COVERING LETTER:

I am instructed by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to submit representations upon the Strategic Growth Options Consultation version of the Brentwood Borough Local Plan. The representations relate to Land at Hook Farm, Hook End.

The representations include the following documents:-
1. Planning statement, prepared by RPS
2. Site location plan dated February 2015
3. Consultation questionnaire

You should note that the representations seek to remove Land at Hook End Farm, Hook End, from the Metropolitan Green Belt and propose that the site be allocated for housing. The reasons for the representation is set out in the enclosed planning statement.

PLANNING STATEMENT:

INTRODUCTION

This planning statement has been produced in support of a representation made by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to Brentwood Borough Council in February 2015. The representation is made in response to the Brentwood Borough Local Plan 2015-2030: Strategic Growth Options Consultation.
Mr M Sidwell, Mr J Bowler and Mrs J Alderton put forward land at Hook End Farm, Hook End, as a potential housing site. The merits of Land at Hook End Farm (representation site) for housing are addressed in this planning statement.
The representation site is located centrally within the village of Hook End. Hook End falls within the administrative district of Brentwood Borough Council and is approximately 8km from Brentwood town centre. The representation site is approximately 9 hectares (22 acres) and is currently in agricultural use, used for grazing.

The site is largely surrounded by existing residential development. The site is bounded by Hook End Lane to the west and Hook End Road to the south. Residential development adjoins the representation site to the north and to the east. Also to the west is Hook End Farm, which falls outside of the representation site.

The site does fall within the Metropolitan Green Belt. However, for reasons set out in this statement, there are very good reasons for removing the site from the Green Belt and allocating the site for housing.

HOUSING BACKGROUND

It is absolutely clear from the Borough Council's work to date on their emerging Local Plan that there is an issue in terms of finding enough land to meet housing requirements. Prior to issuing this Strategic Growth Options document, the Council produced a Preferred Options version of the draft Local Plan, in July 2013.

The Preferred Options version of the Local Plan was only able to identify sites to accommodate 3,500 new homes. This figure, and the apparent shortfall of housing, attracted objections from neighbouring authorities, namely Basildon Council, Chelmsford Council and Thurrock Council. The thrust of the objections being that the Preferred Options document did not propose to meet all of Brentwood's housing need, and that these adjoining authorities would not accept any shortfall from Brentwood Borough within their own boundaries.

Under such circumstances, it is known that Brentwood Borough Council recognise that there is a real prospect that the Local Plan would be likely to be found 'unsound' at a Local Plan Examination in Public. Indeed, the consequences of failure to meet full housing need has become clearly evident in decisions both from the Secretary of State and Planning Inspectors, in relation to specific housing proposals and also other Local Plan examinations. Notably, local plans that did not meet full housing needs have been found 'unsound' on the basis that they do not conform with the National Planning Policy Framework (NPPF). Accordingly, Brentwood Borough Council have taken the decision not to proceed to the pre-submission stage with the Preferred Options version of the Local Plan.

Rather, the Borough Council have now decided to proceed with this Strategic Growth Options Consultation document, to which this representation relates. The Strategic Growth Options document provides an overview of the main views to be considered as part of the Local Plan process.

The Strategic Growth Options document recognises a number of important points:-
* The NPPF sets out that local planning authorities should objectively assess their market and affordable housing needs and provide for that in full.
* The capacity of all brownfield sites within urban areas in the Borough could provide for a maximum of 2,500 new homes. That means any housing provision above this would need to consider use of Green Belt land.
* The Council has commissioned a study to identify objectively assessed housing needs for the Borough, which concludes a requirement to provide for around 360 new homes per year. Over 15 years that comes to around 5,500 homes, some 3,000 more than what can be provided from brownfield sites in urban areas.
* It is also important to consider the need for a more affordable housing.

Accordingly, in order to meet its housing requirements, Brentwood Borough Council must release Green Belt land for housing. This representation and the request to remove Land at Hook End Farm from the Green Belt, to be replaced by a housing allocation, is submitted within this context.

