I've looked through the planning document as carefully as I can and I don't see any reference to parking provision. Since a number of the brownfield sites designated within Brentwood are on existing car parks, and that there is already a serious shortage of street parking in the town, what provision has been made for all the extra cars which will be generated by the development?

The a127 corridor is currently very heavily used, by increasing the housing and employment in this area will require very careful consideration

Page 7 Infrastructure Planning paragraph d: we welcome the fact that green infrastructure planning is one of the key strategic priorities; however, we would like to see the aspiration for access for all to such green infrastructure embedded within the key strategic priorities. We therefore suggest that this paragraph is reworded thus: 'improving the quality, range, connectiveness and accessibility of the Borough's natural green assets...'

There has been no identification of the additional infrastructure needed in order to cope with increased housing. The local areas cannot deal with traffic at present nor can the train lines or station at Shenfield.

I support enhancing green infrastructure networks. However, today people cannot walk or cycle safely to Weald Park or Thorndon Park. Also crossing, either the A12 and A127 using footpaths is highly dangerous. Bridges should be considered in the light of increased population forecasts.

the ldp indicates that three car parks in brentwood town centre are to be developed for housing.
i see no suggestion that replacement car parks are being developed.
the additional housing in both the town centre and environs will increase, not decrease, the need for town centre car parks.
i see no indication that local roads will be developed to accommodate the increased traffic caused by 7000 more homes (& the families occupying them).
this seems to be a rather less than holistic approach to planning.

Infrastructure Planning -
General education comments -
Page 7: paragraph 19 - As recognised in this paragraph, sufficient work has yet to be undertaken to accurately assess the impact of growth on education infrastructure. It is critical that this takes place whilst the Regulation 19 plan is prepared. A full scenario test identifying the location of and likely unit mix of all allocation sites and permitted development is needed. BBC will need to provide ECC with this information in line with section 3.4 of our 'Planners' Guide to School Organisation'. Once ECC has received this information and completed the assessment, a realistic IDP for education can be prepared and agreed. Discussions with ECC are therefore vitally important to ensure that this growth is planned, phased, properly funded and delivered in an efficient and coherent manner. For information relevant sections of the ECC response to the 2016 Draft Local Plan are included below.

Where growth is to be located it will be essential to ensure the delivery of education facilities is undertaken in a timely and phased manner. Additional school places can be provided either by the expansion of existing schools/ academies or the opening of new "free schools" or academies. Existing schools and academies can only be expanded if they have sufficient site area to do so. In many cases existing school/ academy sites are restricted and cannot, therefore, be expanded easily without the provision of additional land. This is often impracticable in urban areas as schools are located within the existing built up area. In many rural areas schools are on restricted sites but there may be land adjacent to the existing school/ academy site that could be utilised to enable expansion.

Whilst faith schools and academies may have sufficient site area to expand this would need the agreement of the Anglican Diocese of Chelmsford/Roman Catholic Diocese of Brentwood/ the academy trusts responsible for these schools/ academies. This is particularly relevant as a significant proportion of schools/ academies located within the borough are faith schools.

As indicated, ECC can identify those locations, particularly in rural areas, where scope exists to expand existing schools/ academies without the provision of additional land. In those areas where expansion opportunities are limited, sites for new schools should be identified within or close to the proposed developments. If existing schools cannot be expanded or growth is insufficient to provide a new school, it will be necessary for ECC to seek contributions from developers towards meeting the cost of providing transport between homes and schools.

The scale of expansion of existing schools/academies is also important. The majority of primary schools are organised in classes of 30 pupils to comply with infant class size limits. It is easier, more cost effective and better from an organisational perspective to expand primary schools by a full form of entry (30 pupils per year group) or half a form of entry (15 pupils per year group) than it is to accommodate a smaller number of pupils. On this basis it is often easier and more cost effective to ensure that there is a sufficient supply of school places for larger scale housing developments than it is for relatively small scale developments, particularly in rural areas. Sustainable home-to-school travel and transport and the location of development sites to ensure viability to fund schools will need further consideration.

