heavily constrained in heritage terms. Maintaining the landscape gap between Hutton (Brentwood/Shenfield) and Billericay is a further consideration".
76. No details are provided to explain in what way Site 219 is heavily constrained in heritage terms.
77. In contrast, at the Regulation 18 stage consultation, a detailed Heritage Assessment was undertaken by Terence O'Rourke Ltd in respect of this site, and submitted as part of the plan-making process. It is provided again here for completeness (Appendix D).
78. As the Heritage Assessment notes, the site is located within the Hutton Conservation Area. The Heritage Assessment considers the character of the Conservation Area in detail, heritage assets within the locality, and the potential for development to be accommodated on the site without harming the character or significance of these.
79. The Heritage Assessment identified the following key characteristics of the Conservation Area, which would need to be taken into account in the consideration of the development of the site:
80. The survival and legibility of the historically dispersed pattern and the separate development areas.
81. The contrast with the modern development to the west of Hutton Village, which creates a very clear distinction between the conservation area and its setting, with no blurred boundaries.
82. The distinctive road layout allows extensive views within and across the parkland at the centre of the Conservation Area.
83. Trees within house plots and along boundaries are effective in screening the existing development including the large buildings of the care home in views across the parkland from the south.
84. The band of trees and stables to the rear of Hutton Court creates a division and gives the northern triangle of land a weaker parkland character.
85. The estate cottages and the linear group at Hutton Village are a possible model for new development.
86. The Heritage Statement suggests detailed appraisal of any future proposals for development within the Conservation Area by design and heritage advisors be used to inform the details of the future development of the site.
87. The Heritage Statement concludes that the site is capable of accommodating varying forms of development that in themselves would not result in harmful change to the significance of the Conservation Area. The acceptability and degree of change would have to be subject to careful consideration of layout and design, but it is clear that heritage issues are not a reason to reject outright the development of the site or its allocation in the Local Plan.
88. This detailed evidence from the Heritage Assessment has been provided to the Council, and we are not aware of any assessment of equivalent detail which contradicts its findings.
89. Having regard to all of the above, heritage concerns do not justify the rejection of the Site.
90. The SA also makes reference to maintaining a landscape gap between Hutton (Brentwood / Shenfield) and Billericay, though this is not expressed as a reason for rejection, nor does it appear to have been a determinant factor in the decision not to allocate the site.
91. However, for completeness, it should be recognised that the Green Belt Assessment Part 3 produced in respect of the Local Plan confirms that development of the site does not give rise to concerns in respect of coalescence of settlements. Green Belt issues are discussed further, later within this representation.
92. In short, the SA does not provide a justified reason for the rejection of the Site.
93. Turning to the specifics of the SA assessment of the Site, these are set out in Table C of the SA. This provides a 'traffic light' assessment of sites' sustainability. Green indicates sites perform well; amber poorly; red particularly poorly, against specific criteria.
94. Our first point in relation to the approach taken is that it is very simplistic - the assessment of sites appears to be based purely on physical distance to various features / facilities / designations.
95. For example, in relation to criteria 10 (Conservation Area) a site is considered to automatically score 'particularly poorly' if it intersects with a Conservation Area. There is no evidence that any consideration has been given as to whether a particular Conservation Areas is particularly sensitive to development (in many instances (e.g. town centres) Conservation Areas will be very much sustainable locations for development, provided development is implemented sensitively); or how development may impact on a Conservation Area. There may be cases where development could enhance a Conservation Area. Indeed, and somewhat confusingly, the SA acknowledges itself within Table A and in relation to cultural heritage, that it will also sometimes be the case that development can enhance heritage assets.
96. In respect of Site 219, it is deemed to perform particularly poorly in relation to criteria 10 (Conservation Area) due to it being located within a Conservation Area. As noted earlier, in the case of the Site, a detailed Heritage Assessment has been undertaken which confirms that heritage issues do not render the Site unsuitable for development.
97. We would also comment that it is unclear how the SA scoring has been used in decision-making, given that Site 219 has been assessed within Table C as more positive than a number of sites which are proposed to be allocated. It is not clear what weight has been applied to the different criteria.
98. The only other criteria against which the SA assesses the site as performing poorly is criteria 7 (GP surgery). Again, as with other criteria, assessment is based purely on physical distance. It is clear that this alone is a determinant factor, as there are other sites which are also measured as being over 1.5km from a GP surgery, but which are proposed to be allocated.
Green Belt
99. A detailed Green Belt Appraisal was prepared in respect of the Site by Lockhart Garratt and submitted at the Regulation 18 stage consultation. A copy is provided again here, for completeness (Appendix C).
100. 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:
101. 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.
102. The Green Belt Appraisal provides a thorough review of the site in relation to these purposes, and concludes that the site does not perform as Green Belt land as defined by national policy. It is therefore, the Appraisal finds, "not suited to being included within the geographical extent of the Metropolitan Green Belt" (paragraph 5.3.2).
103. The Green Belt Appraisal further concludes that the removal of the site from the Green Belt and its subsequent residential development would not:
* Cause undue harm to the setting of Hutton;
* Lead to settlement coalescence; or
* Diminish the wider character of the Metropolitan Green Belt.
104. A Part 3 Green Belt Appraisal (dated 31 January 2019) has been published by the Council. This considers specific sites, albeit in limited detail. Site 219 has been assessed through the Part 3 Green Belt Appraisal.
105. There is no evidence that the findings of the Green Belt Appraisal that was produced in respect of the Site by Lockhart Garratt, and which considered the Site in far greater detail than the Council's Part 3 Green Belt Appraisal, have been taken into account.
106. 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. For example, in relation to Purpose 3 (to assist in safeguarding the countryside from encroachment) the methodology states that where the majority of the existing land use is considered an appropriate land use with regard to Green Belt policy, and which contribute strongly to the functional countryside, such land will automatically be regarded as functional countryside. Such a finding then appears to contribute to a site being found to a high overall contribution to the purposes of the Green Belt. This approach to Green Belt assessment contrasts to that undertaken by Lockhart Garratt in respect of the Site, which - taking the consideration of Purpose 3 again by way of example - examines the relationship between the Site and the existing settlement in far greater detail, resulting in the provision of information which is of far greater use for the purposes of plan-making.
107. The Lockhart Garratt Green Belt Assessment provides a far more detailed and robust review of the Site's contribution to the purposes of Green Belt than that published by the Council, and should be considered as part of the plan-making process.
108. In addition, we note that despite the Council's Part 3 Green Belt Appraisal stating that Site 219 has "little or no relationship to historic town" on the first page of the Site's assessment. However, on the second and final page of the assessment it concludes that the Site has a "Strong Relationship with Historic Town (SHRT)", which appears to have contributed to the Site being found to have a moderate / high overall contribution to the purposes of the Green Belt. This is clearly an error.
Overview
109. The Council's own evidence base states that Site 219 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.
110. The reasons given for the rejection of the Site are spurious and based on erroneous conclusions.
111. The rejection of Site 219 is unjustified, and overlooks an opportunity to correct other soundness deficiencies in respect of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton.
112. The allocation of Site 219 for development will assist in curing defects in respect of the Local Plan, enabling it to be a sound plan.

