This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can delivery early in the plan period, and support the existing supply of housing.

These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients land north of the A1023 (Chelmsford Road), Shenfield, which has been allocated as part of a wider allocation area under Policy R03 of the PSLP. A plan showing the site is provided as Appendix A to this representation. 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. 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. The representations set out Countryside Properties position in relation to the allocation of the site as part of a wider strategic allocation 'R03' Land north of Shenfield and is an important contribution towards BBC's land supply for Brentwood's Draft Local Plan. The representations provide comments on the relevant policies relating to those interests in the Draft Plan. As the Council will be aware, representations have previously been made on behalf of the original landowner of the site, 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. As a result of these representations and the discussions that have been held with officers at Brentwood Borough Council alongside the Local Plan process, the site has been allocated as part of a wider allocation proposed for strategic mixed-use development on land north and south of Chelmsford Road in Shenfield, between the A12 to the north west and the railway line to the south west. Previous representation have included supporting information relating to landscape visual and Green Belt impacts have demonstrated the low value of the site in this respect, which have respectively support its proposed allocation. This representation therefore builds on this and should be read in conjunction with this information provided previously. Countryside Properties overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to the elements of the Housing, Employment and Development Management Policies and the housing trajectory relating to the delivery of Policy R03 during the plan period. Where concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist the Council to make the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. The site extends to a total area of 4.4ha, albeit the Council have previously defined the net developable area as 3.44ha. The site is located to the north of Chelmsford Road (A1023) and immediately south of the A12, directly south west of the A12/A1023/B1102 gyratory and westbound A12 slip road. The linear residential development of Chelmsford Road lies to the south of the site. The PSLP has recognised the sustainability of the site and enclosed character, as has been evidence through previous representations of the site, and have therefore proposed it for removal from the Green Belt and for its allocation to provide housing. We support this allocation but do however have some concerns over other policies in the PSLP that may have implications for the efficient and timely delivery of this site. Housing Needs: 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). 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. The NPPF requires Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change. At paragraph 4.16 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 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'. 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 or Green Belt protection. Moreover, the figure does not allow provision for unmet need from neighbouring authorities in addition to the minimum requirement. At 4.18 the PSLP confirms the Council have not been able to identify a five-year housing land supply to deliver the annualised requirement. Further to this, at 4.19 the PSLP confirms that there is a high proportion of designated Green Belt within the Borough, making it extremely difficult to achieve a five-year supply due to the fact that sites on the edge of settlements, currently within the Green Belt are not available for development purposes until the adoption of the Plan. The Borough has a limited amount of previously developed land within its authority to provide for short term delivery, as such Green Belt release is required in order to meet the Authorities housing need and deliver within the short, medium and long term, as stated at paragraph 2.54 of the PSLP. The approach to amend the Green Belt boundaries is therefore supported. 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. In respect of the above, whilst the current PSLP and associated housing allocations seek to go some way in delivering housing that will support the recognised needs of the Borough over the next 15 years, there is clearly a need to increase this provision. Whilst this could be helped through the identification of additional sites, ensuring the delivery and efficient use of the sites that are allocated for housing will also provide a degree of buffer. Further commentary and recommendations in this regard are provided later within this representation. 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 period (Paragraph: 038 Reference ID: 3-038-20180913). 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. 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. 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 noticeably 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 Glossary contained within Annex 2 of 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. 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 delivery 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. 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. 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. Policy R03 - Land North of Shenfield: Policy R03 deals with land to the north of Shenfield, known as Officer's Meadow and surrounding land. The entire allocation area comprises an area of 58.2ha and it is intended that the area will provide around 825 new homes; land for a co-located primary school, early years and childcare nursery; residential care home; 5% self-build and custom build; and 2ha of land for employment purposes across a net developable area of 28.2ha. We are of the understanding that the majority of these primary facilities will be provided within the main portion of the allocated area, to the south/ south west of Chelmsford Road, which immediately adjoins the existing settlement boundary and will therefore be directly accessible and central to the strategic development as a whole. Countryside Properties land is also known as site 158, as assessed by the Council within Brentwood Borough Council's Housing and Economic Land Availability Assessment (2018). The site measures 4.4ha (gross area) and was considered by the Council to comprise a net area of 3.44ha and capable of delivering 100 dwellings. The site forms one of a number of sites that together form the Strategic Allocation under Policy R03, Land north of Shenfield. Employment Land Provision: Policy R03 refers to the provision of 2ha of employment land across the site allocation as a whole. However, it is noted that Figure 7.6 of the PSLP identifies a new employment land allocation of 2ha at land north of A1023 - the site the subject of this representation, and a more specific reference than that contained within the PSLP policy wording. We note the combined requirement for employment land set out in Figure 7.5 of the PSLP, which confirms that the maximum level of employment land expected to be required over the plan period is 45.96ha. This is a maximum, with the lower expectation falling to 33.76ha, dependent on the forecasting scenario use. Respectively, Figure 7.6 recognises a predicted total of 47.39ha of employment land to be delivered through the new Local Plan and this provision therefore currently exceeds even the highest level of forecasted need. We are aware that previous representations and the submission to the Regulation 18 Consultation in particular did consider the potential for the delivery of up to 2ha of employment uses on the site. Since this time however, Countryside Properties have now taken on the promotion of the site. This has been supported by an additional level of due diligence which, alongside further discussions with Brentwood Borough Council officers, have identified a need to discount an employment-led development on this site. Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location, our client is confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location, and not necessarily accommodating 2ha of land. Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature. It would also generally be expected for offices to be located in a more urban and/or town centre location as opposed to this edge of settlement siting, and therefore doubt exists as to the likely interest in B1 premises in this location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area also, and also the implications that such a use could have on the A12 gyratory through the associated movements of HGVs and other vehicles. We are aware that there has been interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognized however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land. The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. As such, the provision of 2ha of land for employment purposes should be removed from the policy. In the interests of ensuring effective delivery, the Council should also consider the benefits of extending the provision of existing or larger proposed employment sites to account for flexibility that may be required on smaller allocations in response to market fluctuations and the viability of mixed use schemes. Countryside Properties are supportive of the land north of Chelmsford Road, Shenfield (ref.158) being identified as an opportunity to deliver a key gateway to Brentwood from the southbound A12. However, Countryside Properties consider the objective of a key gateway needs to be achieved through careful design in consultation with key stakeholders. In order to make Policy R03 effective, it is proposed that the wording in part (e) of the Policy is removed in its entirety, and for part A of Policy R03 to read: a) Amount and type of development; b) Provision for at least 825 new homes of mixed size and type, including affordable housing; c) Provision of land (circa 2.1 hectares) for a co-located primary school and early years and childcare nursery (Use Class D1); d) Provision for a residential care home (around 60 bed scheme as part of the overall allocation); e) Provision for 5% self-build and custom build across the entire allocation area. Whilst the site may have the potential to provide employment generating uses, a large scale provision of B-use class uses as required under Policies PC02 and PC03 is unlikely to be suitable for the site and the respective restrictive nature of this current wording. Countryside would however support the reintroduction of the wording presented to members which included: e) consideration for provision of appropriate new employment development on land north of Chelmsford Road. Figure 7.6 of the PSLP should be amended to reflect the proposed changes detailed above. The table included as this figure should therefore remove reference to Part of R03 - Land north of A1023 as a new employment allocation for 2ha. Unit Numbers: The wording of allocation policies such as Policy R03 should take the requirement for housing delivery flexibility into account, and therefore be worded to provide "at least 825 new homes", as opposed to "around 825 new homes". We consider that this would provide greater certainty