Highways and transportation -

The infrastructure section of the consultation document contains no information on highway and transportation matters. As referred to earlier in this Appendix, this is a fundamental gap, especially in the wider South Essex context and on regional issues such as the A127. ECC is clear that further modelling work needs to clearly illustrate the local and cumulative impact on the local and strategic transport network, to demonstrate that the proposed spatial strategy is the most appropriate, and to identify any infrastructure and/or mitigation measures which would be required.

BBC will need to engage with ECC on this work, and allow for review mechanisms to be put in place, to allow ECC to be satisfied with the modelling approach, assumptions, and outcomes. Until this appropriate work has been undertaken, and ECC has reviewed and confirmed satisfaction of the work, it is recommended that ECC continues to withhold support for the Draft Plan.

ECC supports the aspiration to improve the public realm and circulation arrangements around Brentwood and Shenfield stations given the impact from Crossrail. ECC advises that similar improvements may be necessary at Ingatestone and West Horndon stations to encourage sustainable travel and mitigate the potential growth. For all stations, park and walk, or park and ride sites, are potential tools that could form part of an overall parking and access strategy.

BBC should ensure policy requirements stipulating that a high quality digital infrastructure is installed from the outset of any new developments (residential and non-residential).

ECC advise that BBC should give consideration to enhanced infrastructure to serve strategic locations such as Brentwood Enterprise Park and Dunton Garden Village.

Early Years and Childcare (EYCC) -

The consultation document makes no reference to the requirements for EYCC provision arising from the planned growth in the Plan period. ECC is responsible for meeting certain statutory responsibilities relating to the provision of EYCC services within BBC. This includes supporting EYCC providers with information, advice, guidance, training and a duty under the Childcare Act 2006 to ensure there is sufficient and accessible high quality early years and childcare provision. The Essex Early Years and Childcare Strategy 2015-2018 sets out ECC's strategic objectives and priorities relating to early years and childcare services across Essex.

An assessment of EYCC requirements will need to take place and those requirements will need to be included in appropriate policy and site allocations (both housing and employment) where growth generates need. Once ECC has received this information and completed an assessment, a realistic IDP for EYCC can be prepared and agreed. Discussions with ECC are therefore vitally important to ensure that this growth is planned, phased, properly funded and delivered in an efficient and coherent manner.

ECC also recommend that paragraphs 18a and 76 of the consultation document make specific reference to EYCC provision.

A high level assessment of the preferred housing site allocations detailed in the consultation document using the most up to date sufficiency data (summer 2017) has identified the need for the following: (see attached table)

Employment sites will be affected by the number of employees, and the amount of floorspace on each site. ECC therefore seeks further information in relation to proposed employee numbers and floorspace in order to provide comment in relation to the employment sites.

It is also important to note that the existing capacity has been considered by ward rather than settlement, and hence the available capacity by setting has not been translated into the number of dwellings that each settlement can accommodate. Until BBC provides ECC with a further breakdown as to exact numbers and locations, the figures could be subject to change.

It should also be noted that from September 2017 the Extended Funding Entitlement Offer (EFE) was introduced, which could also affect the calculations of the requirement figures.

BCC will need to provide ECC with all the relevant information in order that ECC can undertake a further assessment of the potential delivery and resource requirements for accommodating anticipated childcare requirements, to inform the pre submission Plan, and its supporting IDP.

Post 16 Education / Skills -

ECC advises that there is a requirement for students to stay in a form of education and training until they are at least 18 years old. The consultation document makes no reference to such provision, and ECC recommends that BBC have consideration to the full range of opportunities for the provision of such education, including apprenticeships, in the Plan making process.

The consultation document makes no references to how the Local Plan will address the issue of improving the skills base in the Borough. The Essex Employment and Skills Board identifies 7 priority sectors which are set for growth in Essex and are suffering skills shortages in advanced manufacturing and engineering, care, construction, financial and related services, health, IT, digital and creative, and logistics. ECC recommends that BBC consider how the Plan can address this matter.

ECC also recommends the plan makes reference to the importance of the use of employment and skills plans, particularly in relation to the large scale developments proposed, such as DHGV.