The Parish note that no significant development is proposed within the Local Plan for Doddinghurst, other than the consideration of ad-hoc proposals that may arise over time, and welcomes this given the nature of the village and the obvious constraints , that have been recognised within the Plan, to any significant development.
However, we are also aware of concerns being expressed elsewhere in the Borough and of the possible implications this may have for the village. The Parish Council therefore wish to make known its concerns in relation to the Local Plan should any changes, which may impact on Doddinghurst, be considered as a result of the consultation process.
The village of Doddinghurst is a self-contained community with a clear identity and well-defined boundaries to its built up area. The Parish Council wish to express its view that the maintenance fo both of these are paramount and would not s=wish to see any development that would be inconsistent with present nature of the village or that would extend or blur the boundary to current built up area.
Apart from its concerns that development would detrimentally alter the nature of the village community, the Parish Council has serious concerns that the infrastructure of the village could not support further growth because:
There is no main road access to the village. The Blackmore Road provides good access but the route is through Kelvedon Hatch and the busy junction with the A128. All other access routes to the village are little more than winding country lanes of limited capacity, particularly for larger vehicles.
It would be unacceptable if access to any development were to use already congested residential street. Access for any proposed development, ad-hoc or otherwise , must be directly onto one of the larger through roads within the village.
There is limited public transport tto the village.
The doctors surgery is already finding it difficult to cope with present demand.
The public utilities, particularly water and gas, are regularly under repair and it is understood that the sewerage system is at capacity.

