Whilst consolidating the Pre-Submission Plan's Green Belt policies into a single strategic policy (MG02) gives these policies greater prominence in the plan, the fine detail encapsulated in Policies NE10-NE15 of the Pre-Submission Plan has been lost. To delete these policies on the basis that they are "Covered by other policies in the Plan" leaves the Council's position unclear on the exceptions allowed by paragraph 149 of the NPPF, and is unhelpful given that the matters dealt with in Policies NE10-NE15 are not covered by other policies in the plan.

MM5 states that "The vitality of rural communities to ensure villages grow and thrive, in line with paragraph 78 of the NPPF, was a key consideration in defining the spatial strategy", but this aspiration is not borne out by the proposed modifications to the Plan. For the record, paragraph 78 of the NPPF states:

"In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this."

The government's position is clear: local planning authorities should support opportunities to bring forward rural exception sites to meet identified local needs (with no distinction drawn between Green Belt and non-Green Belt locations). Yet the proposed modifications remove the only route open to communities and landowners to bring forward affordable housing for local community needs i.e. schemes which accord with paragraph 149 of the NPPF (the paragraph 72 route being ruled out by note 36 which excludes Green Belts).

In the Pre-Submission Plan, Policy NE10 specifically allowed for limited affordable housing for local community needs in accordance with other policies set out in this Plan, reflecting the approach set out in paragraph 149 of the NPPF. As modified, the Plan contains no support for exception sites (whether in the Green Belt or not), in conflict with paragraph 78 of the NPPF. This is a particular concern given that the Pre-Submission Plan identifies at paragraph 8.79 that 89% of the borough is designated as Green Belt, giving Brentwood the sixth highest Green Belt area in England, meaning the only realistic option for exception sites in the Borough is the Green Belt.

Although the Plan insets the 11 largest villages from the Green Belt, there are numerous smaller villages in the borough, with MM5 identifying that "Brentwood borough is characterised by a central urban core and a number of scattered villages north and south of this main urban core. This has given rise to its principal character as a 'Borough of Villages'." It is therefore very disappointing that the Plan as modified offers no support for schemes aimed at meeting the housing needs of the smaller villages in the borough.

One possible interpretation of Policy MG02 is that, despite making no reference to Paragraph 149 of the NPPF, it offers implicit support for rural exception sites with the words: "All development proposals within the Green Belt will be considered and assessed in accordance with the provisions of national planning policy". However, paragraph 9(f) of the NPPF offers support only for "limited affordable housing for local community needs UNDER POLICIES SET OUT IN THE DEVELOPMENT PLAN [my emphasis] (including policies for rural exception sites)".

In other words, the Local Plan must contain a positively-worded policy on rural exception sites for a scheme to qualify as an exception. The deletion of policy NE10(f) from the Pre-Submission Plan removes the required positively-worded policy, implying that this exception no longer applies in Brentwood's Green Belt.

This change in emphasis is reinforced by discussions with officers, who have confirmed that it is the Plan's intention, as modified, to preclude rural exception sites in the Green Belt, on the basis that the housing allocations in the Plan will meet the Borough's affordable housing needs in full over the plan period, through the mechanism of each site contributing a proportion of affordable housing. Such an approach is fundamentally flawed, for two reasons:

* house prices in Brentwood are high and rising, pricing many local people out of the housing market, as Strategic Housing Market Assessment Part 2 demonstrates. It is therefore unwise to assume that housing need can be met in full over the plan period, without the fallback option of rural exception sites, in the event that unmet housing need arises over the plan period.

* the allocated housing sites are located predominantly in and around the town of Brentwood, with smaller allocations in the larger villages. By contrast, the smaller villages are spread throughout the borough, in many cases some distance away from allocated housing sites. The aim of the NPPF is to meet local housing needs where they arise, in order to bolster smaller settlements and ensure that local residents can remain in their village rather than being forced to move elsewhere. It runs completely contrary to government advice to plan to meet rural housing need only in the largest settlements in the borough.

As drafted, therefore, the main modifications are in conflict with paragraph 78 of the NPPF, and the Plan is unsound.