Minerals and Waste -

ECC is the Mineral and Waste Planning Authority for Essex. The Mineral Local Plan (2014) and Waste Local Plan (2017) form part of the development plan in Brentwood and therefore should be referenced as such within the opening pages of the Draft Plan.

ECC's response to the draft Local Plan in 2016 remains relevant and is attached as Appendix 2.
 
Minerals -

The Essex Minerals Local Plan (2014) (MLP) provides up-to-date planning policy for minerals development in Essex until 2029. In particular, it gives certainty as to the location of future minerals development by identifying sites and locations for the extraction of mineral deposits. There are also procedures to reduce the demand for primary mineral use, recycle more aggregate and safeguard mineral resources, reserves and important facilities.

There are deposits of sand and gravel within Brentwood Borough which are subject to Policy S8 Safeguarding Mineral Resources of the MLP. In line with national planning policy, Policy S8 identifies a Mineral Safeguarding Area (MSA) which covers large areas of the County where surface development will be resisted unless evidence can be provided to confirm that the resources are not viable/suitable for prior extraction.

There are areas around the urban area of Brentwood that are covered by a MSA for sand and gravel. In 2016, a high level assessment concluded that some proposed allocations in the Draft Local Plan fell within MSAs for sand and gravel. Now that new site allocations are proposed, it is necessary for mineral safeguarding matters to be thoroughly considered prior to inclusion in the Pre Submission Plan. ECC has provided assistance to all other Essex LPA's in relation to their Local Plans in this respect, by running a GIS based assessment process and identifying text for inclusion in site allocation policies where necessary.

It is essential that the preferred site allocations included in the Draft Local Plan are considered in respect of their mineral safeguarding implications. A GIS layer of the preferred sites should be provided to the ECC Minerals and Waste team as soon as possible to enable this assessment to take place.

Waste -

ECC is the waste planning authority for the Borough, and is responsible for preparing planning policies, and also for assessing applications for waste management development. The Essex and Southend-on-Sea Waste Local Plan (2017) (WLP) is a statutory Development Plan which should be read alongside the Draft Local Plan. It sets out where and how waste management developments can occur, and is the planning policy against which waste management development planning applications are assessed. The WLP does not allocate any strategic waste management allocations in the Borough. The WLP also identifies Areas of Search to meet the need for additional small scale waste management facilities. It identifies two Areas of Search within Brentwood Borough. These Areas of Search are existing industrial estates at Childerditch Industrial Estate and West Horndon and are located away from residential and other uses sensitive to amenity impacts such as schools, retail, leisure and office development. The WLP seeks to focus any new proposals for waste management facilities, which support the local housing and economic growth, within these Areas of Search.

The Brentwood Local Plan should refer to ECC's role as the Waste Planning Authority and to the adopted WLP. The draft Local Plan 2016 contained limited reference to waste management facilities, and in particular advice for their provision in the proposed Development Management Policies. Some advice is provided in line with European, National and Planning Practice Guidance, which seeks the promotion of the waste management hierarchy within sustainable development. In particular, ECC recommends reference is made in appropriate policies in the Draft Local Plan to enabling the provision of waste management facilities in employment areas, by referring to 'any associated employment generating sui generis uses', given that the WLP does not allocate any strategic waste management allocations in Brentwood Borough. ECC continues to support references to renewable energy schemes and sustainable construction.

Infrastructure Planning - Water -

BBC should note that both the Strategic Flood Risk Assessment (SFRA) and Water Cycle Studies (WCS) for Brentwood are now out of date.

There have been a significant number of changes in relation to flood risk, including revised climate change allowances and updates to the surface water mapping since Brentwood last updated their SFRA. As a minimum ECC recommends the production of an addendum to the SFRA to consider the impact these changes would have on the proposed sites within the Draft Plan. This should be followed up by a more detailed review of the document that can be used as an additional assessment when dealing with development that is submitted outside the local plan processes. Similarly ECC recommends that a review of the WCS is undertaken to ensure that issues relating to water supply and demand as well as the processing of waste water are fully considered as part of the Local Plan process.

