The Local Plan must be amended to explain how unmet housing needs within neighbouring areas will be addressed.

The Pre-Submission Document (February 2019) (BBDP) makes provision for housing solely to meet the housing needs from within its administrative area. It has therefore not taken into account any unmet needs from neighbouring areas in establishing the amount of housing to be planned for (paragraph 60 of the Framework).

Neighbouring authorities have potential unmet housing needs. For instance, Basildon have stated in its recent Regulation 19 Plan that it has unmet needs of up to 4,000 homes over its plan period. Thurrock have stated that its current housing land supply falls significantly short of its housing needs, at around 15,000 dwellings.

Brentwood Borough also adjoins greater London Authorities. The London Plan is currently under examination and it is possible that unmet housing needs will be established.

The Duty to Co-Operate Position Statement (February 2019) describes engagement with other local authorities, in particular in the South Essex area. However, no reference is made to co-operation over this unmet housing need, and specifically no discussions are referenced in respect of whether Brentwood could accommodate some of the identified need in accordance with Paragraph 137 criteria c of the Framework.

Further, the ASELA Statement of Common Ground (June 2018) does not reflect the latest position on unmet housing need or how it will be addressed. It has therefore not been maintained contrary to paragraph 27 of the Framework.

Therefore, the BBDP is currently not sound as matters relating to unmet housing needs have not been dealt with and the Duty to Co-operate has not met the necessary legal tests.

This approach to plan making has been found unsound elsewhere in similar circumstances. Please see attached the Inspector's Letter of 1st June 2015 to Warwick District Council in respect of its Local Plan following initial hearings. In particular, please note paragraphs 23 to 29.

The duty to co-operate has therefore not been complied with, and as a consequence resulted in an underestimated housing requirement.

The Local Plan must be amended to reflect the most up-to-date approach to assessing the local housing need, and take into account unmet housing needs from neighbouring areas when establishing its housing requirement.

The total housing supply must demonstrate that it provides a sufficient supply and mix to meet the requirement, including for the first five years of the Plan period.

The stepped trajectory must be consistent with the evidence as to when strategic Green Belt allocations will start delivering.

The Local Plan should plan for a minimum of 15 years from adoption.

Establishing Local Housing Need and Requirement

The Pre-Submission Document (February 2019) (BBDP) defines an annual housing need of 350 dwellings per annum (dpa) using the standardised method based on the 2016 based household population projections.

Since the BBDP was drafted, the Framework has been amended to make clear that the 2014 household population projections are the baseline for calculating the standard housing need. On this basis, the annual housing need in the BBDP should be adjusted to 452 dpa.

In addition, an allowance may be necessary for unmet housing needs arising from neighbouring areas (see representations made by Hallam Land Management in relation to the Duty to Co-operate). Any figure would need to be added to the annual housing requirement.

The BBDP also proposes a housing supply buffer of 20% to allow for flexibility in meeting the requirement. This is supported in order to ensure the requirement is achieved. Without planning for a buffer to the housing requirement, there is the potential that housing needs will not be met. This is particularly necessary within Brentwood on the basis that the majority of Borough is Green Belt, and therefore there is very limited capacity for speculative windfall development to address any shortfall arising during the plan period.

Notwithstanding this has yet to be demonstrated, on the assumption that there are no unmet needs arising from neighbouring authorities, the housing requirement with a 20% buffer would be 542 dpa. If there are unmet housing needs, this figure would clearly be greater.

Provision should therefore be made in Policy SP02 for at least a minimum of 9,214 dwellings (based on 542 dpa) in the plan period 2016 to 2033.

On this basis, and setting aside the issue of unmet needs, the total housing supply in Figure 4.2 does not show a sufficient supply and mix of sites to meet the minimum number of homes required. It also does not demonstrate a five year supply on adoption of the Plan.


Stepped Trajectory

Policy SP02 proposes a stepped trajectory in housing supply due to existing Green Belt boundaries currently constraining growth. However, the increase in housing supply starts at 2023/24, which is a year after the housing trajectory assumes delivery starts on a number of the strategic Green Belt allocations (2022/23). The two dates should be consistent with each other.

Plan Period

It is assumed that adoption of the BBDP will be at the earliest in 2019/20. The Plan will therefore fall short by 1 year in ensuring the Plan looks ahead over a minimum 15 year period from adoption (NPPF paragraph 22).