on the number of homes to be delivered as part of each allocation for Brentwood Borough Council, and also allows for the delivery of additional units where appropriate opportunities may arise. For land north of A1023, a significant amount of feasibility work has been undertaken to establish any site constraints, and as a result of this, Countryside are confident in the ability for the site to provide at least 150 homes. We have concerns that the respective policy's current format may be interpreted to confirm the optimum use of the site, rather than a lower limit. In fact, the 100-unit figure has been produced by Brentwood Borough Council with far less rationale and technical justification than has been undertaken by Countryside Properties and may lessen the ability of this site and other policies with similar wording to support Brentwood's need for a buffer and flexibility in their housing land supply. Policy SP03 Health Impact Assessments: The Policy requires planning applications for developments of 50 or more to be dwellings, non-residential development of 1,000sqm or more or schemes for C2 class developments to be supported by HIAs. The HBF response to this policy is unsupportive and they consider the policy to be unsound as it is not consistent with national policy and is ineffective. We are in agreement with the HBF's response, dated 17th March 2019, in relation to the requirement for HIAs to be provided for 50 or more dwellings and consider the requirement to be unnecessary and an additional burden on applicants. Referring to the PPG we note that HIAs may be useful tools, however the PPG also expresses the importance of the local plan needing to consider the wider health issues in an area and ensuring the policies respond to these concerns. The guidance is provided below for completeness. Paragraph: 002 Reference ID: 53-002-20140306 confirms that provision of the required health infrastructure should be supported and taken into account at local and neighbourhood plan making, and when determining planning applications. Referring to National policy, paragraph 20 states that Strategic Policies should set out an overall strategy for the pattern, scale and quality of development, this includes infrastructure and community facilities. In order for the local plan to be consistent with national policy, the Local Plan should already consider the impact of development on the health and wellbeing of the communities and any identified infrastructure should be addressed in policy. Therefore, whilst Countryside support the important consideration of health and wellbeing of communities where development is in line with the policies contained within the development plan a HIA should not be necessary. The requirement for a HIA should only be triggered where there is a departure from the plan, enabling the Council to assess any impacts on the health and wellbeing of the community as a result of said proposals. Policy SP05 Construction Management: The Policy expects all major development schemes/developers to sign up to the Considerate Constructors Scheme, or equivalent. The scheme is a non-profit making, independent organisation which monitors construction sites signed up to the scheme, with the aim of managing and mitigating impacts arising from construction. This requirement is considered unjustified and inconsistent with national policy. Whilst we recognise the importance of managing the potential impacts on construction sites, we consider this policy to be unsound because it is unjustified and not consistent with national policy. We would suggest that consideration for the scheme is best dealt with through planning applications and development management without it being written into formal planning policy. We are not aware of any other adopted or emerging Local Plan which requires applicants and developers of major sites to enter into a specified construction management scheme and therefore question the reasonableness of this policy. The matter of construction management should be assessed on a case by case basis and should not be a matter for a strategic policy to prescribe. How a construction scheme is managed and mitigated should be an item for consideration by the decision taker and assessed on a case by case basis. The imposition of Policy SP05 requires all major developments to be signed up to the Considerate Constructors Scheme regardless of the site or proposal details. It is recommended that this policy is removed. Policy BE02 Sustainable Construction and Resource Efficiency: We consider the policy to be unsound as it is inconsistent with national policy. Part (f) of Policy BE02 requires the inclusion of renewable and decentralised energy as part of a new development, this is not consistent with national policy. Whilst Countryside recognise the importance of sustainable construction, a policy approach to such requirements does not allow for the appropriate flexibility in this regard, as recognised in the NPPF. Paragraph 153 of the NPPF states that local plans can expect development to meet such provisions, however the NPPF also states that they are only required to comply with such policies where it is either feasible or viable. To ensure consistency with national policy part (f) of Policy BE02 should be amended to reflect this position. Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency: It is Government policy to seek to deliver improvements to emissions from buildings through the building regulations regime. As such we do not consider it necessary to include the table at part (a) of this policy. Should a national zero carbon policy be introduced it will be achieved and applied through building regulations. We therefore echo those comments of the HBF's consultation response, dated 17th March 2019, and suggest that if the building regulations are updated then the Council should revisit the policy through a local plan review at that stage, but that such matters are dealt with through building regulations in the meantime to prevent unnecessary duplicate consideration of such matters through both planning and construction stages. Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network: It is acknowledged that the Government support the transition to a low carbon future in a changing climate, including support towards renewable and low carbon energy and associated infrastructure. Countryside support these intentions. Part (b) of Policy BE04 expects sites of over 500 dwellings, including where there are clusters of neighbouring sites that total over 500 units, shall incorporate decentralized energy infrastructure in line with a hierarchy however. We raise concerns in relation to the deliverability of part (b) of the policy in relation to sites within a cluster of 500 or more dwellings given that neighbouring sites will not necessary come forward by multiple landowners and developers at similar times. The coordinating and implementation of a heat network to serve smaller scale sites as separate applications but adjacent to other similar sized sites in the locality, is unreasonable and unjustified and could result in a delay in delivery of new homes, resulting in an ineffective local plan. It is recommended that the requirement for new development located where 'clusters' of neighbouring sites totals over 500 units should be removed from the policy in order to make the policy effective. Policy BE10 Connecting New Developments to Digital Infrastructure: It is Government policy to support the expansion of electronic communications networks. However, we would draw the Council's attention to the Written Ministerial Statement, 25th March 2015, which announced that local planning authorities preparing Local Plans, "should not set any additional standards or requirements relating to the construction, internal layout or performance of new dwellings." The Local Planning Authority are only allowed to adopt the three optional technical standards, in relation to construction, internal layout and performance, subject to evidenced need and viability. As such, the Council should not seek higher standards than Building Regulations, as already referred to in our response to Policy BE03. Therefore, Policy BE10 is considered unsound because it is unjustified and contrary to national policy. We are also unaware of National Policy requiring benches and bins to be connected to mobile digital infrastructure. As such the policy is unjustified and contrary to national policy. Countryside are committed to ensuring that all developments go as far as is practical to meet national intentions to ensure the quality, practicality and future-proofing of new housing developments. We have concerns however that by introducing a wealth of additional planning policies in these areas, there will be unnecessary duplication to building regulations, and potentially delays to planning applications which will in turn impact on the timely delivery of new homes. Summary: Countryside Properties generally support the plan, however alterations to the PSLP can enforce the soundness of the Plan, ensuring it has been positively prepared, justified and effective and consistent with national policy. The proposed allocation of land north of A1023 as part of the wider R03 strategic allocation within the PSLP is supported. Countryside do however raise concerns about the soundness of the Plan in relation to the approach taken to development management policies and timing of delivery of the site proposed for allocation. Policies mentioned above, appear to be based on an idealistic approach which does not account for different site constraints and flexibility in development management which would in turn help to protect the Council's supply of housing and robustness of the PSLP. The proposed amendments to the employment provision within Policy R03 will make the approach taken justified and effective. The proposed alterations will help to ensure that this policy is positively prepared and a justified approach for the site has taken into account the recognised constraints and the site is delivered in accordance with the expected delivery timescales, and that Brentwood can therefore meet housing needs as planned. The proposed amendments will also allow for flexibility over unit numbers in the event that the site can support the recognised need for a greater buffer and flexibility towards housing delivery over the Plan period. (Figure included in attached document).

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

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.

In light of comments raised above (in addition to our Client's comments to Draft Policy RO4 and RO5), we contend that the housing trajectory referenced within Appendix 1 of the PSD should be reviewed and adjusted to recognise that the Ford Warley site (both the northern and southern parcel) can be delivered earlier in the plan period (1-5 years versus the 9-17 years as currently drafted), irrespective and in isolation of the Council Depot - which our Client has indeed raised in both previous rounds of consultation on the local plan (including the Call for Sites and PSA). Indeed, and as BBC officers are aware, Ford will be vacating the Warley Site in 2019, with Conceptual masterplanning already undertaken and submitted to BBC; demonstrating the deliverability and suitability of the Site for a significant quantum of residential development on the Site (please refer to 'Garden in the Woods' Conceptual Masterplan at Appendix A2; as submitted to BBC in May 2017 as part of the Call for Sites consultation).

