Summary of comments These Representations are submitted to Brentwood Borough Council, on behalf of Tesco Stores Limited (who are the freeholder of land currently occupied by Hopefield Animal Sanctuary, Doddinghurst Road, Brentwood), in response to the Draft Local Plan Preferred Site Allocations Regulation 18 Consultation published in January 2018. This document provides our comments to the Draft Local Plan and makes the case for housing-led development at the Hopefield site. Our objective is to achieve a Housing-Led Allocation in the Local Plan (Reg 19 Consultation). Following the Council's sequential approach to identify sites, the Hopefield site represents a sustainable location for housing. It is situated at the heart of the A12 Corridor, adjoins the Brentwood urban area, and is close to the town centre, railway stations, bus stops and local schools and healthcare. The Council even considers the A12 Corridor as one of three potential locations for strategic growth, which demonstrates its sustainability credentials are not in question. Given that urban areas and brownfield site capacity has been exhausted, it is extremely likely that Brentwood will have to release additional land from the Green Belt for housing to meet their local development needs, in accordance with adopted and emerging national policy. In this respect, the Hopefield site is well defined by defendable boundaries and proposals for reinforced landscape planting will strengthen the eastern edge. Importantly, the proposals also maintain the existing role and function of the Green Belt and safeguard the green wedge / critical countryside gap between Brentwood and Shenfield urban areas. The Hopefield site is able to deliver up to 450 new homes which would contribute significantly towards helping the Council meet its local development needs. Beyond housing proposals, the indicative masterplan is also able to deliver a range of unparalleled community benefits: The proposals secure the long-term future of Hopefield Animal Sanctuary which is recognised as a valuable community asset. Hopefield Animal Sanctuary support the Tesco proposals for housing-led development including relocation of the sanctuary on-site and re-provision of grazing land off-site. The proposals provide a new point of access between Doddinghurst Road and Sawyers Hall Lane to significantly improve accessibility and connectivity from Brentwood urban areas to the north and west, including Pilgrims Hatch, to the six schools along Sawyers Hall Lane. This is achieved through the provision of a walk through which connects Doddinghurst Road to the northern end of Sawyers Hall Lane plus a pick-up and drop-off point with car park for 50 spaces. This element of the proposal would in turn lead to a range of related benefits: Improved accessibility to schools along Sawyers Hall Lane for pupils, parents, staff and visitors; Promoting walking and cycling to help address health and wellbeing issues; Less reliance on private car (in particular for local school trips and other local trips); Reduced congestion along Sawyers Hall Lane and Doddinghurst Road; Improved conditions in terms of safety, especially along Sawyers Hall Lane; Alleviation of some traffic congestion to allow for existing schools to expand to help meet future local needs, and achieve their own development and education ambitions. As part of discussions with local stakeholders, St Thomas School have told us of ambitions to expand by further 1/2 form at all levels and that our proposals would help support this aspiration to expand. These proposals are based on our detailed analysis of the local area and meetings with key stakeholders including schools located along Sawyers Hall Lane. Feedback to date has been positive and discussions are on-going. Our comments demonstrate that the Draft Local Plan is unsound, when tested against the National Planning Policy Framework (2012) as it is not positively prepared, not justified, not effective and not consistent with national policy. Most recent Government advice contained in the Draft NPPF (2018) issued on 05 March 2018 requires local planning authorities to adopt the Standard Methodology for calculating housing need. For Brentwood, this would increase the housing target from 380 dpa to 454 dpa, representing an extra 1,480 dwellings over the plan period from 2013-2033. As the Draft Local Plan only identifies supply for 8,263 dwellings this means the Council must identify land for an additional 817 dwellings. It therefore is our view that to address the shortcomings in plan preparation i.e. the evidence base is incomplete and not up to date (e.g. highways evidence is dated 2016) and the current assessment does not consider all the potential sites in a consistent or comprehensive manner. Notably the Council's site assessment does not consider each site on an individual basis and it only considers a limited set of sustainability criteria, with no regard to site specific proposals or benefits, so to identify extra housing sites the Council must restart the sites assessment process. We recommend that the Hopefield site is allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. Overall, the proposals at Hopefield would help address a range critical planning issues which Brentwood Borough Council is currently facing. We would be happy to further discuss proposals with the Council and stakeholders to towards achieving a Housing-Led Allocation. General Comment In summary, at this stage of the plan-making process, we consider that the 2018 DLP is unsound. The 2018 DLP, including supporting evidence base, is not positively prepared, justified, effective or consistent with national policy especially in respect of Paras.11, 36, 61, 74, 117, 134, 137 and 209. This is a serious matter and we recommend that Brentwood Borough Council thoroughly reviews the approach to plan-making in order to prepare a sound Local Plan. Housing Need - DLP ref: Housing Need - Paras. 