SO8 of the Strategic Objectives states that Brentwood Borough Council (BBC) will:

"Plan for housing that meets the needs of the Borough's population and contributes to creating inclusive, balanced, sustainable communities."

SO8 does not correspond with BBC's Spatial Strategy. BBC is not seeking to meet the housing needs of the Borough's population. BBC has rejected Alternative Growth Option 1 - 4,960 to 5,600 dwellings which is equivalent to the Borough's Objectively Assessed Need. The City Council objects to this approach (further detail to follow) however should BBC continue with its preferred Strategy, clearly this Strategic Objective should be removed.

Chelmsford City Council objects to Brentwood's Spatial Strategy which places the protection of the Green Belt and the quality and character of the landscape above meeting objectively assessed need. BBC has rejected Alternative Option 1 which makes provisions for 4,960-5,600 dwellings (331 to 373 homes a year) which is BBC's identified objectively assessed need. Instead BBC has chosen to make provisions for 3,500 new dwellings which equates to only 60% of its objectively assessed need. This means 40% of the housing needs for the Borough will not be met.

BBC's argument for not meeting objectively assessed need is the protection of the Green Belt which they consider to be the top priority for its Local Plan along with protecting the quality and character of the Borough. By their own omission, the protection of the Green Belt and ensuring there is adequate infrastructure to serve residents precludes the accommodation of the totality of market demand. In the context of a national housing shortage, the City Council does not consider that the protection of the Green Belt overrides meeting the full housing needs of Brentwood Borough. Furthermore, where is the evidence to justify this approach? The Plan indicates that the Landscape and Green Belt Assessment is forthcoming. This is unacceptable. This is a crucial piece of evidence base work that should be made available as part of the current consultation. As raised by the City Council and many other authorities in attendance at the Duty to Co-operate meeting on 29th July 2013, by not undertaking a Green Belt review BBC is leaving itself extremely vulnerable at Examination.

At the same Duty to Co-operate meeting Basildon Borough Council asked how BBC can allocate sites for development without the need for a Green Belt review. BBC responded saying that their approach was one of capacity - environmentally sensitive landscapes, capacity of transport infrastructure, provision of services and facilities, etc. However, again there is no published evidence to support this approach. Paragraph 2.29 of the Plan indicates that the Landscape and Green Belt Assessment, Transport modelling, Utilities Study and SHMA update are all forthcoming. The City Council would question how BBC has established their approach to the growth and development of the Borough over the Plan period without the relevant evidence? Paragraph 158 of the NPPF clearly states that 'each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.'

For the reasons set out above, the City Council strongly objects to BBC's Preferred Strategy which includes the possibility of looking to Chelmsford to meet a proportion of Brentwood Borough's unmet housing need. Brentwood Borough is not unique in their circumstances of being constrained by the Green Belt and other landscape characteristics. Chelmsford also has large areas of Green Belt and other environmental and infrastructure constraints which influence the delivery of its own housing requirements. Therefore, it is unreasonable and unacceptable for BBC to expect Chelmsford to make provisions for a proportion of their growth when Chelmsford itself has similar constraints. The City Council already is, and will be expecting to continue, to meet the needs of the City over the Plan period and beyond, without importing or exporting any other growth to/from neighbouring authorities.

The National Planning Policy Framework gives local authorities the ability to review Green Belt boundaries where it would meet objectives of the Framework and this includes meeting objectively assessed need. The City Council considers a Green Belt review is imperative and to meet the needs of the Borough some revisions to Brentwood Green Belt boundaries may be necessary.

West Horndon Allocation -

The City Council questions the processes and evidence base work underpinning the Strategic Allocation within West Horndon. The sites that make up the strategic allocation are two brownfield sites (Sites 20 & 21) and Green Belt land to the north of the industrial estates (Site 37). In absence of a Green Belt review, how has BBC concluded that Site 37 is the most appropriate location? Has it been tested against all reasonable alternatives?

Sites 20 and 21 -

Site 20 and part of Site 21 were identified in the 2011 SHLAA. Site 21 was not considered suitable for residential development on its own due to the nature of surrounding uses. These sites now form part of a comprehensive development, presumably as a result of discussions with the landowner. However, for both of these sites, the SHLAA identifies the need for remediation prior to development. Has this been properly investigated? Could this impact upon the deliverability?

Site 37 -

Site 37 was part of a larger site (G018) identified in the 2011 SHLAA. The development of the whole parcel of land put forward was not considered acceptable. It was considered that any development that provides for more than the local needs of West Horndon would need to be based on an agreed change in the role of West Horndon. This change has occurred as West Horndon has now been identified as a key location for growth to meet the Borough's housing needs. Site 37 is a proportion of G018. What considerations have determined the size and the extent of Site 37? The SHLAA states that contamination is unknown. Has this been investigated? The SHLAA also identifies that the costs associated with connection of the site to infrastructure and services are likely to be considerable. Could this affect the viability of the site? Furthermore, has work been undertaken to demonstrate that there will be appropriate infrastructure and services to support this allocation? Where is the infrastructure evidence to demonstrate that this site is in fact deliverable?

Remaining allocations -

Many of the sites identified are Council assets, i.e. Council-owned garages in the Borough, and are subject to further review by BBC. Assumed windfall sites also form part of BBCs housing targets. Generally, there appears to be significant uncertainty in many of BBC's allocations. This is concerning as BBC has already chosen not to meet its objectively assessed need and instead is unjustifiably, in the City Council's view, looking at neighbouring authorities to meet unmet need. There is a possibility that BBC's housing target could be further reduced because sites allocated in their Plan are not actually deliverable.