The above concerns have already been identified within the local plan as reasons not to identify Doddinghurst as an area for planned development and the Parish Council would re-emphasise these constraints should the current Local Plan's recommendations be subject to any change.
Yours faithfully
Cllr Debbie Dicker
Chair of Doddinghurst Parish Council

Withdraw plan as it stands. Consider brown field sites, infills and derelict properties,
Use parish council to communicate with the residents,
Establish a realistic proposal via the residents/parish council

The plan is unsound, not legally compliant and fails to comply with the duty to cooperate. Yet again green belt is being developed on. Blackmore struggles to deal with the amount of traffic and parking and will not cope with the new development. Doctors surgeries, public amenities are already at breaking point, how will they cope.
Increased risk of flooding
Withdraw plan as it stands. Consider brown field sites, infills and derelict properties,
Use parish council to communicate with the residents,
Establish a realistic proposal via the residents/parish council

The proposals map should be modified to remove Site 033 from the Green Belt and identified for the delivery of residential development.

These representations on the Brentwood Borough Proposed Submission Local Plan (February 2019) (PSLP) are submitted by Strutt and Parker on behalf of Chelmsford Diocesan Board of Finance (CDBF) and in relation to land to the south of Lodge Close, Hutton. Land to the south of Lodge Close, Hutton ('the Site') has previously been promoted as part of the Council's plan-making process, site reference 033. The site has been actively promoted by CDBF throughout the plan-making process. Previous representations have been made at various stages of the Local Plan, including in relation to call for sites exercises and consultations on iterations of the Local Plan. CDBF as the freehold owner of the site are actively promoting the Site for residential allocation in the Council's new Local Plan. A location plan for the site is provided as Appendix A. The proposed period runs until 2033. Assuming - optimistically - 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. This deficiency in the PSLP is of particular relevance given that the Borough is predominantly 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). Commentary on the Total Housing Requirement: 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 Planning Practice Guidance [PPG). 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. 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. 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). 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. The PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The 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'. 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. 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 year's 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. 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 the PSLP 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: The Council is required to demonstrate a five-year housing land supply at any point in the plan period2. 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. 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. 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. 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. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings. 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; 2 Paragraph: 038 Reference ID: 3-038-20180913; 3 Paragraph: 037 Reference ID: 3-037-20180913; did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. 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. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24 (or, to be precise, it projects 2,305.1 dwellings). 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. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is projected to delivery housing completions from 2022/23, i.e. falling within the first five years of the plan. 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. 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 before development has even begun. As such, it is totally 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. Proposed Approach to Hutton: Hutton is the second largest settlement in the Borough. In 2011, the town had a population of 15,578 and a total of 6,564 dwellings (Census 2011). It is a large, established community and a local centre which benefits from a range of services, facilities, access to public transport, and employment opportunities. Hutton is situated approximately 30 kilometres from Central London, 12 kilometres from Chelmsford and in a position well related to regional and national infrastructure. Hutton lies in close proximity to Brentwood and Shenfield on the A12 corridor. Hutton has strong service and education provision. The settlement benefits from excellent access to Shenfield High Street on the Hutton Road which adjoins Rayleigh Road and runs centrally through the settlement on an east-west axis. The High Street provides a variety of services, shops and businesses. The PSLP sets out the Borough's settlement hierarchy. Hutton is identified as Category 1 - Main Town. It is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. In addition, as an established community, it is important that the Local Plan manages the growth of the settlement to ensure the vitality of the community is sustained or enhanced. However, notwithstanding the above, the PSLP proposes to direct no housing growth to Hutton. This contrasts sharply with the proposed approach to the other settlements identified as Category 1 - Main Towns. It is also notable that a considerable amount of growth is being directed to settlements below Hutton within the settlement hierarchy. The PSLP fails to support the sustainable growth of Hutton. The proposal to direct none of the Borough's housing need to Hutton is unjustified, and inconsistent with national policy. To ensure the Local Plan is sound, paragraph 2.10 and the associated Table should be amended to ensure that Hutton delivers a scale of growth appropriate to its position within the hierarchy as a Category 1 Settlement. At present, Hutton will deliver fewer homes than any of the Category 2 Settlements. The site, as shown on the plan provided in Appendix A measures approximately 1.3 hectare. The Council have defined the net developable area of the site at 1.18 hectare, with an indicative yield of 35 dwellings. The site principally comprises open pastoral grassland of low landscape value. The site is roughly rectangular in shape, is well contained by thick trees and hedgerow and is constrained by development to the north and west, and Hutton Village to the east and south. The site is on land currently allocated as Green Belt in the Bentwood Replacement Local Plan (2005), but is situated immediately adjacent to the settlement boundary of Hutton. Within previous submissions to the Council, we