Indeed, the Strategic Growth Options document does contemplate the possibility of releasing sites to the north of the Borough, which is made up of a collection of villages, including Hook End. For example, paragraph 2.15 of the document states that it is important to consider allowing villages to grow in order to provide for local need. The same paragraph recognises that sites on the edge of villages could be released. Those points add further support to the release of a site such as the representation site.

MERITS OF LAND AT HOOK END FARM

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. These characteristics are set out below:-

a) Relationship to Built-Up Area

Unlike many other potential Green Belt/housing sites, Land at Hook End Farm is sandwiched between existing residential development. To the north is residential development on the roads of Hook End Lane/Nursery Road/First Avenue. To the east is the residential development on the roads of Hook End Road/Spring Pond Meadow. To the west is Hook End Farm.

As apparent from the site location plan (submitted with this representation), the representation site forms a logical infill between the existing parcels of development that form the village of Hook End. Consequently, the effects of residential development on the representation site will be to consolidate development in Hook End, so as to form a logical and clearly defined settlement.

To the south and west are Hook End Road and Hook End Lane respectively, which are the two principal roads within the village for Hook End. Bus stops are located close to the representation site providing regular services to Brentwood and the surrounding area.

b) Lack of Constraints

Unlike many Green Belt and greenfield sites, the representation site is unconstrained in planning terms. Apart from its position in the Metropolitan Green Belt, the representation site does not contain any prohibitive planning designations. Notably, the representation site is not within a conservation area, a special landscape area, a landscape improvement area, a County wildlife site, a site of special scientific interest or a local nature reserve. These designations apply to a number of sites within Brentwood Borough, outside the built-up area. Furthermore, the representation site is not within a flood zone and does not comprise either Grade I or Grade II agricultural land. On the issue of agricultural land, the representation site has been used for many years for the grazing of horses and therefore is of little value in terms of agricultural quality.

c) Size of Representation Site

At 9 hectares (22 acres), the representation site is reasonably large. At this size, the site is indeed large enough to accommodate well in excess of 100 houses, which can make a meaningful contribution to the Borough's housing requirement. Furthermore, the site is large enough to accommodate other development that may be beneficial to residents of the village. For example, if necessary, it would be possible to accommodate some local shops, areas of open space and other community facilities, albeit such matters would need to be discussed with local residents, the Parish Council and other local groups. Additionally, the site could accommodate a range of house types, including affordable housing.

Accordingly, the release of Green Belt land in this case can bring forward significant benefits, unlike the release of much smaller sites.

d) Availability and Deliverability

The representation site is in the ownership of the three parties making this representation, with additional interests held by other family members. All parties fully support this representation and are content to promote the site for residential development. Furthermore, there are no physical or practical constraints in bringing forward development on this site. Accordingly, the site is available and deliverable and is able to make a significant contribution to meeting the Borough Council's housing requirements, in the short term, if necessary.

GREEN BELT CONSIDERATIONS

The Government's policy on Green Belt is contained in the National Planning Policy Framework (NPPF). Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances, but that any alteration of boundaries should be undertaken through the preparation or review of the local plan. In this case, the need to meet housing requirements is such an exceptional circumstance, which will be addressed through this review of the Brentwood Local Plan.