ECC advise that the Surface Water Management Plans (SWMPs) are being reviewed and an addendum to the SWMPs will be published shortly. The review of the SWMP has taken place following updates to the criteria used to assess properties at risk of flooding. Key changes to the SWMP include revised Critical Drainage Areas (CDAs) and some changes to flood extents.

An impact analysis of the proposed new CDA boundaries on the preferred site allocations proposed in the current consultation has been undertaken, which indicates that, of the 47 sites (housing and employment) 14 are not within a CDA, and 1 site is only within an old CDA. 14 sites are within both the old and new CDA's, and there are 18 of the sites which now fall within the new CDA's. Details are set out below:

* Childerditch Industrial Estate (ref. 112A) - Not In CDA
* William Hunter Way car park, Brentwood (ref. 102) - In New Only
* Land at Alexander Lane, Shenfield (ref. 87) - In Both
* Wates Way Industrial Estate, Ongar Road, Brentwood (ref. 3) - In New Only
* Horndon Industrial Estate, Station Road, West Horndon (ref. 21) - In Both
* Westbury Road Car Park, Westbury Road, Brentwood (ref. 39) - In New Only
* Chatham Way/Crown Street Car Park, Brentwood (ref. 40 ) - In New Only
* Land at Hunter House, Western Road, Brentwood (ref. 41) - In New Only
* Council Depot, The Drive, Warley (ref. 81) - In New Only
* Land west of Warley Hill, Pastoral Way, Warley (ref. 83) - In New Only
* Land adjacent to Tipps Cross Community Hall, Blackmore Road, Tipps Cross (ref.085B) - Not In CDA
* Brentwood railway station car park (ref. 2) - In Both
* Sow & Grow Nursery, Ongar Road, Pilgrims Hatch (ref. 10) - In New Only
* Land adjacent to Ingatestone by-pass (part bounded by Roman Road, south of flyover) (ref.079A) - In Both
* Land south of Redrose Lane, north of Woollard Way, Blackmore (ref. 77) - Not In CDA
* Land south of Redrose Lane, north of Orchard Piece, Blackmore (ref. 76) - Not In CDA
* West Horndon Industrial Estate, Childerditch Lane, West Horndon (ref. 20) - In Both
* Land at Honeypot Lane, Brentwood (ref. 22) - In New Only
* Land off Doddinghurst Road, either side of A12, Brentwood (ref. 023A) - In New Only
* Land east of Nags Head Lane, Brentwood (ref. 32) - In New Only
* Officer's Meadow, land off Alexander Lane, Shenfield (ref. 34) - In Both
* Land at Priests Lane (west), Brentwood (ref. 44) - In Both
* Land adjacent to Carmel, Mascalls Lane, Warley (ref. 27) - In New Only
* Land adjacent to Ingatestone by-pass (part bounded by Roman Road) (ref. 079C) - In Both
* Ingatestone Garden Centre, Roman Road, Ingatestone (ref. 128) - In New Only
* Land East of Horndon Industrial Estate (ref. 152) - In New Only
* Land North of A1023 Chelmsford Road, Shenfield (ref. 158) - In Both
* Land at Priests Lane (east) adjacent Bishops Walk, Brentwood (ref.178) - In Both
* Land at Crescent Drive, Brentwood (ref. 186) - In Both
* Land south of East Horndon Hall (ref. 187) - Not In CDA
* Childerditch Industrial Estate (ref. 112D) - Not In CDA
* Brizes Corner Field, Blackmore Road, Kelvedon Hatch (ref. 194) - Not In CDA
* Site adjacent to Ingatestone Garden Centre (former A12 works site) (ref. 106) - In New Only
* Land to the north of Alexander Lane, Shenfield (ref. 235) - In Both
* Land east of Chelmsford Road, Shenfield (ref. 263) - In Both
* Oak Hurst, Chelmsford Road, Shenfield (ref. 276) - In New Only
* Chestnut Field, Backmore Road, Hook End (ref. 294) - Not In CDA
* The Eagle and Child Public House, Chelmsford Road, Shenfield (ref. 311) - In Both
* Ford Warley - Northern Site (ref. 117B) - In New Only
* Ford Warley - Southern Site (ref. 117A) - Not In CDA
* Land off Stocks Lane, Kelvedon Hatch (ref. 075B) - Not In CDA
* Childerditch Industrial Estate (ref. 112E) - Not In CDA
* Brentwood Enterprise Park (M25 Works Site at A127/M25 junction 29) (ref. 101A) - Not In CDA
* Land off Doddinghurst Road, either side of A12, Brentwood (ref. 023B) - In New Only
* Codham Hall Farm (ref. 101C) - Not In CDA
* Codham Hall Farm (ref. 101D) - Not In CDA
* Dunton Hills Garden Village (ref. 200) - In Old Only