have set out the sustainability of land south of Lodge Close, Hutton for residential development, and an overview of these is provided again here, as follows. There are three dimensions to sustainable development: economic; social and environmental. In terms of economic impact, there is an inherent link between providing homes and the creation of jobs. Benefits of the site's development include additional local expenditure in and around Hutton from the additional residents. The intention for the land south of Lodge Close, Hutton is to provide homes for people working in and around the Hutton area, assisting in local economic development. Development of the site will reduce pressure to accommodate development on potentially more environmentally sensitive sites. In respect of social impacts, the land south of Lodge Close, Hutton is very well connected to local service provision with the majority of Hutton and Shenfield's services within a 2km radius of the site. In addition, the site benefits from excellent public transport links. The provision of homes to meet housing needs will have very significant social sustainability benefits. Notably, the Council's evidence base supports the view that the site is suitable and achievable for development, as confirmed through the assessment of the Site within the Brentwood Borough Council Housing and Economic Land Availability Assessment (October 2018) (HEELA). We would however disagree with the assessment of the Site's availability as a reason for the Site being discounted. The findings suggest that the Site is 'unavailable' due to a lack of active promotion from the landowner; the site has been promoted through previous consultations of the Local Plan review process at Call for Sites and Preferred Options. The site is therefore available for development. The proposals map should be modified to remove Site 033 from the Green Belt and identified for the delivery of residential development. Strategic Environment Assessment / Sustainability Appraisal (SEA/SA). The Environment Assessment of Plans and Programmes Regulations (2004) requires SA/SEA to inter alia set out the reasons of preferred alternatives, and the rejection of others, be made set out. In addition, the Planning Practice Guidance4 makes clear that the strategic environmental assessment should outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. Sustainability appraisal of the PSLP has been published: The Sustainability Appraisal of the Brentwood Local Plan January 2019 (the SA). Site 033 has been wholly discounted, failing to progress to 'shortlisted omission sites' nor the final shortlist. The SA explains that a number of sites were identified through the HELAA that were considered developable or deliverable, but are nevertheless not proposed to be allocated in the PSLP. The SA does not provide a justified reason for the rejection of the site. Paragraph: 038 Reference ID: 11-038-20150209. We seek modifications to refine the Site Appraisal Criteria contained in the SA of the Brentwood Local Plan, prepared by AECOM. The decision process for utilising the RAG scoring is unclear in regards to the weighting given to the overall scores, and how this results in a site being considered suitable for allocation or unsuitable. The criteria set out in Appendix B Table 3 must adopt a more refined approach to its scoring in order to be of use in the identification of which sites and more or less sustainable. Criteria 7, 8, 9 should take account of the capacity of existing facilities and the scale of a proposed site, as this will affect the ability to provide additional facilities, or to support existing facilities. Criteria 10, 12, 13, 15 each assume that closer proximity of a site will have a negative effect on the criteria, when this is not necessarily the case. Criteria 17 should not be included in the SA as the notes for this criteria (p.96) confirm the Agricultural Land Classification Maps are of a poor resolution. It is recommended that a more refined scoring system is required to improve the utility of the SA to the identification of sustainable sites. A more refined scoring system would more accurately reflect the sustainability of any potential allocation. Further, greater transparency is required in relation to how the individual RAG scores have been used to reach a decision to allocate or omit sites. Green Belt: A Part 3 Green Belt Appraisal (dated 31st January 2019) has been published by the Council. This considered specific sites, albeit in limited detail. Site 033 has been discounted, with the assessment explaining: 'based on the progressive findings of the HELAA and wider evidence base, a selective approach to the assessment of additional has been undertaken. Overall, Sites (located within the Green Belt) which have been discounted for other environmental or strategic reasons (i.e. too small to form a strategic allocation), were not considered for further assessment.' Whilst the assessment has justified Site 033 (and other sites) being omitted from the assessment, the study assesses the significance of each site's contribution to four of the five purposes of the Green Belt, with an understanding the fifth purpose is implemented as an integral part of the Brentwood Local Plan. As such, previous findings contained in the HEELA and environmental / strategic constraints, unless explicitly relating to the four purposes of the Green Belt, should not be used for justifying site omission. With regards to Site 033, this is especially pertinent when considering the ambiguity of weight given to various SA scores (i.e. distance to GP and interaction with the Conservation Area) and the inaccuracy of availability in the HEELA (2018). Even were it appropriate to use such criteria to discount sites from a Green Belt assessment, the criteria itself in the case of the above has proven inaccurate, overly simplistic and therefore unreliable. As such we recommend the site is assessed within the Council's Part 3 Green Belt assessment as a suitable, deliverable and available site. As an overarching point, 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. We would therefore recommend that the Council provide a far more detailed and robust review of sites' contribution to the purposes of the Green Belt as part of the plan-making process. As part of any residential allocation, we would look to undertake further technical evidence to support the site's release from the Green Belt. Conclusion: The site is considered, suitable, available, achievable for development in accordance with the PSLP's aspirations for sustainable growth. The reasons given for the rejection of the site are spurious and based on erroneous conclusions. The rejection of site 033 is unjustified, and overlooks an opportunity to correct other soundness deficiencies of the Local Plan, including in relation to the overall quantum of housing proposed and the lack of support for any growth of Hutton. The allocation of Site 033 for development will assist in curing defects of the Local Plan, enabling it to be a sound plan.