Importantly, paragraph 80 of the NPPF states that the Green Belt serves five purposes, which are as follows:-
* To check the unrestricted sprawl of large built-up areas
* To prevent neighbouring towns merging into one another
* To assist in safeguarding the countryside from encroachment
* To preserve the setting and special character of historic towns
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The representation site is considered against each of these purposes:-
i) The representation site is an infill site, bringing together two residential areas which form the village of Hook End. Development will not extend the limit of the existing built up area. Consequently, development on the representation site will not have the affect of creating 'sprawl'. In any event, the settlements of Hook End and neighbouring villages do not constitute 'large built-up areas.'
ii) For the reasons set out in (i) above, development on the representation will not have any effect in terms of encouraging the merging of neighbouring towns. Rather, the effect is to join two separate parts of the village.
iii) By the nature of the representation site in relation to the existing built-up area, development will not constitute 'encroachment' in to the countryside.
iv) There are no historic towns nearby and therefore this purpose has no relevance
v) It is clear from work undertaken by the Borough Council that there is not sufficient derelict and other urban land available to meet housing requirements. Consequently, Green Belt land needs to be released for housing and therefore protecting Green Belt sites will not have the desired effect of encouraging the recycling of derelict and other urban land.

Accordingly, it is clear that the representation site does not fulfil any of the five Green Belt purposes. For this reason alone, the representation site has merit and should be considered favourably as a potential housing site.

In addition to the five purposes of Green Belt, paragraph 85 of the NPPF, amongst other points, advises that local planning authorities should define the boundaries of the Green Belt, using physical features that are readily recognisable and likely to be permanent. On the basis of the site's relationship to the built-up area, development will enable a more logical Green Belt boundary to be drawn, which more probably recognises the features of the village.

SUMMARY AND CONCLUSIONS

The representation site is Land at Hook End Farm, Hook End. The representation site is located centrally within the village of Hook End, being largely surrounded by existing residential development. The site falls with the Metropolitan Green Belt.

Brentwood Borough Council have a shortfall of housing in relation to objectively assessed needs. In order to meet this shortfall, the emerging Local Plan recognises that Green Belt land needs to be used. One of the options considered is utilising sites on the edge of villages.

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. It is well related to the built up area, it is unconstrained in planning terms, it is available and deliverable, plus it is large enough to make a meaningful contribution to meeting housing need and in addition provide other facilities to the benefit of the community.

The representation site does not fulfil any of the five Green Belt purposes, as set out in the NPPF. Rather, on the basis of the site's relationship to the built up area, development will enable a more logical Green Belt boundary to be drawn.

In conclusion, the site is of little value in Green Belt terms and can more effectively be used for housing, assisting the Borough Council in meeting housing requirements.

COVERING LETTER:

I am instructed by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to submit representations upon the Strategic Growth Options Consultation version of the Brentwood Borough Local Plan. The representations relate to Land at Hook Farm, Hook End.

The representations include the following documents:-
1. Planning statement, prepared by RPS
2. Site location plan dated February 2015
3. Consultation questionnaire

You should note that the representations seek to remove Land at Hook End Farm, Hook End, from the Metropolitan Green Belt and propose that the site be allocated for housing. The reasons for the representation is set out in the enclosed planning statement.

PLANNING STATEMENT:

INTRODUCTION

This planning statement has been produced in support of a representation made by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to Brentwood Borough Council in February 2015. The representation is made in response to the Brentwood Borough Local Plan 2015-2030: Strategic Growth Options Consultation.
Mr M Sidwell, Mr J Bowler and Mrs J Alderton put forward land at Hook End Farm, Hook End, as a potential housing site. The merits of Land at Hook End Farm (representation site) for housing are addressed in this planning statement.
The representation site is located centrally within the village of Hook End. Hook End falls within the administrative district of Brentwood Borough Council and is approximately 8km from Brentwood town centre. The representation site is approximately 9 hectares (22 acres) and is currently in agricultural use, used for grazing.

The site is largely surrounded by existing residential development. The site is bounded by Hook End Lane to the west and Hook End Road to the south. Residential development adjoins the representation site to the north and to the east. Also to the west is Hook End Farm, which falls outside of the representation site.

The site does fall within the Metropolitan Green Belt. However, for reasons set out in this statement, there are very good reasons for removing the site from the Green Belt and allocating the site for housing.