As a result ECC recommends that any changes arising from the SWMP review will need to be taken into account and inform the preparation of the pre-submission plan.

ECC recommends site specific policies relating to each of the sites that are now within CDA areas. Some suggested working is set out below:

The site is located within a Critical Drainage Area (CDA). This development may have the potential to impact on the CDA in respect of surface water flooding. As a result of this the site is likely to require an individually designed mitigation scheme to address this issue.

ECC advises that it is not clear whether the flood extents within the original SWMP documents have been used for determining surface water flood risk on the preferred site allocations or whether BBC have used the Environment Agency's Risk of Flooding from Surface Water Flood map. If the original SWMP extents have been used then further analysis will be necessary to understand the impact that this will have on the proposed housing and employment allocations.

ECC as Lead Local Flood Authority has provided comments throughout the Draft Local Plan process to ensure the delivery of Sustainable Drainage Systems to provide water quality, amenity and ecological benefits. ECC seeks further discussions with BBC to ensure its Local Plan policies comply with ECC requirements.

The adopted ECC Sustainable Urban Drainage Systems (SuDs) Design Guide should form part of the Plan making process, both in terms of policy formation and supporting evidence base work.

Delivery of proposed development -

Paragraph 162 of the NPPF states that LPAs should work with other authorities and providers to assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk, and its ability to meet forecast demands. An IDP will need to be prepared to support the BBC Local Plan, and identify infrastructure required. The Local Plan should make clear, for at least the first five years, what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development. For the later stages of the Plan period it might be acceptable for less detail to be provided as the position regarding the provision of infrastructure is likely to be less certain. If it is known that a development is unlikely to come forward until after the Plan period due, for example, to uncertainty over deliverability of key infrastructure, then this should be clearly stated in the Draft Plan. As stated earlier, until appropriate work on infrastructure provision has been undertaken, and ECC has reviewed and confirmed its satisfaction with the work, it is recommended that ECC continues to withhold support for the Draft Plan.

Alongside the provision of infrastructure such as improved roads and public transport and the provision of schools to support and accommodate future growth, ECC would strongly advise that the provision of flood and drainage infrastructure is included within the IDP. This would be to alleviate any existing drainage and flood risk concerns and accommodate and support future development. ECC would also strongly advise the inclusion of details on the costing of such infrastructure.

ECC recommend the inclusion of a specific overarching section 106 and CIL policy to ensure a consistent approach and framework for the delivery of relevant infrastructure from developers. This approach would bring together the individual policy requirements and support the provision of further supplementary planning documents and/or CIL Regulation 123 Charging Schedule.

The new policy should consider covering the following:
* Specify when developers are required to either make direct provision or to contribute towards development for the provision of local and strategic infrastructure required by the development (including land for new schools);
* Requirements for all new development to be supported by, and have good access to all necessary infrastructure;
* Requirement to demonstrate that there is or will be sufficient infrastructure capacity to support and meet all the necessary requirements arising from the proposed implications of a scheme (i.e. not just those on the site or its immediate vicinity) and regardless of whether the proposal is a local plan allocation or a windfall site;
* When conditions and/or planning obligations will be appropriate - as part of a package or combination of infrastructure delivery measures - likely to be required to ensure new developments meets this principle; and
* Consideration of likely timing of infrastructure provision - phased spatially or to ensure provision of infrastructure in a timely manner.

Recommended wording for an 'Infrastructure delivery and impact mitigation' policy is provided below.

