* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum.
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue.
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.

Main submission: REPRESENTATIONS TO BRENTWOOD LOCAL PLAN
APPENDIX A: SITE LOCATION PLAN
APPENDIX B: CONCEPT MASTERPLAN
APPENDIX C: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS MAP
APPENDIX D: HIGHWAYS TECHNICAL NOTE (ON PROPOSALS)
APPENDIX E: CONCEPT MASTERPLAN REPORT (separate attachment)
APPENDIX F: LANDSCAPE ASSESSMENT (separate attachment)
APPENDIX G: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS REPORT (separate attachment)

The above representations and supporting evidence can be summarised as followed:
The preparation of Brentwood Local Plan is supported and our comments aim to help it pass the NPPF (2019) test for soundness.
At present, we consider that the Local Plan is unsound and additional work is required to revise the Local Plan. Specifically it is:
* not positively prepared - objectively assessed development needs are not met, duty to cooperate doesn't consider unmet needs.
* not justified - reasonable alternatives are not suitably assessed and the preferred strategy is not suitably justified.
* not effective - the growth strategy is questionable, over ambitious completion rates and over reliance on strategic site.
* not consistent with national policy - Local Plan is not in conformity with NPPF (2019) e.g. objectively assessed development needs are not met, plan period is incorrect, no five year housing land supply is demonstrated etc.
This is a serious matter and we recommend that Brentwood Borough Council thoroughly reviews the approach to plan-making in order to prepare a sound Local Plan. Our main recommendations are summarised as follows:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum;
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer);
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue;
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment;
* Undertake updated Green Belt assessment;
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy.
Recommended modifications:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum. This is required to comply with the NPPF (2019).
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer). This is required to comply with the NPPF (2019).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue. This is required to comply with the NPPF (2019).
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.
Overall the benefits of the proposals represent "exceptional circumstances" in accordance with the NPPF (2019) - regardless of any increase in housing provision - which would allow for the site to be released from the Green Belt for housing.
* Significant community benefit by securing the future of Hopefield Animal Sanctuary. Hopefield will be granted long-term freehold for visitor centre.
* Opportunity to provide a great legacy for the town for recognised important community facility / Asset of Community Value;
* High quality and attractive new residential scheme within landscaped setting;
* New homes (including 35% affordable housing) to meet local needs.
* Significantly improved accessibility and connectivity through new footpath / cycleway connection between Doddinghurst Road and Sawyers Hall Lane and new drop off facility for car users.
* Limited impact on highways. As a result of highways / accessibility / connectivity improvements, the net effect of proposals in terms of vehicle movements for 450 dwellings, will be 285 dwellings, as the proposals will effectively remove trips equivalent to 165 units trips. Highways proposals are supported by Essex County Council.
* Suitable and sustainable location for development;
* Development proposals are developable;
* Proposals bring direct and indirect economic benefits to Brentwood town and the wider area;
* Proposals respect character and identity of Brentwood.
* No / limited impact on the overall role and function of the Green Belt and landscape.
GL Hearn (on behalf of Tesco) are working on a key site in Brentwood at Hopefield. The site is an important local community asset and therefore a solution for its future should be set out in the plan. We have been making Reps to the Local Plan since 2015. Therefore we expect to be part of the Local Plan examination discussions as we aim to help to produce a sound Local Plan.

* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum.
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue.
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.

Main submission: REPRESENTATIONS TO BRENTWOOD LOCAL PLAN
APPENDIX A: SITE LOCATION PLAN
APPENDIX B: CONCEPT MASTERPLAN
APPENDIX C: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS MAP
APPENDIX D: HIGHWAYS TECHNICAL NOTE (ON PROPOSALS)
APPENDIX E: CONCEPT MASTERPLAN REPORT (separate attachment)
APPENDIX F: LANDSCAPE ASSESSMENT (separate attachment)
APPENDIX G: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS REPORT (separate attachment)

The above representations and supporting evidence can be summarised as followed:
The preparation of Brentwood Local Plan is supported and our comments aim to help it pass the NPPF (2019) test for soundness.
At present, we consider that the Local Plan is unsound and additional work is required to revise the Local Plan. Specifically it is:
* not positively prepared - objectively assessed development needs are not met, duty to cooperate doesn't consider unmet needs.
* not justified - reasonable alternatives are not suitably assessed and the preferred strategy is not suitably justified.
* not effective - the growth strategy is questionable, over ambitious completion rates and over reliance on strategic site.
* not consistent with national policy - Local Plan is not in conformity with NPPF (2019) e.g. objectively assessed development needs are not met, plan period is incorrect, no five year housing land supply is demonstrated etc.
This is a serious matter and we recommend that Brentwood Borough Council thoroughly reviews the approach to plan-making in order to prepare a sound Local Plan. Our main recommendations are summarised as follows:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum;
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer);
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue;
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment;
* Undertake updated Green Belt assessment;
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy.
Recommended modifications:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum. This is required to comply with the NPPF (2019).
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer). This is required to comply with the NPPF (2019).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue. This is required to comply with the NPPF (2019).
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.
Overall the benefits of the proposals represent "exceptional circumstances" in accordance with the NPPF (2019) - regardless of any increase in housing provision - which would allow for the site to be released from the Green Belt for housing.
* Significant community benefit by securing the future of Hopefield Animal Sanctuary. Hopefield will be granted long-term freehold for visitor centre.
* Opportunity to provide a great legacy for the town for recognised important community facility / Asset of Community Value;
* High quality and attractive new residential scheme within landscaped setting;
* New homes (including 35% affordable housing) to meet local needs.
* Significantly improved accessibility and connectivity through new footpath / cycleway connection between Doddinghurst Road and Sawyers Hall Lane and new drop off facility for car users.
* Limited impact on highways. As a result of highways / accessibility / connectivity improvements, the net effect of proposals in terms of vehicle movements for 450 dwellings, will be 285 dwellings, as the proposals will effectively remove trips equivalent to 165 units trips. Highways proposals are supported by Essex County Council.
* Suitable and sustainable location for development;
* Development proposals are developable;
* Proposals bring direct and indirect economic benefits to Brentwood town and the wider area;
* Proposals respect character and identity of Brentwood.
* No / limited impact on the overall role and function of the Green Belt and landscape.
GL Hearn (on behalf of Tesco) are working on a key site in Brentwood at Hopefield. The site is an important local community asset and therefore a solution for its future should be set out in the plan. We have been making Reps to the Local Plan since 2015. Therefore we expect to be part of the Local Plan examination discussions as we aim to help to produce a sound Local Plan.

Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.

Main submission: REPRESENTATIONS TO BRENTWOOD LOCAL PLAN
APPENDIX A: SITE LOCATION PLAN
APPENDIX B: CONCEPT MASTERPLAN
APPENDIX C: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS MAP
APPENDIX D: HIGHWAYS TECHNICAL NOTE (ON PROPOSALS)
APPENDIX E: CONCEPT MASTERPLAN REPORT (separate attachment)
APPENDIX F: LANDSCAPE ASSESSMENT (separate attachment)
APPENDIX G: ACCESSIBILITY / CONNECTIVITY IMPROVEMENTS REPORT (separate attachment)

The above representations and supporting evidence can be summarised as followed:
The preparation of Brentwood Local Plan is supported and our comments aim to help it pass the NPPF (2019) test for soundness.
At present, we consider that the Local Plan is unsound and additional work is required to revise the Local Plan. Specifically it is:
* not positively prepared - objectively assessed development needs are not met, duty to cooperate doesn't consider unmet needs.
* not justified - reasonable alternatives are not suitably assessed and the preferred strategy is not suitably justified.
* not effective - the growth strategy is questionable, over ambitious completion rates and over reliance on strategic site.
* not consistent with national policy - Local Plan is not in conformity with NPPF (2019) e.g. objectively assessed development needs are not met, plan period is incorrect, no five year housing land supply is demonstrated etc.
This is a serious matter and we recommend that Brentwood Borough Council thoroughly reviews the approach to plan-making in order to prepare a sound Local Plan. Our main recommendations are summarised as follows:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum;
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer);
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue;
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment;
* Undertake updated Green Belt assessment;
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy.
Recommended modifications:
* Use 2014-based household projections as basis for the Local Plan. This means local housing needs baseline is 454 dwellings per annum. This is required to comply with the NPPF (2019).
* Set a housing requirement in Policy SP02 of 9,265 dwellings (which takes account of a 20% buffer). This is required to comply with the NPPF (2019).
* Re-balance the stepped trajectory approach to bring forward more housing in the first five years. This will also help address the five year housing land supply issue. This is required to comply with the NPPF (2019).
* Undertake additional work in respect of Duty to Co-operate, Sustainability Appraisal and Habitats Regulation Assessment. This is required to comply with the NPPF (2019) and legal tests.
* Undertake updated Green Belt assessment.
* Identify the Hopefield Site as a Housing Allocation in the new Local Plan as part of the revised and sound development strategy. This is required to address the above matters especially in relation to delivering the growth strategy and meeting five year housing land supply.
Overall the benefits of the proposals represent "exceptional circumstances" in accordance with the NPPF (2019) - regardless of any increase in housing provision - which would allow for the site to be released from the Green Belt for housing.
* Significant community benefit by securing the future of Hopefield Animal Sanctuary. Hopefield will be granted long-term freehold for visitor centre.
* Opportunity to provide a great legacy for the town for recognised important community facility / Asset of Community Value;
* High quality and attractive new residential scheme within landscaped setting;
* New homes (including 35% affordable housing) to meet local needs.
* Significantly improved accessibility and connectivity through new footpath / cycleway connection between Doddinghurst Road and Sawyers Hall Lane and new drop off facility for car users.
* Limited impact on highways. As a result of highways / accessibility / connectivity improvements, the net effect of proposals in terms of vehicle movements for 450 dwellings, will be 285 dwellings, as the proposals will effectively remove trips equivalent to 165 units trips. Highways proposals are supported by Essex County Council.
* Suitable and sustainable location for development;
* Development proposals are developable;
* Proposals bring direct and indirect economic benefits to Brentwood town and the wider area;
* Proposals respect character and identity of Brentwood.
* No / limited impact on the overall role and function of the Green Belt and landscape.
GL Hearn (on behalf of Tesco) are working on a key site in Brentwood at Hopefield. The site is an important local community asset and therefore a solution for its future should be set out in the plan. We have been making Reps to the Local Plan since 2015. Therefore we expect to be part of the Local Plan examination discussions as we aim to help to produce a sound Local Plan.