HOUSING BACKGROUND

It is absolutely clear from the Borough Council's work to date on their emerging Local Plan that there is an issue in terms of finding enough land to meet housing requirements. Prior to issuing this Strategic Growth Options document, the Council produced a Preferred Options version of the draft Local Plan, in July 2013.

The Preferred Options version of the Local Plan was only able to identify sites to accommodate 3,500 new homes. This figure, and the apparent shortfall of housing, attracted objections from neighbouring authorities, namely Basildon Council, Chelmsford Council and Thurrock Council. The thrust of the objections being that the Preferred Options document did not propose to meet all of Brentwood's housing need, and that these adjoining authorities would not accept any shortfall from Brentwood Borough within their own boundaries.

Under such circumstances, it is known that Brentwood Borough Council recognise that there is a real prospect that the Local Plan would be likely to be found 'unsound' at a Local Plan Examination in Public. Indeed, the consequences of failure to meet full housing need has become clearly evident in decisions both from the Secretary of State and Planning Inspectors, in relation to specific housing proposals and also other Local Plan examinations. Notably, local plans that did not meet full housing needs have been found 'unsound' on the basis that they do not conform with the National Planning Policy Framework (NPPF). Accordingly, Brentwood Borough Council have taken the decision not to proceed to the pre-submission stage with the Preferred Options version of the Local Plan.

Rather, the Borough Council have now decided to proceed with this Strategic Growth Options Consultation document, to which this representation relates. The Strategic Growth Options document provides an overview of the main views to be considered as part of the Local Plan process.

The Strategic Growth Options document recognises a number of important points:-
* The NPPF sets out that local planning authorities should objectively assess their market and affordable housing needs and provide for that in full.
* The capacity of all brownfield sites within urban areas in the Borough could provide for a maximum of 2,500 new homes. That means any housing provision above this would need to consider use of Green Belt land.
* The Council has commissioned a study to identify objectively assessed housing needs for the Borough, which concludes a requirement to provide for around 360 new homes per year. Over 15 years that comes to around 5,500 homes, some 3,000 more than what can be provided from brownfield sites in urban areas.
* It is also important to consider the need for a more affordable housing.

Accordingly, in order to meet its housing requirements, Brentwood Borough Council must release Green Belt land for housing. This representation and the request to remove Land at Hook End Farm from the Green Belt, to be replaced by a housing allocation, is submitted within this context.

Indeed, the Strategic Growth Options document does contemplate the possibility of releasing sites to the north of the Borough, which is made up of a collection of villages, including Hook End. For example, paragraph 2.15 of the document states that it is important to consider allowing villages to grow in order to provide for local need. The same paragraph recognises that sites on the edge of villages could be released. Those points add further support to the release of a site such as the representation site.

MERITS OF LAND AT HOOK END FARM

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. These characteristics are set out below:-

a) Relationship to Built-Up Area

Unlike many other potential Green Belt/housing sites, Land at Hook End Farm is sandwiched between existing residential development. To the north is residential development on the roads of Hook End Lane/Nursery Road/First Avenue. To the east is the residential development on the roads of Hook End Road/Spring Pond Meadow. To the west is Hook End Farm.

As apparent from the site location plan (submitted with this representation), the representation site forms a logical infill between the existing parcels of development that form the village of Hook End. Consequently, the effects of residential development on the representation site will be to consolidate development in Hook End, so as to form a logical and clearly defined settlement.

To the south and west are Hook End Road and Hook End Lane respectively, which are the two principal roads within the village for Hook End. Bus stops are located close to the representation site providing regular services to Brentwood and the surrounding area.

b) Lack of Constraints

Unlike many Green Belt and greenfield sites, the representation site is unconstrained in planning terms. Apart from its position in the Metropolitan Green Belt, the representation site does not contain any prohibitive planning designations. Notably, the representation site is not within a conservation area, a special landscape area, a landscape improvement area, a County wildlife site, a site of special scientific interest or a local nature reserve. These designations apply to a number of sites within Brentwood Borough, outside the built-up area. Furthermore, the representation site is not within a flood zone and does not comprise either Grade I or Grade II agricultural land. On the issue of agricultural land, the representation site has been used for many years for the grazing of horses and therefore is of little value in terms of agricultural quality.