Policy X: Infrastructure delivery and impact mitigation

Permission will only be granted if it can be demonstrated that there is sufficient appropriate infrastructure capacity to support the development or that such capacity will be delivered by the proposal. It must further be demonstrated that such capacity as is required will prove sustainable over time both in physical and financial terms.

Where a development proposal requires additional infrastructure capacity, to be deemed acceptable, mitigation measures must be agreed with the Council and the appropriate infrastructure provider Such measures may include (not exclusively):
* financial contributions towards new or expanded facilities and the maintenance thereof;
* on-site construction of new provision;
* off-site capacity improvement works; and/or
* the provision of land.

Developers and land owners must work positively with the Council, neighbouring authorities and other infrastructure providers throughout the planning process to ensure that the cumulative impact of development is considered and then mitigated, at the appropriate time, in line with their published policies and guidance.

The Council will consider introducing a Community Infrastructure Levy (CIL) and will implement such for areas and/or development types where a viable charging schedule would best mitigate the impacts of growth. Section 106 will remain the appropriate mechanism for securing land and works along with financial contributions where a sum for the necessary infrastructure is not secured via CIL.  
For the purposes of this policy the widest reasonable definition of infrastructure and infrastructure providers will be applied. Exemplar types of infrastructure are provided in the glossary appended to this plan.

Exceptions to this policy will only be considered where:
* it is proven that the benefit of the development proceeding without full mitigation outweighs the collective harm;
* a fully transparent open book viability assessment has proven that full mitigation cannot be afforded, allowing only for the minimum level of developer profit and land owner receipt necessary for the development to proceed;
* full and thorough investigation has been undertaken to find innovative solutions to issues and all possible steps have been taken to minimise the residual level of unmitigated impacts; and
* obligations are entered into by the developer that provide for appropriate additional mitigation in the event that viability improves prior to completion of the development.

EPOA is preparing a Viability Protocol by working with development interests to ensure the correct level of development related infrastructure is provided as well as a means to assist the LPAs unlock financial barriers that may hold up the development of housing.

Reference should also be made to the adopted ECC Developers' Guide to Infrastructure Contributions (2016), in relation to the level of contributions required from new development for the provision of essential infrastructure by ECC.

ECC would also recommend that there is a need to ensure that local facilities are in place to coincide with the completions of different phases of development. This will need to be progressed through the IDP to support the pre submission plan.

ECC recommends that BBC should seek to produce a Development Plan Document (DPD) to support the planning policy position for DHGV, and provide clarity of the deliverability of the allocation. This will ensure that the development can be delivered with the appropriate infrastructure and phasing. This is an approach that has been taken by the three North Essex LPA's in their part 1 Local Plans.

Green Infrastructure -

Green Infrastructure (GI) is a network of multi-functional high quality green spaces and other environmental features, (such as street trees, green roofs and walls, which together deliver multiple environmental, social and economic benefits , that contribute to the quality, attractiveness and distinctiveness of the Borough. A number of the site allocations do not mention the opportunities to enhance the GIs, and ECC seek clarity on how GIs will be integral to all site allocations (including those for commercial and educational developments).

The Forestry Commission produced a report on the economic value of Green Infrastructure. Within this report it states that the perceptions of a region can be a barrier to recruitment for businesses within that region, especially in relation to highly qualified staff. However, high quality GIs will have a benefit on people's health, wellbeing, quality of life and contribute to improved educational capability. The investment into maintenance and creation of high quality GIs can act to encourage and attract commercial industry, entrepreneurs and workers to that region.

A strong example of this is from the north of England, that of Riverside Park Industrial Estate in Middlesbrough where investment in the GI of the park created a setting for stimulating business growth and investment. The redeveloped site attracted new, high profile, occupants and saw occupancy grow from 40% to 78%, and levered over £1 million of private investment (CLES/Groundwork, 2007)

Every development has the potential to enhance and create new GI and contribute to creating green corridors for better connectivity of the GI network. Therefore, ECC recommend that there should be a consideration for new housing and commercial development to have reasonable access and distance to green spaces and which includes the requirement to create new green spaces. Natural England produced a guide to help decision makers to ensure that everyone has access to good quality natural greenspace near to where they live and work. Accessible Natural Greenspace Standard (ANGSt) recommends for example green space of at least 2 hectares in size, no more than 300 metres (5 minutes' walk) from home and one accessible 100 hectare site within five kilometres of home. Another example is Bristol City which has put in place a distance standard to protect and promote an accessible network of green space, based on research with residents and layout to ensure credibility, including requiring a distance to the nearest green space of 400 metres or 9 minutes' walk, and natural green space within700 metres 18 minutes' walk etc. (Bristol's Parks and Green Space Strategy, 2008).