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its ownership and commercial interests at Eagle Way, Warley, Brentwood (the 'Site') within the administrative area of Brentwood Borough Council ('BBC'). Accordingly, Iceni has been instructed by Ford to prepare and submit written representations to the BBC New Local Plan, Pre-submission Draft consultation (2019) (referred to herein as 'PSD'). On behalf of our Client, we welcome the opportunity to comment on PSD which was published for consultation on the 5th February 2019. This is the final stage of consultation on the new Local Plan, following which the plan will be submitted to the Planning Inspectorate for independent examination. We therefore note that this stage of consultation is inviting comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2018) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy. The PSD consultation follows two previous consultations on the Local Plan, including the Call for Sites in 2016 and Preferred Site Allocations ('PSA') consultation in 2018. As BBC Officers will be aware, Ford have continued to actively engage in the preparation of the local plan with BBC - having submitted representations to all previous stages of consultation; supporting the allocation of the Site for housing. In this regard, Ford's previous representations have demonstrated that the Site represents a highly suitable and available Site for such development early in the plan period (particularly given the recent announcement regarding a change in operational requirements moving forwards) which should be prioritised given its brownfield nature. Within the PSD consultation version of the new Local Plan, our Client is supportive of the principle of the Site's allocation for residential development under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness in the NPPF (2018) - which the PSD consultation is indeed specifically seeking comments on, our Client wishes to object to the designation of 2 hectares ('ha') of employment land on the southern portion of the Ford Site (RO4) as specifically referenced under Draft Figure 7.6 and Draft Policy PCO3 in addition to the provision of specialist accommodation and self-build housing - in the absence of sufficient, supporting evidence to justify this. At this stage, our Client therefore considers the emerging Local Plan to be unsound and unjustified in the absence of a robust strategy, which should be based on proportionate evidence contrary to the NPPF Paragraph 35 and the overarching objective of enabling the delivery of sustainable development. Our Client also wishes to raise comments on other aspects of the PSD and Draft policies (as detailed in Section 3 of this representation submission); respectfully requesting that this is reviewed by BBC ahead of its submission to the Planning Inspector for examination. We would also welcome
discussing this submission in further detail with officers at the earliest possible convenience. In accordance with the requirements of the PSD consultation, and in order to inform this submission, the following documents have been submitted on behalf of our Client: * BBC completed Consultation Form; and * Written representations statement (this report which should be read in tandem with the above). This representation is submitted in line with the consultation deadline of 19th March 2019. The Site Location and Surroundings: The Site comprises 8.51 hectares (21.03 acres) of land located within Warley, forming the southern
edge of the Brentwood settlement boundary. This is a primary location for housing growth within both the adopted and PSD version of the emerging Local Plan - recognising its urbanised location within an existing settlement boundary. The Site is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway. The Site was originally developed for military purposes before being occupied by Ford as their European headquarters in the 1950s. Whilst the head office function has since been relocated to Cologne, Germany, the Site has remained in use by Ford as a central office for its UK services. However, Ford have recently announced that the Site will not continue to have an operational function as offices for the company moving forwards (due to a change in operational requirements). As such, it now represents a pivotal strategic opportunity within the PSD as a highly deliverable and available Site for new housing. Eagle Way runs east-west through the Site, dividing it into two parcels of land, as outlined below: * 'The northern parcel' - 1.37 hectares (3.39 acres) of land to the north of Eagle Way, currently utilised for staff car parking. A bus station is located on The Drive which runs along the western boundary, with Eagle Way running along the southern boundary of the northern parcel. To the north there is BBC owned land which is currently being utilised as additional car parking by Ford (on a lease agreement), as well as the highways depot and auto garage known as 'Council Depot.' 'The southern parcel' - 7.14 hectares (17.64 acres) of land to the south of Eagle Way where the main office building is located. The 6-7 storey office building has a NIA of 43,664 sq.m (470,000 sq.ft.), together with an ancillary data centre building, car parking and landscaping. Notably, the southern parcel includes an area of Green Belt Land along the eastern edge (comprising the Warley Gap) which is not proposed for any development within the PSD. The southern parcel is bounded by woodland, Clive Road to the west, Eagle Way to the north and woodland to the east. The area surrounding Site is predominantly characterised by residential uses, in addition to Marillac nursing home (to the east) and a local centre comprising retail and commercial uses to the west. Existing Planning Policy - Designations: In terms of adopted planning policy, the Site is currently subject to employment land use designations as defined by the BBC Replacement Local Plan (2005). Land to the north of Eagle Way is designated for 'general employment', and the land to the south of Eagle Way is designated as 'office'. A small portion of the southern parcel of the Site also falls within the Green Belt, along its eastern edge - which is not proposed for any form of development within the emerging PSD. In terms of heritage, there are Grade II listed buildings located outside of the site to the west including: The Royal Essex Regiment and Royal Anglian Regiment Headquarters building and Chapel. Site Ownership: Ford is the freehold owner of the Site. Ford also occupy an additional area to the north, which is currently owned by BBC and leased to Ford as car parking (comprising part of Draft allocation RO5 within the PSD). A plan highlighting the ownership boundary is included at Appendix A1. Formal Response to PSD Consultation: The following provides a formal consultation response on behalf of our Client to the PSD consultation. Specifically, this representation relates to the 'soundness' of the PSD - commenting on individual Draft policies within the consultation document on this basis (in accordance with the PSD Consultation Form Section B). Draft Policy R04 and R05: Ford Headquarters and Council Depot: Ford notes that the current PSD includes the Warley Site as a 'Strategic Housing Allocation' with the Council Depot, Warley under Draft policy allocation RO4 and RO5 - Ford Headquarters and Council Depot, which are collectively allocated for residential development for around 473 new homes anticipated to be delivered between 2024/25 and 2032/33 (within years 9-17 of the plan period). Notably, the Draft allocation also states that 'development proposals should consider the following': * The provision of a 60-bed residential care home as part of the overall allocation; * Provision for 5% self-build and custom build across the entire allocation; and * Provision of 2ha of land for employment purposes (specifically allocated on land south of Eagle Way with reference to Figure 7.2). Supporting Appendix 2 (Site Allocations) provides two separate plans for allocation RO4 ('land south of Eagle Way'; comprising the main Ford office building) and RO5 ('land north of Eagle Way; comprising the additional car parking area for Ford and the Council Depot) setting out that the sites have a collective site area of 9.4ha - of which 8ha is considered developable: * RO4 (south of Eagle Way) - 5.34ha of which 4.5ha developable. * RO5 (north of Eagle Way) - 4.06ha of which 3.5ha developable. Ford wishes to voice support in principle for the Draft allocation in the PSD for future residential development - including up to 350 new dwellings on the Ford owned land (as per our Clients previous representations to the PSA consultation and as demonstrated as deliverable within the 'Garden in the Woods' conceptual masterplan; as prepared by Iceni Design). This is highlighted with specific regards to the Site's situation within the Brentwood / Urban Area settlement boundary; comprising of previously developed brownfield land whereby the NPPF (2018) and PSD (2019) acknowledges that housing growth should be directed as a matter of priority in promoting sustainable development (providing a sound policy basis under the test of soundness within the NPPF). The need for BBC to identify additional land for housing is also required in order to address cross-boundary pressures such as London's future housing growth, which has been exemplified within relevant London Plan EiP hearing sessions. In this context, the Mayor of London has confirmed that local planning authorities within the wider south east, where the housing market is influenced by that of London should be working collaboratively with the GLA to significantly boost the supply of housing and ensure that Local Plans meet full objectively assessed needs. The arrival of Crossrail at Brentwood and Shenfield further exemplifies this requirement. This will undoubtedly bring even greater connections to central London, inevitably resulting in an increase in people living in the local area. This places further pressure on land for residential development, with the Site at Warley providing a key brownfield opportunity for much needed new housing. However, and as per our Clients previous formal response to the PSA consultation in May 2017, Ford request that the Draft allocation is revised to reflect the Ford owned land being available and deliverable earlier in the plan period - notably, 1-5 years versus the 9-17 years currently referenced within the PSD under the collective allocation with the Council Depot. This will help to deliver a significant degree of Brentwood's housing requirement in the short term (in line with the key objective of the NPPF with regards to boosting the supply of housing without delay). In this regard, it is assumed that the collective allocation has been put forward later in BBC's housing trajectory - to reflect the timescales anticipated for the Council owned Depot to be relocated. On this basis, our Client contends that the Ford owned land should be treated separately, with the Draft allocation revised to reflect the earlier