Further growth should be directed towards the Central Brentwood Growth Corridor

Growth Strategy

Hallam Land Management support the strategy of growth within the Central Brentwood Growth Corridor as it maximises the benefits of the existing sustainable transport corridors (the A12, the Great Eastern Main Line, and the Elizabeth Line). Development within and on the edge of the existing Brentwood urban area has the most propensity to benefit from these corridors, and it is where the majority of housing and employment needs are derived from.

However, in identifying the A127 corridor as the other key axis, the Spatial Strategy is reliant upon the delivery of a significant level of growth away from where the vast majority of housing and employment needs of the Borough are derived.

The Local Plan proposes that more than half of the total allocations are located in the A127 corridor. There is an imbalance here. Therefore, if further growth is necessary as representations made in relation to housing need and requirement suggest, the Central Brentwood Growth Corridor should be considered first, ahead of any further growth within the A127 corridor.

Remove the north west green wedge symbol from the Key Diagram.

Key Diagram

The Key Diagram sets out the main aspects of the Spatial Strategy and diagrammatically includes three green wedges around the Brentwood urban area. Reference is made to 'green wedges of Green Belt' separating the urban areas of Brentwood and Shenfield in the explanation to Policy NE9 - Green Belt (para. 8.93).

In respect of the arrow to the west of Brentwood, it doesn't separate any settlements given it is such a wide tract of land. Furthermore, this tract of land doesn't separate Brentwood from Pilgrim's Hatch because they are joined to the north and will be further joined by proposed site allocations R16 & R17.

Clearly, these Green Wedges have informed the Spatial Strategy but when considering the Key Diagram, they do not all serve the function as expressed in paragraph. 8.93. Further analysis of the Green Belt, landscape and settlement coalescence is submitted with these representations.

The Plan needs to consider safeguarding land in order to meet longer term development needs.

Hallam Land Management have made representations elsewhere as to the failure of the Plan to show a sufficient supply and mix of sites to meet the minimum number of homes required, or to address the issue of unmet needs.

In this context, the Draft Plan should be providing more land for housing and thereby releasing more land from its Green Belt in order to promote sustainable patterns of development as required by Paragraph 138 of the Framework.

It is noted from paragraph 8.84 of the Draft Plan that the Council propose to only release 1% of land from the Green Belt within the Borough. This release will not result in any discernible difference to the character and appearance of the Borough, and is indicative of the fact that the Draft Plan has not thoroughly examined the contribution it should be making towards housing needs within the wider region through the release of Green Belt land. Moreover, the Draft Plan has not therefore considered the implications of its approach for sustainable development and settlements within and beyond the Green Belt in accordance with Paragraph 138 of the Framework.

Whilst the Council has reviewed its Green Belt as part of the process of preparing its Local Plan, the Assessment appears to have been overly influenced by the draft housing requirement set within the Draft Plan, and therefore over-estimated certain sites' contributions to the five purposes of the Green Belt in order to arrive at the proposed allocations and the draft housing requirement.

It is Hallam Land Management's strong view that there is a site that warrants release from the Green Belt as its development would contribute towards sustainable development and meeting housing needs where they arise, without undermining the integrity of the Green Belt within the Borough. This site is referred to as Calcott Hall Farm, Brentwood and representations are made elsewhere which support its proposed allocation.

Safeguarded Land

Notwithstanding the need to consider whether further land should be released from the Green Belt, national planning policy requires Local Plans to be able to demonstrate that Green Belt boundaries beyond the plan period will not need to be altered (NPPF para. 139).
In the context of a Local Plan area covered predominantly by Green Belt designation, with limited windfall opportunities and the Council's recognition that additional growth is inevitable beyond 2033, the Local Plan should ensure that additional land is removed from the Green Belt and safeguarded to meet longer term development needs.
This will ensure that the Local Plan provides for new defensible boundaries for future generations in accordance with Policy NE13, criterion B.
Other recently adopted Local Plans with similar levels of Green Belt coverage and future growth pressures have amended Green Belt boundaries to identify safeguarded land, for instance see South Staffordshire Site Allocations Document or Warwick District Local Plan.

Hallam Land Management have identified in these representations (and representations made in relation to Duty to Co-operate and Housing Need and Requirement), that the housing supply identified in the Plan will not meet the housing required to be provided for within the Plan. This is both in terms of the Plan period as a whole, and in terms of the first five years of the Plan period.

Additional Site Allocations are therefore necessary to make the Local Plan sound. Further, given the absence of non-Green Belt alternatives, the requirement to meet housing needs would be the exceptional circumstances for the further release of land and alterations to the Green Belt boundary as set out within the Local Plan.