c) Size of Representation Site

At 9 hectares (22 acres), the representation site is reasonably large. At this size, the site is indeed large enough to accommodate well in excess of 100 houses, which can make a meaningful contribution to the Borough's housing requirement. Furthermore, the site is large enough to accommodate other development that may be beneficial to residents of the village. For example, if necessary, it would be possible to accommodate some local shops, areas of open space and other community facilities, albeit such matters would need to be discussed with local residents, the Parish Council and other local groups. Additionally, the site could accommodate a range of house types, including affordable housing.

Accordingly, the release of Green Belt land in this case can bring forward significant benefits, unlike the release of much smaller sites.

d) Availability and Deliverability

The representation site is in the ownership of the three parties making this representation, with additional interests held by other family members. All parties fully support this representation and are content to promote the site for residential development. Furthermore, there are no physical or practical constraints in bringing forward development on this site. Accordingly, the site is available and deliverable and is able to make a significant contribution to meeting the Borough Council's housing requirements, in the short term, if necessary.

GREEN BELT CONSIDERATIONS

The Government's policy on Green Belt is contained in the National Planning Policy Framework (NPPF). Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances, but that any alteration of boundaries should be undertaken through the preparation or review of the local plan. In this case, the need to meet housing requirements is such an exceptional circumstance, which will be addressed through this review of the Brentwood Local Plan.

Importantly, paragraph 80 of the NPPF states that the Green Belt serves five purposes, which are as follows:-
* To check the unrestricted sprawl of large built-up areas
* To prevent neighbouring towns merging into one another
* To assist in safeguarding the countryside from encroachment
* To preserve the setting and special character of historic towns
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The representation site is considered against each of these purposes:-
i) The representation site is an infill site, bringing together two residential areas which form the village of Hook End. Development will not extend the limit of the existing built up area. Consequently, development on the representation site will not have the affect of creating 'sprawl'. In any event, the settlements of Hook End and neighbouring villages do not constitute 'large built-up areas.'
ii) For the reasons set out in (i) above, development on the representation will not have any effect in terms of encouraging the merging of neighbouring towns. Rather, the effect is to join two separate parts of the village.
iii) By the nature of the representation site in relation to the existing built-up area, development will not constitute 'encroachment' in to the countryside.
iv) There are no historic towns nearby and therefore this purpose has no relevance
v) It is clear from work undertaken by the Borough Council that there is not sufficient derelict and other urban land available to meet housing requirements. Consequently, Green Belt land needs to be released for housing and therefore protecting Green Belt sites will not have the desired effect of encouraging the recycling of derelict and other urban land.

Accordingly, it is clear that the representation site does not fulfil any of the five Green Belt purposes. For this reason alone, the representation site has merit and should be considered favourably as a potential housing site.

In addition to the five purposes of Green Belt, paragraph 85 of the NPPF, amongst other points, advises that local planning authorities should define the boundaries of the Green Belt, using physical features that are readily recognisable and likely to be permanent. On the basis of the site's relationship to the built-up area, development will enable a more logical Green Belt boundary to be drawn, which more probably recognises the features of the village.

SUMMARY AND CONCLUSIONS

The representation site is Land at Hook End Farm, Hook End. The representation site is located centrally within the village of Hook End, being largely surrounded by existing residential development. The site falls with the Metropolitan Green Belt.

Brentwood Borough Council have a shortfall of housing in relation to objectively assessed needs. In order to meet this shortfall, the emerging Local Plan recognises that Green Belt land needs to be used. One of the options considered is utilising sites on the edge of villages.

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. It is well related to the built up area, it is unconstrained in planning terms, it is available and deliverable, plus it is large enough to make a meaningful contribution to meeting housing need and in addition provide other facilities to the benefit of the community.