38-45, and Para.67 The NPPF (2012) Para.14 and Draft NPPF (2018) Para.11 clearly state that LPAs should plan to meet local development needs and the Draft NPPF (2018) Para.61 states that such needs should be calculated using the Government's standard methodology. We therefore recommend that the Council plans to fully meet its local development needs, based on the Government' standard methodology, with sufficient flexibility to respond to rapid change. We recommend that the 2018 DLP increases its planned housing target from 380 dpa to 454 dpa. Over the 20 year plan period from 2013-2033 this increases the overall target from 7,600 dwellings to 9,080 dwellings. Therefore the target must increase by 1,480 dwellings. We recommend that the Council recognises that the standard methodology approach offers a range of local and national benefits. It ensures a consistent and fair approach is applied by all LPAs across the country, and it will help work towards achieving the national objective to provide 300,000 net housing additions each year in England. The application of the standard methodology approach, alongside duty-to-cooperate, should be considered by the Council as paramount importance to provide the basis of a sound Local Plan. By adopting this approach the Council would also save a disproportionate amount of time discussing objectively assessed need at the Local Plan examination. Overall we do not consider that Brentwood Borough Council has any excuse not to adopt the standard methodology approach for the purposes of plan-making. We recommend that the new Local Plan must plan for 9,080 dwellings rather than the 7,600 (currently set out in the 2018 DLP). This approach must be adopted for the new Local Plan to be sound. We recommend that the Council considers unmet needs of surrounding LPAs within the Local Plan. Site Assessment and Sustainability Appraisal - DLP ref: An Evolving Evidence Base - Para. 14-17 - DLP ref: Site Allocations - Evidence Base ref: Sustainability Appraisal - Evidence Base: Sustainability Appraisal - Reasonable Alternatives Briefing Note - Evidence Base: Preferred Site Allocations Site Selection Methodology and Summary of Outcomes -Working Draft We recommend that the site assessment process is revisited and undertaken in a consistent and comprehensive manner, and based on a complete evidence base. The Sustainability Appraisal scoring system completely fails to recognise the site specific benefits of the proposals at Hopefield. We recommend that a new site assessment is undertaken in light of the unique site specific factors relating to securing the future of Hopefield Animal Sanctuary and improved accessibility (including range of impacts relating to safety, school access and expansion). We consider that a new assessment would elevate the site to a position where site allocation would be fully justified. Finally, as previously reported to the Council, the Sustainability Appraisal, refers to the site at Hopefield as two sites: "024A" and "024B". This approach does not reflect the actual site opportunity, which we are promoting and which is under a single ownership. We recommend that Brentwood Borough Council recognise the site at Hopefield as a single site, not two sites. This point was raised in our 2015 and 2016 Representations but the Council still fails to recognise this matter. Overall we recommend that the whole site assessment (to inform the 2018 DLP) is undertaken again because the approach adopted by the Council is not sound. We recommend that the revised assessment is undertaken in a comprehensive and consistent manner so that all factors relevant to each site are acknowledged and all sites are considered individually. As a result of the new site assessment, we recommend that the site at Hopefield is identified as a Housing-Led Allocation. Spatial Strategy and Sequential Approach - DLP ref: Spatial Strategy - Paras. 29-37 - DLP ref: Settlement Hierarchy and Accommodating Growth - Para. 75 As discussed under Housing Need above, in accordance with national policy, we recommend that that Council plans for 454 dpa, not 380 dpa. We recommend as a result that additional sites for housing must be identified by the Council so that it can fully meet its local development needs. This approach must be adopted for the new Local Plan to be sound. Assuming that no more or a limited amount of land within the urban area can be identified and there is no or limited scope to accelerate delivery or increase densities, we recommend that Green Belt land represents the only solution to deliver more houses. We recommend that the Council recognises that the Hopefield site is part previously developed land as it contains a large single dwelling house. Further to this, the principle of