Hallam Land Management are of the strong view that there is a suitable site adjoining the Brentwood Urban Area that would not undermine the purposes and importance of the Green Belt if it were to be released.

The site is referred to as Calcott Hall Farm, Brentwood, which is under the control of Hallam Land Management and could start delivery within five years of adoption of the Plan. The HEELA, October 2018 recognises the site as suitable, available and achievable (Site Ref 302c). Furthermore, the Sustainability Appraisal has already deemed the Site as a reasonable alternative (Table 5.2, SA of Brentwood Local Plan, January 2019).

Notwithstanding the Council's position that the site is suitable, available, and achievable, Hallam Land Management have submitted with these representations a suite of technical documents that demonstrate the site is both suitable and that its development would align with the Vision, Spatial Strategy and Strategic Objectives of the Plan. The key points to note are below:

Location

* As illustrated on the attached plan, the site is immediately adjacent to the Brentwood Urban Area (Settlement Category 1) as defined in the Settlement Hierarchy (Figure 2.3);
* The site lies to the immediate south of Pilgrims Hatch, and to the west of Brentwood and the A12;
* The site does not perform a role in maintaining separation between the already connected settlements of Brentwood and Pilgrims Hatch as evident from the plan and when viewed on the ground;
* The site falls within the Central Brentwood Growth Corridor; and,
* Its allocation would therefore be consistent with the Settlement Hierarchy and Spatial Strategy for the Borough.

Green Belt

* The site is already bounded on two sides by the Urban Area (to the north and east);
* The site has clear, physical defensible boundaries to the Green Belt to the south and west, namely Weald Road and Weald Country Park (a Local Authority owned parkland which is also a Registered Park and Conservation Area);
* These physical features are readily recognisable, and are permanent in accordance with paragraph 139 of the Framework, and an amended boundary for the Green Belt is appended to these representations;
* Any development would therefore be contained and the site has limited intervisibility with the wider Green Belt due to the presence of the urban area, and woodland and tree cover within the site;
* Paragraph 138 of the Framework requires first consideration to be given to releasing Green Belt land which has been previously developed or is well served by public transport. The site is well served by public transport as explained below under Accessibility and should therefore be a first consideration;
* Paragraph 138 also requires removing land from the Green Belt to be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. The environmental quality and accessibility of Weald Country Park can be improved through the release of this land as explained below under Transport and Connectivity; and,
* The site's release from the Green Belt would therefore be consistent with National Green Belt Policy and would not undermine the integrity of the Green Belt within the Borough.
Accessibility

* The site is within 2km or 10 minute cycle distance/20 minute walking distance of local services within Brentwood Town Centre, and closer still to day-to-day facilities within Pilgrims Hatch;
* Brentwood Train Station is a 12 minute cycle distance/25 minute walking distance, with Shenfield Train Station around 15 minute cycle distance/30 minute walking distance;
* Safe, direct and convenient routes to the town centre and train stations from the site are achievable; and,
* Existing bus routes already pass the northern entrance to the site, and a public transport strategy has been agreed with the Bus Operator to improve connections from the site with the train station and town centre.

Transport and Connectivity

* The site has the ability to deliver a Community Link Road (CLR) connecting Ongar Road to the north, with Weald Road to the south. The Transport Feasibility Study prepared states that the CLR would provide an alternative route for traffic from Pilgrims Hatch heading south to the A12/M25 that avoids Brentwood Town Centre and the Air Quality Management Area;
* The CLR would also improve the environmental quality of the Weald Country Park through enabling the downgrading of Sandpit Lane that runs along the site's western boundary by preventing through traffic; and,
* The site also has the ability to provide safe, direct and convenient pedestrian and cycle routes from the Brentwood Urban Area to the Weald Country Park that do not currently exist, and thereby improving its accessibility to the local population.

Environment

* There are no environmental features of interest that would prevent development of the site as evidenced within the suite of technical documents appended to these representations covering arboriculture, drainage, ecology, heritage, noise and air quality;
* There is the ability to deliver environmental benefits on the site, including ecological benefits arising from the management of the High Wood Local Wildlife Site and provision of green infrastructure that would enhance habitat connectivity with the Weald Country Park;
* Benefits to the setting of nearby designated heritage assets through the downgrading and reduction in vehicular traffic along Sandpit Lane;
* The site has limited inter-visibility with the wider landscape, and its visual envelop is primarily limited to points along the boundaries of the site; and,
* The retention of landscape features within the site, and locating development within the lease sensitive areas will ensure the landscape and visual impact is limited.