The representation site does not fulfil any of the five Green Belt purposes, as set out in the NPPF. Rather, on the basis of the site's relationship to the built up area, development will enable a more logical Green Belt boundary to be drawn.

In conclusion, the site is of little value in Green Belt terms and can more effectively be used for housing, assisting the Borough Council in meeting housing requirements.

I refer to the above consultation, which runs until the 17th February 2015. Please accept this letter of representation as a formal response to the consultation.

Having spoken with Ms. Camilla James (Planning Policy Officer), I understand the current consultation is in response to a number of key issues which have arisen since the time of the draft Local Plan 2015-2030 'Preferred Options' consultation (July 2013), and the Borough Council is not abandoning 2013 'Preferred Options' document altogether. The current consultation is thus to be viewed in tandem with the Preferred Options document.

The reason for this letter is that we wish to comment on the Council's approach to identifying suitable travellers' sites.

Emerging Brentwood Borough Council Traveller policy

One of the issues requiring reconsideration in this consultation relates to 'planning for Gypsies and Travellers' (G&T), following production of a G&T accommodation assessment for all of the Essex local authorities (Page 6). The consultation goes on to state that "the Council will need to consider the conclusions of this in preparation of the next version of the Draft Local Plan".

Draft Policy DM28 of the 'Preferred Options' document sets out the Council's proposed strategy for identifying suitable sites for Gypsies and Travellers within the borough. The policy proposes to "meet the need for 44 permanent Gypsy and Traveller Pitches to 2030...the Council will identify Gypsy and Traveller sites to meet this provision, through a combination of allocations to ensure a five year land supply is maintained throughout the plan period, and the grant of planning permissions in accordance with the following criteria:

a) The site does not give rise to unacceptable harm to the Green Belt,
b) The site is well related to existing communities and accessible to local services and facilities, such as shops, primary and secondary schools, healthcare and public transport,
c) The site is serviced by a suitable access road,
d) The location would not result in unacceptable living conditions for its occupants,
e) The proposed accommodation would not harm the character and/or appearance of the area and/or result in unacceptable visual impact,
f) The site is located, designed and landscaped to minimise any impact on the environment".

Under the policy, the Council proposes to meet its entire need through the permanent allocation of some existing temporary sites and by providing the remainder as part of mixed-use development at one or more new strategic allocations.

We are concerned that the Council is only considering the housing needs of Gypsies and Travellers, not Travelling Showpeople. Page 8 of the document 'Planning Policy for Traveller Sites' (PPTS, March 2012) specifically excludes Travelling Showpeople from the definition of 'gypsies and travellers', so it is our assumption that the Council is not including Travelling Showpeople in the policy. This is further emphasised by the fact that draft policy DM28 only discusses the provision of Gypsy and Traveller 'pitches', which are by definition separate and distinct from Travelling Showpeople's 'plots' (again see PPTS, page 8). As it stands, where the draft Local Plan appears to us to be 'silent' on the provision of Travelling Showpeople's accommodation, the Council is vulnerable to the presumption in favour of sustainable development, as set out in Paragraph 14 of the NPPF, which confirms that where a plan is silent planning permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits.

Whilst we accept that the Essex Gypsy and Traveller and Travelling Showpeople
Accommodation Assessment (EGTTSAA) undertaken on behalf of the Essex Planning Officers Association by Opinion Research Services (ORS) in July 2014 suggests there is no identified 'need' for plots for Travelling Showpeople's accommodation within Brentwood Borough, PPTS is clear that Local Plans should include criteria-based policies, as a basis for decisions for any such application, should a proposal come forward nonetheless. This is in order to provide a fair and equal method of facilitating the traditional way of life of Travelling Showpeople.