timescales for housing delivery (which has indeed been evidenced to BBC through Ford's original Call for Sites submission in addition to ongoing, open dialogue with officers following Ford's announcement regarding the rationalisation of the business and subsequent vacation of the Site later this year). In this context, we wish to emphasise that the Ford Warley Site is a highly deliverable and available site for housing development, with realistic prospects that this will be delivered within the early phases of the plan period. Conversely, the Depot site is currently unavailable with an existing occupier, whereby we understand that BBC as the landowner have made no decisions regarding the site in terms of alternative provision. The approach to separating the sites within the Plan, will ensure that the early delivery of the Ford land for much needed housing is not unduly jeopardised (in accordance with the HELAA 2018, which indicated that new housing in the Borough would be brought forward on brownfield sites within the early years of the Plan). Please also see detailed comments made to Draft Policy SP02. Ford also wishes to object to the retention of 2ha of employment floorspace specifically at the land south of Eagle Way (i.e. the main Ford site; as referenced in Draft Figure 7.2 and Appendix 2) - in the absence of robust evidence to justify this, in tandem with acknowledging that the Site is no longer suitable for such uses (with the Ford site arguably being bespoke and an anomaly within the Borough; whereby the site's location would not be an attractive location for modern commercial investment). It is also apparent that BBC actually have a surplus of employment supply over the plan period, including at other more suitable sites across the Borough, whereby there is no logical or sound reasoning for the retention of 2ha of employment floorspace at the main Ford site (please also see comments made under Draft Policy PC03 'Employment Allocations' for full details / response on this matter). In a similar context, Ford also wishes to challenge the inclusion of a 60-bed care home and 5% custom build housing across the wider RO4 and RO5 Draft allocation - in the absence of any sound justification for this (contrary to the NPPF with regards to the requirement for planning policies to be underpinned by proportionate evidence) (please also see comments made under Draft Policy HP01 'Housing Mix' and HP04 'Specialist Accommodation' for full details / response on this matter). Whilst Ford welcomes the update to the PSD with regards to the correct site areas for Draft allocations RO4 and RO5 (under Appendix 2), as per our Client's comments to the PSA consultation (enclosed at Appendix A3 for reference), Ford wish to highlight that it is not possible to feasibility accommodate the amount of development currently included across the collective allocation - in the form which the market demands, whereby the provision of a care home and 2ha of employment floorspace significantly reduces the net developable area and ability to deliver up to 350 news homes on the Ford owned land (taking account of open space and infrastructure requirements; as demonstrated within the Garden in the Woods Conceptual Masterplan). This would result in a potential dwelling density that is wholly inappropriate for this type of location and would not respond at all well to the market demand for a housing-led development. As such, and for the reasons specifically raised under Draft Policy PCO3 and HP04 Ford wishes to object to the inclusion of these additional land uses in the interests of ensuring that the Site can be maximised for much needed housing development. To insist on retaining these alternative uses would significantly impact upon the ability and rate at which new housing could be delivered on this site, which would work against other objectives and policies in the Plan which are seeking early years delivery of housing on PDL. Draft Policy SP01: Sustainable Development: Ford wishes to voice support for the stated positive approach to the presumption in favour of sustainable development under Draft Policy SP01, in line with the NPPF (2018). In this regard, it is noted that the purpose of the planning system is to act positively to contribute to the achievement of this overarching objective. Draft Policy SP01 also provides a commitment from BBC to always work 'proactively with applicants to find solutions which mean that proposals for sustainable development can be approved wherever appropriate, and to secure development that improves the economic, social and environmental conditions in the area.' Again, this is welcomed by our Client and is considered a sound approach to plan and decision making (in accordance with NPPF Paragraph 12) which we would strongly urge BBC to ensure is underpinned by all other aspects of the new Local Plan in order for it to be sound. Spatial Development Strategy - Draft Paragraph 3.23: Ford wishes to voice support for the spatial strategy set out within the PSD, under Draft Paragraph 3.23, which seeks to prioritise brownfield sites wherever suitable, making efficient use of land in urban areas. In this regard, Ford wishes to highlight the suitability of the land at Eagle Way for residential development in supporting this endeavour - which is located within the established urban neighbourhood of Warley (recognised as being the priority settlement for housing growth). As such, the delivery of housing at the Ford site should be viewed as a vital, and priority opportunity for BBC in recognising that the Borough is heavily constrained by Green Belt (which makes up 89% of the Borough area), whereby this has made it challenging for BBC to fully meet its development needs. Our Client therefore contends that this approach is sound but should be consistently reflected in other aspects of the Plan (including the Draft allocation for the Ford site as discussed at Paragraph 3.2 of these representations). Draft Policy SP02: Managing Growth - The Government has introduced a new standardised methodology for calculating local housing need in line with the NPPF (2018). This is based on 2014 household projections published by the ONS. The NPPF (2018) places a much greater emphasis on seeking to meet objectively assessed needs than previous national policy - recognising that there are several significant negative socio-economic consequences that result from a failure to meet housing needs. This includes reducing access to housing, increasing inequality and housing market instability. One of the most significant impacts of a lack of housing supply is to reduce affordability, thereby increasing the number of concealed households and increasing the proportion of income required to rent. It is noted that the current PSD (Draft Policy SP02) makes provision for 7,752 new residential dwellings (net) to be built in the Borough over the plan period 2016-2033 at an annual rate of 310 dwellings per year to 2022/23, followed by 584 dwellings per year from 2023/24-2033. This approach adopts a stepped trajectory; resulting in the backloading of housing delivery beyond 2023 which we understand is in part due to a high proportion of Draft designated GB edge of settlement sites not being available for development until later in the plan period. Whilst our Client supports BBC's ascertain to direct housing growth to allocated sites in highly accessible locations along the transit/growth corridor (including the Ford Site) (as referenced under Draft Policy SP02 B), our Client considers that the starting point for examination of the Plan should be that a straight, rather than stepped trajectory should be used - to avert a significant, historic under-delivery of housing to persist (acknowledging that BBC are continuing to under-supply against its housing requirement until at least 2022/3). Whilst we do not consider that the principle of a stepped trajectory is justified, if this is accepted, we consider that a higher annual rate of housing delivery over the five-year period to 2023 should be tested. Iceni note that the current requirement for 310 dpa would fall below even the projected level of household growth. Indeed, the SHMA (2018) sets out that BBC has an uncapped need of 365 homes per year, reduced to 350 once a 40% cap is applied. The SHMA has pragmatically advised that BBC still needs to plan for at least 380 dpa as a minimum. Accordingly, we believe that BBC should take a rational position on this and plan for a higher annual housing target leading up to 2023 to ensure that a robust strategy is adopted (in line with the test of soundness). Notwithstanding, Ford encourages BBC to review the OAN figure as the Local Plan progresses towards examination to ensure that the housing target is adequately reflected. Housing Trajectory: In light of comments raised above (in addition to our Client's comments to Draft Policy RO4 and RO5), we contend that the housing trajectory referenced within Appendix 1 of the PSD should be reviewed and adjusted to recognise that the Ford Warley site (both the northern and southern parcel) can be delivered earlier in the plan period (1-5 years versus the 9-17 years as currently drafted), irrespective and in isolation of the Council Depot - which our Client has indeed raised in both previous rounds of consultation on the local plan (including the Call for Sites and PSA). Indeed, and as BBC officers are aware, Ford will be vacating the Warley Site in 2019, with Conceptual masterplanning already undertaken and submitted to BBC; demonstrating the deliverability and suitability of the Site for a significant quantum of residential development on the Site (please refer to 'Garden in the Woods' Conceptual Masterplan at Appendix A2; as submitted to BBC in May 2017 as part of the Call for Sites consultation). Further to ongoing dialogue with BBC, our Client also understands that the timescales for bringing forward the Council Depot for housing (which is still operational) are currently unknown at this stage, whereby the early delivery of the Ford site for housing should not be precluded on this basis. As such, our Client contends that the PSD as currently drafted, is contrary to the Governments ambitions to deliver 300,000 new homes by the mid-2020s nationally - ignoring the availability and deliverability of a significant proportion of housing at the Ford site, early in the plan period in providing for much needed housing for the Borough as soon as possible, at a sustainable brownfield location. In this regard, it is considered that the PSD is unsound on this basis and should be revised prior to being submitted for examination by BBC. Draft Policy SP06: Effective Delivery of Development: Our Client notes that Draft Policy SP06 is designed to ensure that a collaborative and participatory approach is taken when working up proposals. Ford are broadly supportive of this policy position, understanding the importance of comprehensive masterplanning to inform strategic site delivery. However, our Client wishes to note that such exercises should not inhibit the ability of individually