More specifically, with reference to the suite of technical documents, the site can be developed in accordance with relevant national and local planning policies as summarised below:

* A Desk Based Heritage Assessment has been prepared which demonstrates how harm to the setting of nearby designated assets, including Weald Country Park and South Weald Camp Iron Age Hillfort, can be avoided through the incorporation of suitable buffers from built development which are incorporated into the Capacity Plan;

* A Landscape and Visual Statement has been prepared which demonstrates how development of the site would not result in any sense of greater coalescence between Pilgrims Hatch and Brentwood than exists today, and how the site has limited intervisibility with the countryside to the south and west such that its visual impacts would be limited. Key landscape features have also been incorporated into the Capacity Plan;

* A Preliminary Acoustics Review has been prepared which demonstrates that potential sound sources, including from traffic on the A12, can be mitigated to acceptable levels through consideration being given to layout and the relationship of dwellings to the noise source, and incorporation of an acoustic bund which has been incorporated into the Capacity Plan;

* A Preliminary Air Quality Review has been prepared which demonstrates the effects of sources of air pollution near to the site, including the A12, on development can be mitigated through incorporating sufficient buffers within the layout which have been incorporated into the Capacity Plan;
* A Preliminary Arboricultural Assessment has been prepared which demonstrates how the woodland and trees of high quality within the site can be retained through the indicative layout incorporated into the Capacity Plan;

* A Preliminary Ecological Appraisal has been prepared which demonstrates how valuable ecological habitats on site will be protected and enhanced through the indicative layout incorporated into the Capacity Plan; and

* A Surface Water and Foul Water Feasibility Study has been prepared which demonstrates that surface and foul water can be appropriately managed in conjunction with onsite measures including attenuation ponds within the layout which have been incorporated into the Capacity Plan.

Infrastructure

* The site has the ability to accommodate a primary school should this be necessary to serve the development; and
* There are no constraints to development in terms of utilities infrastructure as illustrated on the appended Utilities Constraints Plan.

Delivery
* Hallam Land Management control the site, and as outlined above there are no impediments to early delivery;
* They have a strong track record of securing deliverable outline planning permissions that are attractive to the market. It is therefore considered that delivery could start within five years from plan adoption;
* In addition, as there are two points of vehicular access (at either end of the site) with a central spine road (CLR) that in part could accommodate sales outlets on either side, two to three sales outlets are achievable. On this basis the following trajectory is assumed:

Year: Dpa: - 22/23: 25 23/24: 75 24/25: 100 25/26: 100 26/27: 100 27/28: 100 28/29:100 29/30: 100 30/31: 100 - Total: 800


Review of the Draft Local Plan Evidence Base
Hallam Land Management have undertaken a review of the evidence base relevant to the above site.

As noted above, the HEELA, October 2018 recognises the site as suitable, available and achievable (Site Ref 302c). Furthermore, the Sustainability Appraisal deemed the Site as a reasonable alternative (Table 5.2, SA of Brentwood Local Plan, January 2019).
The site has also been assessed within the various Green Belt Studies that have been undertaken for the Council.

The Green Belt Studies Part 2 (January 2018) and Part 3 (November 2018) both assessed the site as making a moderate-high contribution to the purposes of the Green Belt.

However, this assessment changed when a new Green Belt Study Part 3 (January 2019) was published in February 2019 which assessed the site as making a high contribution to the purposes of the Green Belt. The reason for the changes to the evidence base after publication of the Draft Local Plan are unclear and should be explained.

Furthermore, there are a number of inaccuracies in the January 2019 assessment of the site as follows:

* The study considers the site as having clear separation from the urban area based on the A12 and A128, and limited association with the urban area.

In response, Pilgrims Hatch extends to both sides of the A128 and therefore the A128 does not separate the site from the urban area. The site, and features such as High Wood, sports pitches, and Calcott Hall Farm, have close association with Pilgrims Hatch which forms part of the Brentwood Urban Area in accordance with the Council's Settlement Hierarchy.

* The study assesses the site as 'not contained'.

In response, it is evident from the plan and on the ground that the site is contained on two sides by built development. The site abuts the built-up area, would be an urban extension, and should be regarded as 'partly contained'.

* The study considers the site would lead to a physical narrowing of the gap and 'potential' visual coalesence between Pilgrims Hatch and Brentwood. The study also refers to 'perceptual' coalescence.