Remove sites R25 and R26 from plan, refer to the Blackmore Village Heritage Association (BVHA) 'Neighbourhood Plan' for housing need.

Including the following sections:
LDP Fig 2.3 Settlement hierarchy
LDP Section 04 (management growth)
Policies:
SP01 - D
Paras 4.6 4.9 4.20
Policy SP02
Policy SP04 - A
LDP Section 06 (housing provision)
Policy HP 08

Section 08
Natural Environment
Policy NE 06 paras 8.51 -8.64
Para 8.85 (IV)
Para 8.90
Para 8.101
Policy NE13
Section 09 site allocation
Policy R25 para 9.87 -9.200
Policy R26 paras 9.201 - 9.204

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons:
1. IDP Fig 2.3 settlement hierarchy: there are errors in the plan eg the population of Blackmore is listed as 829 but this does not cover the residents in Nine Ashes Road past Red Rose Lanes and Chelmsford Road which includes a mobile home park and illegal travellers site.

2. Duty to cooperate: there has not been sufficient consultation with other neighbouring authorities. There us a development of 30 new, large houses by Epping Forest DC 100m outside the parish boundary in Fingrith Hall Lane. These properties are 1/3 miles from Blackmore Village and 5 miles from any other town/village. This will exacerbate the impact of the proposed 70 new properties being considered for Blackmore in the infrastructure and amenities.

3 Red Rose lane is a single track and not suitable for the extra volume of traffic generated by the proposed housing. It is used by walkers, joggers, cyclists; dog walkers and horseriders and has no pavement. The additional traffic will bring increased danger to these users along with the lack of street lights.

4. Flood Risk: Blackmore sites in a dip and is prone to flooding which has occurred a number of times over the years. The planned 70 homes will reduce the available land to soak up water, therefore flooding will increase.

5. Policy NE06 states that in 8.52: Developing inappropriately in high risk areas can put property and lives at risk; this policy seeks to ensure this does not happen.