We note that the EGTTSAA has identified a need to provide 183 additional plots, across Essex, in the period from 2013 to 2031. Both the NPPF and PPTS place a clear duty to cooperate on local planning authorities in both identifying and delivering Travelling Showpeople's accommodation to meet with this identified need. It may be that Brentwood Borough Council is required to provide accommodation which has been identified in one of the adjoining Boroughs. The Local Plan needs to provide a suitable policy framework for Travelling Showpeople as well as gypsies and travellers.

Furthermore, we are concerned that the draft policy, as currently worded, suggests that the Council will only support applications on suitable sites up to the point where a total of 44 pitches are provided. This approach is contrary to PPTS, for the same reason.

National Traveller Policy

PPTS provides Government policies for traveller sites (noting that the definition of 'traveller' in PPTS includes 'Gypsies and Travellers' and 'Travelling Showpeople'). The aim of this document is to "ensure fair and equal treatment for travellers, in a way that facilitates the traditional...way of life of travellers, whilst respecting the interests of the settled community".

Local planning authorities should ensure that their traveller policies, amongst other things, "promote peaceful and integrated co-existence between the site and the local community" and "reflect the extent to which traditional lifestyles (whereby some travellers live and work from the same location thereby omitting many travel to work journeys) can contribute to sustainability".

Suggested amendments to the Council's draft policy

Criterion (b) of draft Policy DM28 states that suitable sites will be "well-related to existing communities and accessible to local services and facilities". If our understanding is correct, and the Council is suggesting that only urban-edge sites will be considered suitable, this is inconsistent with PPTS.

Travellers' traditional way of life often involves living in rural areas. Indeed, we note the following from the EGTTSAA: "the majority of sites in Brentwood are in remote Green Belt areas...some of these Gypsy and Traveller residents have been situated in the Green Belt for many years and show a preference to live there rather than being located near towns and villages".

We would suggest the Council adopts a more holistic view of the requirements of travellers when considering the suitability of individual sites. PPTS confirms that it is perfectly acceptable to allocate/grant planning permission on rural sites for travellers, provided they do not dominate the nearest settled community (Paragraph 23). Indeed, when one considers the important requirement for local planning authorities to promote peaceful and integrated co-existence between a travellers' site and the settled community (Paragraph 11a), it could be the case that a rural location provides the most sustainable option for accommodating
travellers.

Referring specifically to Travelling Showpeople's sites, we consider an urban or urban edge site allocated for this purpose would also be an inefficient use of land, particularly given the difficulty the Council faces of providing 5,500 new homes over the plan period. Showmen's Guild Model (site layout) Standards (2007) confirm that a plot of over 0.5 acres (0.22ha) is normally required, when one accounts for the need for storage space of equipment, vehicles and machinery within individual plots. It is unlikely that Travelling Showpeople's accommodation could secure the values that would be necessary to acquire such land, unless this was provided by a developer through a planning obligation. Furthermore on the
point of the Council's suggested delivery mechanism as part of a strategic allocation, we see no policy basis on which the Council could reasonably justify requiring a developer to provide land for the purposes of travellers' accommodation, as part of any planning application for bricks and mortar housing, since it would be difficult to see how it would be required in order to make a proposed residential development acceptable in planning terms. It is therefore extremely risky to rely on this approach as a source of land for travellers' sites.

We would suggest that the Council should consider an additional category of land that could also form an appropriate supply of sites for gypsies and travellers. Previously developed sites in rural areas, including suitable sites within the Green Belt, may be an appropriate alternative option for allocation / granting of planning permission for the purposes of Travelling Showpeople's accommodation. Such sites would provide an efficient re-use of previously developed land, supported by both the NPPF and PPTS, and would meet with the above-stated requirements of promoting peaceful co-existence between traveller and settled communities and also reflecting the contribution of these sites to sustainable
development these sites make, by reason of the fact that residents often live and work on the same site. Clearly such policy would need to make it clear that such use of previously-developed land in the Green Belt must comply with other Green Belt policies.

We would be happy to discuss the matter further, should you have any queries in relation to my representation.