In response, the A12 is the only gap between Pilgrims Hatch and Brentwood and this would not change. The boundary of the site is pulled back from the Ongar Road adjacent to the A12 to reflect the existing sports pitches such that there would be no change to visual coalescence as perceived on the ground than that which already exists as a result of development on the opposite side of Ongar Road.

* The study assesses the site as having 'significant separation reduction'.

In response, there is no reduction in the separation between Pilgrims Hatch and Brentwood, and they both form part of the Brentwood Urban Area.

* The study assesses the site as having a moderate relationship with a historic town.

In response, the site does adjoin Weald Country Park which is a Registered Park and Garden. However, Weald Country Park is not a historic town and therefore the assessment has unfairly considered the site.

These inaccuracies have led to the conclusion that the site has a high contribution to the purposes of the Green Belt. The weight to be given to this evidence in informing the Draft Local Plan is therefore diminished.

There is not clear or sufficient evidence to demonstrate that the housing trajectory for the following sites in Appendix 1 is justified as required by the Framework to demonstrate a site is deliverable. This undermines the evidence within Figure 4.2 Demonstrating Housing Provision which therefore results in Policy SP02 being ineffective and not justified.

R01 Dunton Hills Garden Village

It is noted that a Scoping Opinion has been submitted for R01. However, the Council has yet to reach a determination and it is understood that it does not intend to grant planning permission for any subsequent application until the adoption of the Local Plan.
Assuming the Plan is adopted in 2019/20 and a decision is taken shortly thereafter, this would give at best three years before the first 100 homes are completed on the site in 2022/23. No evidence has been provided to demonstrate the site is deliverable in accordance with the Framework, and one would expect a timetable with key milestones to reach a start date for construction and the completion of 100 dwellings.

Further, R01 is expected to achieve another 2,600 homes over the remaining 10 years of the Plan period (an average of 260 dpa). This average per annum is greater than the average identified in recent studies examining the delivery of large scale development. For instance, the Start to Finish Study (NLP, 2016) noted the annual average build for sites over 2,000 dwellings was 161 dpa. More recently the Letwin Review (Independent Review of Build Out, MHCLG, 2018) noted an average build rate of 6.5% of the total site for sites over 1,500. If the average was applied to R01, this would equate to 175dpa. No evidence is provided as to why a substantially greater build out rate will be achieved.
As evidenced by the length and detail of Policy R01, and the infrastructure requirements set out in the Plan, R01 is a complex site with a number of physical and policy constraints that need to be addressed. It is also a critical component of the housing supply and therefore the strategy to meet housing need. By way of example, if the start date for construction was delayed and the first 100 dwellings were not completed until 2024/25, this would result in 500 less dwellings being built within the Plan period. This equates to over a year worth of housing need not met.

In the absence of any evidence on delivery, Hallam Land Management do not believe the trajectory will be achieved.
R02 Land at West Horndon Industrial Estate

As it stands, the site is currently occupied by various commercial enterprises all of which would need to be vacated for the site to be developed in full. The Housing Trajectory (Appendix 1) assumes these uses are all relocated in order to facilitate the completion of 65 dwellings in 2021/22. There is no evidence the current occupiers have found alternative premises such that they could relocate their businesses within the next 12 to 18 months in order to enable completions in Spring 2021.

There is therefore not clear evidence that housing completions will begin on site within 5 years as required by the Framework to demonstrate deliverability.

Further, the estimated number of units achievable on the site is considered over-optimistic with a net density of 57 dwellings per hectare contrasting sharply with the established character of the West Horndon village. The final capacity of this site may therefore be less than suggested in the Local Plan.

Finally, given the close proximity of R01 and R02, evidence should be provided on market saturation and the ability of the level of housing completions to be achieved. The Housing Trajectory suggests at their peak in years 2026 to 2029, 365 dwellings per annum would be achieved in the A127 corridor from these two sites alone. This is a significant proportion of the annual housing need for the Borough (over 80%) being delivered in one location.

R03 Land North of Shenfield
There is no clear evidence that housing completions will begin on site within 5 years (2023/24) as required by the Framework to demonstrate deliverability.

Furthermore, the Trajectory assumes 155 dwellings to be completed in the first year of the development (2023/24). This is a significant rate of delivery for the first year of a development, and notably higher than other sites in Borough (e.g. R01 is 100 dwellings). The figure appears unrealistic in the absence of any evidence.

