Paragraphs 1.1 - 1.5 of the PSLP and all references throughout the PSLP including supporting text and Policies should be amended to refer to a period of at least 15yrs from date of adoption. It is suggested that this be at least 2016 - 2035. Policies SP02; HP07; and PC02 should be amended to refer to a minimum of 15yrs from date of adoption with all housing and land requirements adjusted accordingly.

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

Housing requirement number to be recalculated, relevant policies to be amended and additional sites allocated.

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

Aditional non-strategic sites are required.

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

The Council should take the opportunity to allocate further smaller sites within the Local Plan, assisting in providing flexibility and improving housing delivery in the short term.

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

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

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