owned sites to come forward for development. This is specifically referenced with regards to the Council Depot currently being included under the wider allocation for the Ford site, which we understand is not anticipated to be available for redevelopment until later in the plan period. As such, whilst Ford welcomes open and collaborative discussions regarding the wider allocation, and indeed the masterplan works to date have shown how future connections could be made to the Depot site; in tandem with how development could be proposed so as not to prejudice the development of either site, the early delivery of housing on the Ford owned land should not be prejudiced by delays in the decision-making process with regards to the Depot (see also comments under Draft Policy RO4 and RO5). It is considered that this would go against the premise of the overarching objective of the emerging Local Plan and the NPPF (2018) Paragraph 59 in terms of the delivery of sustainable development and ensuring the supply of homes without unnecessary delay. Draft Policy HP01 Housing Mix (varied types and tenures): Ford supports the intentions of Draft Policy HP01 in seeking to ensure that residential development proposals deliver housing in a way that contributes to the rebalancing of the housing stock; ensuring it reflects the recognised needs of existing and future communities. This includes providing a mix of dwelling types, sizes and tenures, relevant to the context of each site. Self-Build and Specialist Accommodation Threshold: Notwithstanding the above, our Client notes that the threshold for requiring a minimum of 5% self-build homes (which can include custom housebuilding and provision for specialist accommodation; see comments also made to Draft Policy HP04) is set at 500 or more dwellings. However, this threshold does not appear to have been applied to Draft allocations RO4 and RO5, which includes a requirement for both custom build housing and specialist accommodation across the wider allocation, despite having a total housing yield of 473 units across the Draft allocation - i.e. under the 500-unit threshold. Accordingly, our Client urges BBC to review this and requests that Draft allocation RO4 and RO5 is revised to remove this requirement based on the threshold set under Draft Policy HP01. At present, it is considered that there is a lack of evidence to justify this policy position, rendering the PSD unsound on this basis. Draft Policy HP03 - Residential Density: Ford welcomes Draft Policy HP03, which aims to ensure efficient use of the boroughs land whilst promoting a design-led approach to density which ensures schemes are sympathetic to local character and context. The supporting text states efficient land use is essential in a borough like Brentwood where land is scarce and enables new homes to be provided without encroaching on the countryside. This stresses the importance of delivering new housing on previously developed sites. Draft Policy HP05 - Affordable Housing: We fully appreciate that there is a significant need for affordable housing in Brentwood Borough, with 35% affordable applied to major residential schemes. Ford are aware that this level of affordable housing will likely be applied as part of any future planning application for the site, however this will be subject to scheme viability. BBC have recognised this approach, outlining that they will consider this where robust viability evidence demonstrates that the full amount of affordable housing cannot be delivered. This approach is welcomed by our Client and is considered to form a sound basis for negotiating affordable housing on a site-by-site basis (in line with NPPF Paragraph 62). Draft Policy PC03 - Employment Allocations: Ford notes that Draft Figure 7.6 and Appendix 2 of the PSD includes Part of allocation RO4 - 'Ford offices Eagle Way' (southern parcel of the Ford owned land) as an Existing Employment Site, whereby 2ha of land is proposed to be retained for employment purposes. However, there is no further evidence and/or explanation provided for this designation, which our Client indeed questioned and requested within our previous representations to the PSA consultation. Further, Draft Figure 7.5 'Employment Land Need' of the PSD outlines an employment land requirement of between 33.76ha and 45.96ha (taking account of four growth scenarios referenced under Draft Figure 7.4; as derived from the supporting Economic Future Report ['EFR'] January 2018). The EFR states that there is a pipeline supply of employment space in the Borough totalling 111.3ha. This includes 47.4ha of new employment allocations, 41.0ha of existing employment allocations, and 22.9 ha of existing employment sites previously unallocated. When subtracting the employment land requirements from BBC's new employment land supply there is a surplus in the range of between 21.4 ha and 33.7 ha (which is indeed recognised by BBC under Draft Paragraph 7.20 'exceeding requirements'). As such, it is highlighted that with the new employment allocations alone, BBC appear to have more than supply of employment land to meet its overall forecast needs over the plan period - questioning the requirement to retain 2ha of employment floorspace at the Ford site (whereby there appears to be very limited, or indeed no market demand for such space with no real planning basis for the 2ha figure referenced). Accordingly, it is anticipated that the new supply through the 'Proposed Allocations' should sufficiently compensate for the full release of the Ford site for residential with the Draft allocation for the Site revised accordingly including the removal for the requirement for 2ha of employment land. Ford also wishes to emphasise that the existing offices at Eagle Way were designed specifically for Ford and are bespoke for the operational and commercial requirements of Ford. It is therefore very unlikely that the Site could continue to support large-scale, modern employment uses of such a scale. It is also considered that the distance from Brentwood and Shenfield town centres and train stations would not be an attractive location for commercial investment - acknowledging that typically businesses requiring commercial properties of this size today, would pursue sites within close proximity of strategic infrastructure, trunk roads and more extensive local facilities and services. As such, and in light of current national policy parameters which specifically seek to promote sustainable forms of development, Ford wishes to object to the retention of employment uses at the Site - acknowledging that such a use is not considered an appropriate, or viable use of the Site in the future (contrary to the NPPF 2018). Ford further acknowledges that whilst there will be a requirement for commercial space in the Borough, land for residential development is critical in order to relieve any additional pressures on the Borough's Green Belt - with the Site representing an ideal opportunity for maximising residential development (including much needed family accommodation) which should be recognised under the Draft site allocation versus being restricted. In light of the above, and in the absence of robust evidence, Ford wishes to object to the provision of any level of employment use at the Site - rendering the PSD, Draft Policy PC03 and allocation RO4 and RO5 unsound on these grounds. Our Client therefore respectfully requests that the Site is removed from the listed 'Existing Employment Allocations' under Draft Figure 7.6. We also note that no reference is made to the re-provision of the Council Depot which we understand is likely to be retained for employment purposes into the early years of the plan period (given its current operational status). Draft Policy HP04 - Specialist Accommodation: Ford acknowledges that BBC are encouraging proposals to contribute to the delivery of Specialist Accommodation and are broadly supporting of Draft Policy HP04 in terms of providing such facilities where there is a 'demonstratable established local community need'. Ford recognises that the SHMA Part 2 (2016) identifies that there is likely to be an additional need for 494 specialist units over the next 20 years, including 466 units as sheltered housing and 28 extra-care units (albeit no distinction is made between them within the Draft policy wording, with no further assessment having been undertaken in recent years with regards to local requirements). Whilst Ford is supportive of BBC seeking to accommodate such facilities across the Borough, we note that there is currently a lack of evidence (including a detailed assessment of local community need) to fully justify accommodating such a use under Draft allocation RO4 and RO5, alongside residential. Indeed, we understand that that this requirement has only been included in response to a likely strategic-need for age friendly housing, but with no local analysis and/or basis to support this. Accordingly, and similarly to Ford's comments regarding the retention of employment uses at the Site, Ford wishes to highlight that due to the Site's location on the edge of Warley, it is considered that the Site does not represent the most suitable location for specialist care accommodation, with no analysis having been undertaken by BBC to demonstrate how the site is best placed to serve older people and their specialist needs. This goes to the heart of the NPPF (2018) test of soundness, in terms of the requirement for policies within local plans to be based on proportionate evidence. Further, Ford's commercial advisors CBRE have undertaken a recent analysis of local demand and supply within the surrounding Site area (Pulse Report) whereby this has identified that there is an oversupply of bed spaces across a variety of care spectrums (including a c.200 bed space oversupply within a 5-mile radius and c.1,000 within a 3 mile radius) - signifying a lack of need within the local area; whereby the Draft allocation would likely result in an un-viable future use (contrary to the parameters of sustainable development set out within the NPPF). As such, we would strongly urge BBC to revise the Draft allocation for the Site accordingly - recognising that it is most suitable for residential use only. Summary: On behalf of Ford, thank you for providing the opportunity to comment on the BBC PSD consultation document. As noted above, Ford is broadly supportive of the Draft allocation of its Site for housing, subject to further discussions with BBC Officers regarding the proposed additional land uses and development capacity - with sufficient evidence requested to justify the former, prior to the Local Plan being submitted for examination (to ensure that it is sound and legally compliant, in accordance with the NPPF 2018). We trust that the enclosed is clear, but please do not hesitate to contact Andrew Gale or Lucy Howes should you require any additional information. We would welcome discussing these representations with BBC at the earliest possible opportunity and to be kept informed of progress to the next stages of local plan preparation.

