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

The Plan's housing need should be amended to cover at 15 years from adoption. Realistically, we expect that an additional 2 years' worth of housing may be required to support a plan period up to 2035. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Allocating further sites for housing, like sites at Hanging Hill Lane, would provide for additional housing delivery.

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

The Plan's housing need should be amended to cover at 15 years from adoption. Realistically, we expect that an additional 2 years' worth of housing may be required to support a plan period up to 2035. Moreover, in respect of the fact that the authority is predominantly Green Belt, even if the plan period is extended until 2035, policies should account for potential development needs beyond this period. Allocating further sites for housing, like sites at Hanging Hill Lane, would provide for additional housing delivery.

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

The suggested inability of the plan to ensure a consistent five-year supply is not consistent with national policy. Land at Hanging Hill Lane, could cater to this need.

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

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

Land at Hanging Hill Lane should be allocated in Hutton to ensure the sustainable
growth of the settlement, and to ensure the soundness of the Local Plan.

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

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

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