Crossrail -

The existing evidence on Crossrail suggests that the main economic benefits arising from the scheme, particularly for Brentwood Town and Station, will be an increased frequency of rail service serving Central London. In addition, journey times to destinations west of London Liverpool Street will be significantly improved. In turn, upgraded station facilities and more frequent rail services will provide opportunities for the expansion of businesses and the creation of new employment and housing sites in and around Brentwood Rail Station.

The City Council has concerns that the opportunities arising from Crossrail have neither been fully explored nor incorporated in BBC's Preferred Options Document. The Document acknowledges the benefits of Crossrail but does not have any relevant economic strategies or policies related to the scheme other than the provision of a 'Park and Walk' facility at Shenfield. Given the strategic importance of Crossrail and the economic benefits that it will deliver to London and the South-East, the City Council considers that BBC's Preferred Options Document should have dedicated policies that seek to drive development derived from the potentially substantial economic benefits that Crossrail will bring to the Borough, with a clear focus on Brentwood Town Centre.

West Horndon Allocation -

The City Council questions the processes and evidence base work underpinning the Strategic Allocation within West Horndon. The sites that make up the strategic allocation are two brownfield sites (Sites 20 & 21) and Green Belt land to the north of the industrial estates (Site 37). In absence of a Green Belt review, how has BBC concluded that Site 37 is the most appropriate location? Has it been tested against all reasonable alternatives?

Sites 20 and 21 -

Site 20 and part of Site 21 were identified in the 2011 SHLAA. Site 21 was not considered suitable for residential development on its own due to the nature of surrounding uses. These sites now form part of a comprehensive development, presumably as a result of discussions with the landowner. However, for both of these sites, the SHLAA identifies the need for remediation prior to development. Has this been properly investigated? Could this impact upon the deliverability?

Site 37 -

Site 37 was part of a larger site (G018) identified in the 2011 SHLAA. The development of the whole parcel of land put forward was not considered acceptable. It was considered that any development that provides for more than the local needs of West Horndon would need to be based on an agreed change in the role of West Horndon. This change has occurred as West Horndon has now been identified as a key location for growth to meet the Borough's housing needs. Site 37 is a proportion of G018. What considerations have determined the size and the extent of Site 37? The SHLAA states that contamination is unknown. Has this been investigated? The SHLAA also identifies that the costs associated with connection of the site to infrastructure and services are likely to be considerable. Could this affect the viability of the site? Furthermore, has work been undertaken to demonstrate that there will be appropriate infrastructure and services to support this allocation? Where is the infrastructure evidence to demonstrate that this site is in fact deliverable?

Remaining allocations -

Many of the sites identified are Council assets, i.e. Council-owned garages in the Borough, and are subject to further review by BBC. Assumed windfall sites also form part of BBCs housing targets. Generally, there appears to be significant uncertainty in many of BBC's allocations. This is concerning as BBC has already chosen not to meet its objectively assessed need and instead is unjustifiably, in the City Council's view, looking at neighbouring authorities to meet unmet need. There is a possibility that BBC's housing target could be further reduced because sites allocated in their Plan are not actually deliverable.

West Horndon Allocation -

The City Council questions the processes and evidence base work underpinning the Strategic Allocation within West Horndon. The sites that make up the strategic allocation are two brownfield sites (Sites 20 & 21) and Green Belt land to the north of the industrial estates (Site 37). In absence of a Green Belt review, how has BBC concluded that Site 37 is the most appropriate location? Has it been tested against all reasonable alternatives?

Sites 20 and 21 -

Site 20 and part of Site 21 were identified in the 2011 SHLAA. Site 21 was not considered suitable for residential development on its own due to the nature of surrounding uses. These sites now form part of a comprehensive development, presumably as a result of discussions with the landowner. However, for both of these sites, the SHLAA identifies the need for remediation prior to development. Has this been properly investigated? Could this impact upon the deliverability?

Site 37 -

Site 37 was part of a larger site (G018) identified in the 2011 SHLAA. The development of the whole parcel of land put forward was not considered acceptable. It was considered that any development that provides for more than the local needs of West Horndon would need to be based on an agreed change in the role of West Horndon. This change has occurred as West Horndon has now been identified as a key location for growth to meet the Borough's housing needs. Site 37 is a proportion of G018. What considerations have determined the size and the extent of Site 37? The SHLAA states that contamination is unknown. Has this been investigated? The SHLAA also identifies that the costs associated with connection of the site to infrastructure and services are likely to be considerable. Could this affect the viability of the site? Furthermore, has work been undertaken to demonstrate that there will be appropriate infrastructure and services to support this allocation? Where is the infrastructure evidence to demonstrate that this site is in fact deliverable?

Remaining allocations -

Many of the sites identified are Council assets, i.e. Council-owned garages in the Borough, and are subject to further review by BBC. Assumed windfall sites also form part of BBCs housing targets. Generally, there appears to be significant uncertainty in many of BBC's allocations. This is concerning as BBC has already chosen not to meet its objectively assessed need and instead is unjustifiably, in the City Council's view, looking at neighbouring authorities to meet unmet need. There is a possibility that BBC's housing target could be further reduced because sites allocated in their Plan are not actually deliverable.