activity is long established on site (through the animal sanctuary use and works and visitors on-site). In addition, the site is well-served by public transport. It is 2.2 km from Brentwood station and within 400m of four bus stops. We support transport corridor-led growth, which is promoted in the 2018 DLP, especially long the A12 Corridor. The sustainability credentials of this general location for growth are not in question. Furthermore, the settlement hierarchy set out in the 2018 DLP identifies Brentwood as the Main Town (in Category 1). Therefore we recommend that an additional sources of housing supply be identified at or adjoining Brentwood urban area. We recommend that the transport corridor led approach to new growth is preferred over further pursuing village growth in rural areas. Overall we recommend that an additional site within the A12 Corridor is bought forward for housing-led development. Given its location, adjoining Brentwood and in the heart of the A12 Corridor, combined with its PDL characteristics plus the unique benefits of the proposals relating to securing the long-term future of Hopefield and improving local accessibility and connectivity, the site at Hopefield must be identified as a Housing-Led Allocation in the new Local Plan. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. Housing Supply / Housing Led Allocations - DLP ref: Housing Supply - Paras. 51-56 - DLP ref: Housing Led Allocation - Paras. 57-68 Based on the fact that the 2018 DLP has identified a supply of 8,263 dwellings, to achieve the Government's standard methodology target of 454 dpa, we recommend that the Local Plan identifies land for an additional 817 dwellings. In terms of Green Belt sites for housing, and in respect of 2018 DLP Para. 67, we consider that the Hopefield site can provide "defendable" edges. Overall we recommend that the Hopefield site is added to Figure 9 of the 2018 DLP under "Green Belt Land - Edge of Brentwood Urban Area." The site has the capacity to deliver up to 450 new homes. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. The 2018 DLP does not include any comment on the five year housing supply position. The latest publication of a five year housing land supply assessment is from 2016. At present we consider that Brentwood cannot demonstrate a five year housing land supply and therefore is not fully aware of its pipeline or trajectory of future housing sites. Without this we consider the 2018 DLP is not flexible or cannot respond to any changes in housing delivery. Therefore the 2018 DLP is not sound because it is not positively prepared or consistent with national policy. We recommend an up to date five year housing land supply is prepared by the Council. Transport and Infrastructure Plan - DLP ref: Transport - no references - DLP ref: Infrastructure Planning - Para. 18 - DLP ref: Infrastructure Planning - Para. 76 - DLP ref: Primary Schools - Para 77-87 We consider that the 2018 DLP does not propose enough to improve the primary school provision situation. Therefore we recommended that the Hopefield site is proposed as a Housing-Led Allocation in the new Local Plan because it's allocation would contribute towards helping local schools expand. Vision - DLP ref: Vision - Para. 26 We recommend that the vision is not changed but the Local Plan is amended so that the Council plans to meet its local development needs of 454 dpa, not 380 dpa. This required the Local Plan to increase the housing target to 9,080 dwellings over the plan period, and based on an existing identified housing supply of 8,263 dwellings identify land for an additional 817 dwellings. Plan-Making and Evidence Base - DLP ref: Plan-Making - Para. 1 - DLP ref: An Evolving Evidence Base - Para. 7 Overall, the plan-making approach for the Brentwood Local Plan is not sound and is not justified or consistent with national policy. We recommend that the plan-making process is revisited by Brentwood Borough Council and that the new Local Plan is based on an up to date evidence base, justified site assessment and that the whole preparation process is consistent with national policy. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. We recommend that the Green Belt Review is undertaken to inform the new Local Plan, especially in relation to preferred site options for growth which are proposed to be released from the Green Belt. Therefore the site assessment process can only commence once an independent and objective Green Belt Review has been completed. Meeting Strategic Objectives - DLP ref: Para. 28 We note that the 2018 DLP sets out a total of 23 strategic objectives, of which 12 are new since the previous 2016 DLP. The site we are promoting at Hopefield contributes significantly towards the objectives (as detailed below in Table 1). Therefore we recommend that the Hopefield site is proposed as a Housing-Led Allocation the Local Plan Regulation 19 document. In conclusion, we recommend that the Hopefield site is identified as a Housing-Led Allocation because the proposals for the site make a major contribution toward the Council's strategic objectives. The allocation of the site would make a significant contribution towards helping meet local development needs which is required to make the Local Plan sound. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. (See attached for further evidence).