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

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

Need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound.

These representations are submitted by Strutt & Parker on behalf of Stonebond Properties Ltd. in relation to the Brentwood Borough Council (BBC) Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our client's land interests at Stocks Lane, Kelvedon Hatch. This is proposed for allocation under Policy R24 of the PSLP. Plans showing the site are included within the Vision Document at Appendix A to this representation. As the Council will be aware, representations have previously been made on behalf of the landowner, W H Norris & Sons, in respect of the land at Stocks Lane, most recently as part of the Regulation 18 Local Plan Consultation in March 2018. Since then the site has come into the control of Stonebond Properties Ltd, a local housing developer with considerable experience of bringing forward high quality homes on small and medium sites. As a result of the previous representations and discussions with officers at Brentwood Borough Council alongside the Local Plan process, this site and land at Blackmore Road (Site R23, Brize's Corner Field, also now under Stonebond Properties' control) have been proposed as sites for future residential development within PSLP. Stonebond's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to certain elements of the Policy R24 in relation to the amount of development, the expected time for delivery in the Plan period and certain elements of the PSLP's Development Management Policies. Where such concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist in BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. Stonebond Properties request the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the Examination of the submitted Local Plan. Settlement Hierarchy: Kelvedon Hatch is confirmed as a Category 3 Larger Village as set out in the Settlement Hierarchy shown at figure 2.3 of PSLP. It states that these villages are characterised by the amount of amenities and services able to cater for residents' day to day needs. Kelvedon Hatch has a local centre with a range of services, facilities, access to public transport, and education services. The PSLP sets out that Category 3 settlements should seek to make the most of brownfield redevelopment opportunities, while limited urban extensions will be encouraged to meet local needs where appropriate. The population is stated as 2,124, making Kelvedon Hatch the second largest Category 3 Settlement behind Doddinghurst. Due to the proximity of Doddinghurst (around 1km to the east), there is a reciprocal relationship between the two villages in terms of the availability and access to services and other facilities. As a result, development at Kelvedon Hatch 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 provides for the growth of the settlement to ensure the vitality of the community is sustained or enhanced. In line with Paragraph 78 of the NPPF, growth in one village may have the added benefit of further supporting opportunities and growth in nearby surrounding villages. The two sites for additional housing in Kelvedon Hatch identified in the PSLP at Land at Stocks Lane (R24) and west at Blackmore Road (R23) are fully supported. The proposed allocation of these two sites is considered to be justified, consistent with national policy and necessary to ensure the sustainable growth of Kelvedon Hatch and the Borough for reasons set out elsewhere in these representations. Spatial Strategy - Vision and Strategic Objectives: Vision for the Borough: The Vision for the Borough set out at Section 3 of the PSLP is supported. For the reasons set out in these representations, carefully planned development at Kelvedon Hatch as provided for at Policies R23 and R24 will make an important contribution to BBC's housing needs to meet the Local Plan objectives. Indeed, these representations and those relating to R24 make the case that a modest and justified increase in the sites' ability to accommodate more homes will assist meet those aims and provide for greater flexibility in meeting housing needs. Stonebond Properties have undertaken detailed site assessments. These confirm that there are no barriers to delivery of development. As a consequence, the expressed objectives of development in the Vision to be landscape-led responding to a "design and build with nature approach firmly embedding high quality green infrastructure through public realm to create a seamless transition to our surrounding countryside" can all be achieved and delivered in the allocation of sites R23 and R24. This is demonstrated in the accompanying Vision Documents to this representation for R24. Managing Growth - Policy SP02: Managing Growth: Policy SP02 proposes a total of 7,752 dwellings be provided in the Borough between 2011 and 2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. This matter is dealt with further at Section 8 below. Furthermore, and notwithstanding the stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. BBC are effectively placing most of its "eggs in one basket." in the range of sites that are proposed in the PSLP. It is important to note that, of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at Dunton Hills Garden Village and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at Dunton Hills. The ability of larger strategic 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's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. It therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound. Sequential Land Use: Paragraph 4.22 and 4.23 of the PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP. SP04 - Developer Contributions: There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted. Resilient Built Environment: We are generally supportive of the Council's objectives to achieve a resilient built environment. Nevertheless, there are concerns that the policies set out in the PSLP and as drafted may have an impact on viability, deliverability and affordability for housing development generally. We are aware of the representations made by the House Builders Federation (HBF) referring to sustainable construction (BE020), allotments (BE20), Green and Blue Infrastructure (BE18), access to nature (BE19), digital infrastructure (BE10), open space (BE22), electrical vehicle charging (BE15), housing quality (HP06). The implications of the requirements set out do not appear to have been fully considered as part of the viability assessment. As a consequence, we would suggest that the viability assessment for the PSLP is revisited to reflect on these requirements to better inform or provide clarity on the proposed policies. Policy BE01 - Future Proofing: Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. As a consequence, it is suggested that Policy BE01 should be set out as supporting text rather than a specific policy. Policy BE02 - Sustainable Construction and Resource Efficiency: Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments. Policy BE20 - Allotments and Community Food Growing Space: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations. Policy BE22 - Open Space in New Development: The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes. Housing Provision: Policy HP01 - Housing Mix: The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. As a consequence, it is suggested that para 6.5 should provide greater clarity and a minor change confirming that the final mix will be subject to negotiation "as part of a planning application" rather than "with the applicant". We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations. Policy HP03 - Residential Density: We support the PSLP's approach to residential density as set out in Policy HP03. This is considered to be justified based on the evidence and consistent with the national policy. As far as our client's land interests are concerned at R23 and R24, both sites are capable of providing an increased density to that expressed for the relevant policies R23 and R24. However, part B of the policy quite properly acknowledges that a chosen density should take into account the character of the surrounding area and other site constraints. This is supported. A further explanation of suggested density or yield for R24 is set out at Section 8 below. Policy HP05 - Affordable Housing: We note that the SHMA provides justification for the affordable housing requirements. However, it is questionable whether the precise tenure/mix should be set out at B(a) of the Policy, given that requirements can change relatively quickly over time and the prescriptive approach may not take into account precise local needs. As a consequence, it is recommended that the criteria under B(a) should omit the reference to 86% and 14% proportions. It is suggested, in the alternative, that "the mix, size, type and cost of affordable homes will meet the identified housing needs of the Council's area and local needs as appropriate, established by housing need assessments including the SHMA". Design and Place-making: The approach set out in the PSLP for design and place-making is broadly supported. However, we note that there are effectively seven policies (HP12 - HP18) which provide the requirements against these matters. We also note that there are some areas of repetition on some of the objectives against those policies. We consider that those commenting on and determining applications should preferably have one or two identified policies to refer to and/or applicable thresholds to more succinctly set out requirements. This would ensure that planning applications can be more effectively judged against context, design and place-shaping criteria. Natural Environment: We generally support the Council's approach to Green Belt and the identification of suitable sites to meet the Council's housing and other needs. Accompanying these representations is an overview of the Green Belt and Landscape Sensitivity considerations relating to Stonebond's land interests at R23 and R24 to confirm the suitability of removing those sites from the Green Belt and limited impact on the landscape. Policy NE13 - Site Allocations in the Green Belt: We welcome the PSLP's intentions to remove sites R23 and R24 from the Green Belt. This calls into question the need for Policy NE13. The requirements set out by criterion A and B are dealt with by other policies in the Plan. If there are site specific requirements relating to sites, these should be covered within the specific policies relating to those sites. Site Allocations: Policy R24 - Land off Stocks Lane: The proposed allocation of Land off Stocks Lane as Policy R24 and its removal from the Green Belt is considered sound and is fully supported. It has been established through the evidence base supporting the PSLP that Kelvedon Hatch is a sustainable location to accommodate a modest amount of new houses to contribute to the Borough's housing needs. Indeed, as recognised by para 68 of the NPPF and as a medium sized site, such sites make an important contribution to "meeting the housing