6. infrastructure Requirements: There are no infrastructure requirements listed in policy R25 or R26, however all amenities and services are already stretched inc the local primary school, electricity, sewerage system, doctors surgery etc.

7. There is no clear housing strategy for the villages and general area in the north of the borough. There are many other options that have been suggested through this process but have not been considered.

8. A 'housing needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included on the LDP and why other more suitable areas have not been included.

9. The borough Council have not shown that the required additional houses for the borough could not be delivered by increasing the housing density on the other allocated sites in the plan.

10. There are brownfield sites available nearby but there is no evidence these have been considered in preference to using Green Belt land.

11. Other more suitable locations eg areas around Doddinghurst which have better transport links would have been a far better proposal that the development in Blackmore which is not a sustainable development proposal for the reasons given.

12. The proposed sites are important to wildlife and natural habitats.
Policy HP08 seeks to regularise an illegal travellers site on the Chelmsford Road. The borough Council has failed to undertake its duty to attempt to remove the travellers since they moved in some years ago. The Council has watched the site grow without taking any action!

My family moved to Blackmore 2 years ago from Epping for a quiet village life. The village does not have the capacity for 70 new homes.

Planning are building according only to absolute irrefutable necessity and not based on hypothetical projections of dubious accuracy way into the future.
Rejecting all development in the countryside/Green Belt, thereby respecting and upholding relevant statutes.
Concentrating unavoidable development on brownfield sites. eg West Horndon industrial estate R02, Warley (R04 and R05) and Wates Way industrial estate (R15), followed in order of priority by Ingatestone (former Garden Centre R21 and other R22) and town centre car parks (R10, R11, R14) in each case seeking greater yield by increasing density and constructing additional storeys.
Complying with the prescribed objectives of the sustainability appraisal.
Respecting council taxpayers, and the democratic process by rejecting any, all developments where there is significant local opposition.
All policy - local, regional, national, international should be predicated primarily on the need to restrict and ultimately reverse unsustainable population growth, not pander to it.

SUMMARY Refer to attached scan for full text.
Object to local plan, SA and HRA.
Strongly object to all non-brownfield proposed housing site allocations. The local plan fails to fulfil the prescribed criteria because it involves a deliberate wanton, massive, wholesale destruction, despoliation, violation and vandalism of the countryside and the green Belt in contravention of the Town and Country Planning Acts and the five main purposes of the Green Belt as stipulated by the National Planning Policy Framework.
This is with regard to Dunton Hills Garden Village (R01), Shenfield (R03), Blackmore (R25 and R26), two schemes at Kelvedon Hatch (R23 and R24), Doddinghurst Road (R16 and R17)
Additionally the plan fails to satisfy the objectives of the sustainability appraisal with regard to Soils, Heritage, Landscape, Biodiversity.
The Duty to Cooperate has not be met in that the views of statutory bodies have not been met regarding Dunton Hills Garden Village.
The concerns of Blackmore Parish Council on R25 and R26 have been treated with contempt.

Planning are building according only to absolute irrefutable necessity and not based on hypothetical projections of dubious accuracy way into the future.
Rejecting all development in the countryside/Green Belt, thereby respecting and upholding relevant statutes.
Concentrating unavoidable development on brownfield sites. eg West Horndon industrial estate R02, Warley (R04 and R05) and Wates Way industrial estate (R15), followed in order of priority by Ingatestone (former Garden Centre R21 and other R22) and town centre car parks (R10, R11, R14) in each case seeking greater yield by increasing density and constructing additional storeys.
Complying with the prescribed objectives of the sustainability appraisal.
Respecting council taxpayers, and the democratic process by rejecting any, all developments where there is significant local opposition.
All policy - local, regional, national, international should be predicated primarily on the need to restrict and ultimately reverse unsustainable population growth, not pander to it.

Totally against building work in Blackmore

Local plan is unsound and totally unsuitable for the village of Blackmore: the facilities of Blackmore is not sustainable for more dwellings, the impact on local wildlife, the proposed sites are liable to flood, traffic around the village, impact on the GP and school. Totally against building work in Blackmore