R04 & R05 Ford Headquarters and Council Depot

As it stands, Ford have stated an intention to move but there is no certainty over when this will occur. The Trajectory assumes 40 dwellings being completed in 2024/25. In the absence of any certainty on the timescales as to when the site will be available for development, placing reliance on this site delivering housing completions in this year of the Plan period (which could well fall within the first five years of the Plan period) is not sound.

R07 Sow and Grow Nursery, Ongar Road

This site is identified to have delivered 18 dwellings by April 2021. As the site is in the Green Belt, this will only be achievable if the Plan is to be adopted in 2019/2020. It is therefore questioned whether this site will deliver housing as quickly as proposed within the Housing Trajectory.

The Sustainability Appraisal must be reviewed and updated in light of changes that need to be made to the Draft Local Plan, and in light of new evidence presented to the Council as to the positive effects of development of Calcott Hall Farm, Brentwood.

These representations contain both general and specific concerns in relation to the Sustainability Appraisal, January 2019.

Sustainability Appraisal Process

The Sustainability Appraisal (SA) is an iterative process to help inform the stages of plan making and the key choices the plan must take in light of the findings. In this particular case, the SA has not informed plan making decisions but has responded to them. This is clearly evident from the narrative within the original SA prepared in October 2018 which appraised a different Draft Local Plan to that which is currently subject to consultation. Whilst the SA has been updated to reflect decisions taken regarding the Local Plan at the Extraordinary Council meeting in November 2018, the decision was not made in light of the SA of January 2019.

Establishing Reasonable Alternatives

As noted in representations submitted by Hallam Land Management Limited (HLM) in relation to Housing Need and Requirement, the minimum local housing need (LHN) is 452 dwellings per annum (dpa), based on the standard method, and taking into account 2014 Household Projections.

The SA has only assessed alternative strategic options for the distribution of growth that as a minimum meets the LHN within the Draft Local Plan (350 dpa). Other strategic options should now therefore be appraised which appraise higher levels of growth to reflect the higher level of LHN that now needs to be planned for.

Unmet needs from Neighbouring Authorities

As noted in representations submitted by HLM in relation to the Duty to Cooperate, the identified unmet needs of neighbouring areas have not been taken into account in establishing a housing requirement for Brentwood. The SA also recognises that there are unmet needs (box 5.2 and table 5.1), and notes that higher levels of housing growth would go some way to addressing these needs. Although the SA notes that there would be further environmental consequences of addressing unmet need from elsewhere, this would be inevitable given it is a higher level of growth requiring further land. However, this does not mean that a higher level of growth could be deemed unsustainable.
Additional Strategic Growth at Brentwood

Indeed, the SA concludes:

"A headline conclusion is that a strategy involving one or more strategic allocations within the A127 corridor performs well, relative to the alternative of supporting higher growth at Brentwood, in respect of a number of objectives. It does not automatically follow that a strategy involving higher growth at the Brentwood is relatively unsustainable overall; however, it is an indication. The appraisal has highlighted limited benefits to supporting higher growth at Brentwood, and some significant draw-backs, most notably in respect of 'air quality' and 'biodiversity', with significant negative effects predicted in both respects. However, the appraisal findings do reflect the merits of the particular package of sites assumed to deliver higher growth. There will be alternative packages of sites that perform better in certain respects."

As an example of a site that can perform better in certain respects, it will be noted from representations made in respect of the Site Allocations that Land at Calcott Hall Farm, Brentwood could have a positive effect on air quality and biodiversity as a consequence of the proposals for a Community Link Road and measures to enhance biodiversity and green infrastructure on site. Higher growth at Brentwood would not therefore automatically be appraised as unsustainable in the context of this site being allocated.

Furthermore, the SA also notes that in relation to Climate Change Mitigation, development around Brentwood urban area would be more sustainable than options elsewhere in South Essex where sustainable transport options are not available:

"In conclusion, options involving a concentration of growth along the A127 corridor perform best, along with Option 7, which is higher growth options that could feasibly reduce pressure for growth at locations to the east within South Essex where commuting by train to London is less attractive as an option."

The SA should therefore re-assess its appraisal of additional growth at Brentwood in light of the evidence presented by Hallam Land Management within its representations in respect of Calcott Hall Farm. In particular, evidence in relation to air quality, biodiversity, heritage, landscape and transport all impact on how the site should be assessed with the SA. The SA should be updated to reflect this further evidence in the same way evidence prepared to inform the appraisal of Dunton Hills Garden Village has been taken into account.