requirement of an area and are often built out quickly". We do however have some concerns with the amount of development set out at A of the Policy and the indicative yield at page 340 and the suggested trajectory for the site at Appendix 1. These matters are dealt with below. Supporting these representations is a Vision Document at Appendix A, a review of Green Belt and Landscape Sensitivity at Appendix B and a Summary Drainage and Utility Appraisal at Appendix C. These all confirm that the development at the site is both justified and fully deliverable within the terms of para 67a) of the NPPF. The Vision Document demonstrates that careful consideration has been given to the emerging policies set out at BE01, BE08, BE22, as well as those relating to Design and Place-making at HP12, HP13, HP14, HP15 and HP18 of the PSLP to confirm that a scheme can meet the PSLP objectives in this regard. The Summary Drainage and Utility Appraisal at Appendix B confirms that there are no constraints to delivery. In addition, Stonebond Properties commissioned a transport appraisal from Ardent Consulting Engineers. This has confirmed that the location of the access shown in the Vision Document meets normal highway requirements in terms of safety and visability. This has been confirmed in speed surveys undertaken in Stocks Lane. The Green Belt and Landscape Sensitivity Assessment at Appendix B confirms that the release of the site from the Green Belt is justified. It also confirms that there would be no significant impact on the surrounding landscape. Part A of Policy R24 suggests that there be provision for around 30 new homes on the site. Part A Policy HP03 of the PSLP requires proposals to take a design led approach to density to ensure schemes are sympathetic to local character and make efficient use of land. Part B expects development to achieve a net density of at least 35dph unless the special character of the surrounding area suggests that such densities would be inappropriate. The suggested amount of 30 homes set out for Policy R24 does not currently reflect these requirements or provide an accurate representation of what is achievable on site. 30 homes represent 18.6dph which clearly does not represent an efficient or effective use of the land contrary to the objectives of HP03 and the supporting text set out at 6.18 to 6.20 and 6.22. The Vision Document confirms that around 45 homes can actually be provided on the site representing a far more efficient and effective dwelling yield. 45 homes would represent a density of approximately 28dph. Whilst this does not achieve 35dph, the Vision Document demonstrates that full account has been taken of the objectives of HP03 to ensure that a scheme would be sympathetic to local character. Critically, the illustrative scheme shows provision for open space within the site to meet the objectives of Policies HP13 and BE22. These policies provide for functional on-site open space. As such, achieving a greater density would be problematical. In addition, it is important to note that the site is on the edge of the settlement where there is a need for sensitivity, having regard to the countryside to the east and south. Para 6.22 of the PSLP confirms that efficient land use is critical to the delivery of this Plan for the reasons set out at Sections 4 and 6 above against this background, it is recommended that amendments are made as follows: Policy R24A - substitute 30 new homes with 45 new homes; Page R24 - indicative dwelling yield substitute 30 with 45. At para 9.195 the PSLP suggests the development would take its access from Blackmore Road. This is an error. The paragraph should be amended to refer to Stocks Lane. The site is within the control of Stonebond Properties, a local house builder with considerable experience in the development of medium sized sites, quick delivery and achieving high design and layout standards. Upon removal from the Green Belt and grant of a planning permission, it would be expected that development at the site could commence 2020/21 and be completed within two years of the Plan. As a consequence, it is recommended that the Local Development Plan Housing Trajectory at Appendix 1 is amended to provide for the following based on an increased number of homes as set out in these representations: Year 5 - 2020/21 = 10; Year 6 - 2021/22 = 35. These comments on Policy R24 provide greater certainty on delivery of the site. In addition, the changes suggested would contribute to the issues we have identified elsewhere with the PSLP specifically in relation to the supply and delivery of homes generally. As a result, we trust that the Council will be able to agree modifications/changes accordingly.

Need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound.

These representations are submitted by Strutt & Parker on behalf of Stonebond Properties Ltd. in relation to the Brentwood Borough Council (BBC) Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our client's land interests at Stocks Lane, Kelvedon Hatch. This is proposed for allocation under Policy R24 of the PSLP. Plans showing the site are included within the Vision Document at Appendix A to this representation. As the Council will be aware, representations have previously been made on behalf of the landowner, W H Norris & Sons, in respect of the land at Stocks Lane, most recently as part of the Regulation 18 Local Plan Consultation in March 2018. Since then the site has come into the control of Stonebond Properties Ltd, a local housing developer with considerable experience of bringing forward high quality homes on small and medium sites. As a result of the previous representations and discussions with officers at Brentwood Borough Council alongside the Local Plan process, this site and land at Blackmore Road (Site R23, Brize's Corner Field, also now under Stonebond Properties' control) have been proposed as sites for future residential development within PSLP. Stonebond's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to certain elements of the Policy R24 in relation to the amount of development, the expected time for delivery in the Plan period and certain elements of the PSLP's Development Management Policies. Where such concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist in BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. Stonebond Properties request the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the Examination of the submitted Local Plan. Settlement Hierarchy: Kelvedon Hatch is confirmed as a Category 3 Larger Village as set out in the Settlement Hierarchy shown at figure 2.3 of PSLP. It states that these villages are characterised by the amount of amenities and services able to cater for residents' day to day needs. Kelvedon Hatch has a local centre with a range of services, facilities, access to public transport, and education services. The PSLP sets out that Category 3 settlements should seek to make the most of brownfield redevelopment opportunities, while limited urban extensions will be encouraged to meet local needs where appropriate. The population is stated as 2,124, making Kelvedon Hatch the second largest Category 3 Settlement behind Doddinghurst. Due to the proximity of Doddinghurst (around 1km to the east), there is a reciprocal relationship between the two villages in terms of the availability and access to services and other facilities. As a result, development at Kelvedon Hatch 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 provides for the growth of the settlement to ensure the vitality of the community is sustained or enhanced. In line with Paragraph 78 of the NPPF, growth in one village may have the added benefit of further supporting opportunities and growth in nearby surrounding villages. The two sites for additional housing in Kelvedon Hatch identified in the PSLP at Land at Stocks Lane (R24) and west at Blackmore Road (R23) are fully supported. The proposed allocation of these two sites is considered to be justified, consistent with national policy and necessary to ensure the sustainable growth of Kelvedon Hatch and the Borough for reasons set out elsewhere in these representations. Spatial Strategy - Vision and Strategic Objectives: Vision for the Borough: The Vision for the Borough set out at Section 3 of the PSLP is supported. For the reasons set out in these representations, carefully planned development at Kelvedon Hatch as provided for at Policies R23 and R24 will make an important contribution to BBC's housing needs to meet the Local Plan objectives. Indeed, these representations and those relating to R24 make the case that a modest and justified increase in the sites' ability to accommodate more homes will assist meet those aims and provide for greater flexibility in meeting housing needs. Stonebond Properties have undertaken detailed site assessments. These confirm that there are no barriers to delivery of development. As a consequence, the expressed objectives of development in the Vision to be landscape-led responding to a "design and build with nature approach firmly embedding high quality green infrastructure through public realm to create a seamless transition to our surrounding countryside" can all be achieved and delivered in the allocation of sites R23 and R24. This is demonstrated in the accompanying Vision Documents to this representation for R24. Managing Growth - Policy SP02: Managing Growth: Policy SP02 proposes a total of 7,752 dwellings be provided in the Borough between 2011 and 2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. This matter is dealt with further at Section 8 below. Furthermore, and notwithstanding the stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. BBC are effectively placing most of its "eggs in one basket." in the range of sites that are proposed in the PSLP. It is important to note that, of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at Dunton Hills Garden Village and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at Dunton Hills. The ability of larger strategic 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's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. It therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound. Sequential Land Use: Paragraph 4.22 and 4.23 of the PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP. SP04 - Developer Contributions: There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted. Resilient Built Environment: We are generally supportive of the Council's objectives to achieve a resilient built environment. Nevertheless, there are concerns that the policies set out in the PSLP and as drafted may have an impact on viability, deliverability and affordability for housing development generally. We are aware of the representations made by the House Builders Federation (HBF) referring to sustainable construction (BE020), allotments (BE20), Green and Blue Infrastructure (BE18), access to nature (BE19), digital infrastructure (BE10), open space (BE22), electrical vehicle charging (BE15), housing quality (HP06). The implications of the requirements set out do not appear to have been fully considered as part of the viability assessment. As a consequence, we would suggest that the viability assessment for the PSLP is revisited to reflect on these requirements to better inform or provide clarity on the proposed policies. Policy BE01 - Future Proofing: Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. As a consequence, it is suggested that Policy BE01 should be set out as supporting text rather than a specific policy. Policy BE02 - Sustainable Construction and Resource Efficiency: Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments. Policy BE20 - Allotments and Community Food Growing Space: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations. Policy BE22 - Open Space in New Development: The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes. Housing Provision: Policy HP01 - Housing Mix: The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. As a consequence, it is suggested that para 6.5 should provide greater clarity and a minor change confirming that the final mix will be subject to negotiation "as part of a planning application" rather than "with the applicant". We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations. Policy HP03 - Residential Density: We support the PSLP's approach to residential density as set out in Policy HP03. This is considered to be justified based on the evidence and consistent with the national policy. As far as our client's land interests are concerned at R23 and R24, both sites are capable of providing an increased density to that expressed for the relevant policies R23 and R24. However, part B of the policy quite properly acknowledges that a chosen density should take into account the character of the surrounding area and other site constraints. This is supported. A further explanation of suggested density or yield for R24 is set out at Section 8 below. Policy HP05 - Affordable Housing: We note that the SHMA provides justification for the affordable housing requirements. However, it is questionable whether the precise tenure/mix should be set out at B(a) of the Policy, given that requirements can change relatively quickly over time and the prescriptive approach may not take into account precise local needs. As a consequence, it is recommended that the criteria under B(a) should omit the reference to 86% and 14% proportions. It is suggested, in the alternative, that "the mix, size, type and cost of affordable homes will meet the identified housing needs of the Council's area and local needs as appropriate, established by housing need assessments including the SHMA". Design and Place-making: The approach set out in the PSLP for design and place-making is broadly supported. However, we note that there are effectively seven policies (HP12 - HP18) which provide the requirements against these matters. We also note that there are some areas of repetition on some of the objectives against those policies. We consider that those commenting on and determining applications should preferably have one or two identified policies to refer to and/or applicable thresholds to more succinctly set out requirements. This would ensure that planning applications can be more effectively judged against context, design and place-shaping criteria. Natural Environment: We generally support the Council's approach to Green Belt and the identification of suitable sites to meet the Council's housing and other needs. Accompanying these representations is an overview of the Green Belt and Landscape Sensitivity considerations relating to Stonebond's land interests at R23 and R24 to confirm the suitability of removing those sites from the Green Belt and limited impact on the landscape. Policy NE13 - Site Allocations in the Green Belt: We welcome the PSLP's intentions to remove sites R23 and R24 from the Green Belt. This calls into question the need for Policy NE13. The requirements set out by criterion A and B are dealt with by other policies in the Plan. If there are site specific requirements relating to sites, these should be covered within the specific policies relating to those sites. Policy R23 - Brizes Corner Field, Blackmore Road: The proposed allocation of Land off Blackmore Road as Policy R23 and its removal from the Green Belt is considered sound and is fully supported. It has been established through the evidence base supporting the PSLP that Kelvedon Hatch is a sustainable location to accommodate a modest amount of new houses to contribute to the Borough's housing needs. Indeed, as recognised by para 68 of the NPPF and as a medium sized site, such sites make an important contribution to "meeting the housing requirement of an area and are often built out quickly". We do however have some concerns with the amount of development set out at A of the Policy, the indicative yield at page 339 and the suggested trajectory for the site at Appendix 1. These representations provide for a modest increase in the developable area of the site with compensatory open space/structural landscaping. These matters are dealt with further below. Supporting these representations is a Vision Document at Appendix A, a review of Green Belt and Landscape Sensitivity at Appendix B and a Summary Drainage and Utility Appraisal at Appendix C. These all confirm that the development at the site is both justified and fully deliverable within the terms of para 67a) of the NPPF. The Vision Document demonstrates that careful consideration has been given to the emerging policies set out at BE01, BE08, BE22, as well as those relating to Design and Place-making at HP12, HP13, HP14, HP15 and HP18 of the PSLP to confirm that a scheme can meet the PSLP objectives in this regard. The Summary Drainage and Utility Appraisal at Appendix B confirms that there are no constraints to delivery. In addition, Stonebond Properties commissioned a transport appraisal from Ardent Consulting Engineers. This has confirmed that the location of the access shown in the Vision Document meets normal highway requirements in terms of safety and visibility. This has been confirmed in speed surveys undertaken in Blackmore Road. The Green Belt and Landscape Sensitivity Assessment at Appendix B confirms that the release of the site from the Green Belt is justified. It also confirms that there would be no significant impact on the surrounding landscape. Vision Document illustrates a form of development for the proposed allocation area set out in the PSLP to provide for around 28 homes. These representations suggest that the allocated area could increase to provide for a modest addition to the developable area in associate with compensatory open space and structural landscaping. It is considered that the proposals would be in accordance with para 138 of the NPPF. This advises local planning authorities to "set out ways in which the impact of removing land from the Green Belt can be off set through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land". The Vision Document demonstrates how this can be achieved using land that is within their control. The Green Belt and Landscape Sensitivity Assessment confirms that such an approach would not result in demonstrable harm to the Green Belt or landscape. Part A of Policy R23 suggests that there be provision for around 23 new homes on the site. Part A Policy HP03 of the PSLP requires proposals to take a design led approach to density to ensure schemes are sympathetic to local character and make efficient use of land. Part B expects development to achieve a net density of at least 35dph unless the special character of the surrounding area suggests that such densities would be inappropriate. Based on page 339 of the PSLP, the suggested dwelling yield of 23 homes would result in a density of 29dph. The Vision Document confirms that within the allocated area it would be possible to provide around 28 homes at a density of 35dph. The Vision Document sets out an alternative approach to the allocation to increase the area to 2.45ha gross. This would provide for around 45 homes at 29dph on a net developable area of approximately 1.6ha. Critically, the Vision Document provides for a third of the area to be set aside for structural accessible open space in accordance with para 138 of the NPPF. The Vision Document therefore proposes that around 45 homes can be provided on the site representing a far more efficient and effective dwelling yield with benefits for open space and the Green Belt generally in this location by bringing forward a robust and enduring boundary. The Vision Document demonstrates that full account has been taken of the objectives of HP03 to ensure that a scheme would be sympathetic to local character. Critically, the illustrative scheme for the increased area for allocation would meet objectives for open space within the site in accordance with Policies HP13 and BE22 whilst taking into account the need for sensitivity, having regard to the countryside to the west and south. Section 4 of these representations sets out the need for greater flexibility and need for the provision of medium sized sites to aid the Council's housing needs and requirements. Against this background, these proposals to provide a modest increase to the allocated area for R23 are commended to the Council on the basis that the increased area provide for structural and accessible open space. It is therefore recommended that Policy R23 is amended as follows: Policy R23A - substitute 23 new homes with 45 new homes; Policy R23B - additional bullet point b - development shall provide for not less than 0.7ha for accessible public open space and structural landscaping; Page 339 R23 - indicative dwelling yield substitute 23 with 45. The site is within the control of Stonebond Properties, a local house builder with considerable experience in the development of medium sized sites, quick delivery and achieving high design and layout standards. Upon removal from the Green Belt and grant of a planning permission, it would be expected that development at the site could commence 2020/21 and be completed within two years of the Plan. As a consequence, and based on these representations for an increased allocation, it is recommended that the Local Development Plan Housing Trajectory at Appendix 1 is amended to provide for the following based on an increased number of homes as set out in these representations: Year 5 2020/21 = 10 and Year 6 - 2021/22 = 35. These comments on Policy R23 provide an ability for a modest increase in the amount of houses for the allocated site with significant local benefits for accessible open space and structural landscaping. This would result in compensatory improvements to the environmental quality and accessibility of Green Belt land in accordance with para 139 of the NPPF. In addition, the recommended changes would contribute to the issues we have identified elsewhere with the PSLP specifically in relation to the supply and delivery of homes generally. As a result, we trust that the Council will be able to agree modifications/changes accordingly.

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 - i.e. land to the south of Lodge Close, Hutton.

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.