ECC welcomes the opportunity to engage with BBC to ensure that GI is imbedded in its Draft Plan.

ECC advises that developers of new sites with more than 30 premises can obtain free Fibre to the Premises (FTTP) provided by both BT Openreach and Virgin Media, giving access to ultrafast broadband speeds.

Whilst from a sustainable transport perspective it is a positive to see the reduction of car parking spaces through development of the car parks, ECC seek clarification on the balance to be achieved between providing residential development in the town centres, on sites currently providing car parking facilities, and the need to ensure local retail and leisure sector businesses continue to thrive and are provided with suitable facilities.

Many of the sites are reasonably well located and accessible, however it will still be important to ensure that additional passenger transport facilities and service funding is secured to enable the existing routes to be enhanced, in terms of frequency, quality and coverage/connectivity. Some of the more important ones are listed below. 

The Draft Plan is light with regard to the specification of improved infrastructure to facilitate sustainable modes of accessibility throughout the Borough. There should be stated aspirations of infrastructure needs specified in the Draft Plan, to be addressed as and when opportunities arise.

There should also be enhanced arrangements to facilitate bus access at Brentwood Station (The Parade) and Shenfield Station.

Paragraph 67 - It is good to note the stated intention of the Council is to 'see an integrated and comprehensive approach to development' - this stance will certainly be beneficial when the LPA is considering the potential sustainable transport solutions necessary to serve its planned developments. It is likely that the Council will need to consider the cumulative impacts of adjacent / aligned developments, in order to ensure that through the pooling of contributions from sites, assurances can be obtained that sufficient pump priming funding can be provided to enable bus services at a suitably attractive level of frequency and quality can be procured for a sufficiently long bedding in period - thus containing the impact of developments on the local highway network.

Area/site specific policies in Pre-Submission Plan for preferred housing and employment sites -

It is recommended that area/site specific policies are included in the Pre-Submission Plan for preferred housing and employment sites, including DHGV. This would provide a clear picture of where development is to be focused and enable specific policy requirements to be outlined. This would cover infrastructure such as the need to provide land for a new school/EYCC facility, highway/access requirements, flooding and surface water mitigation and other community infrastructure requirements such as health services, as well as housing mix.

I have taken a look at the plan online and have the following comments. The development in priests Lane seems not In keeping with the area given the number of dwellings proposed The identification of pretty much every car park in Brentwood is ludicrous. Have you ever tried to park in Brentwood? In tandem with these increased abodes you need to tell us the plans for improved facilities - schools, doctors, parking, healthcare, community, shops - most importantly supermarkets - services eg Wi-fi, rubbish collection etc. Not to talk about that at same time makes it impossible to have anything but a negative view on the proposal. Please share any updates

Thank you and refer to your letter of the 2nd February. In response please note that I object to these proposals because of the following: The infrastructure in Brentwood and the surrounding villages can simply not cope with the additional number of people and vehicles that the proposed development will create. The road system in, around and through Brentwood is already under extreme pressure during the school and working rush hour. Our schools are at capacity and over-crowded and our NHS / doctor services are exposed and not able to cope with the number of patients they already have. The majority of planned development is to be built on greenbelt land, which I do not consider to be necessary. The greenbelt is there to protect us and to support the environment. We can not afford to lose this for the sake of expensive housing only to make developers rich! Once gone it is irreversible. The planned housing is not aimed at first time buyers but will end up being marketed as 'executive housing' and out of reach by all but the very wealthy. The disruption the planned building will have for many years in and around Brentwood does not bear thinking about. As already mentioned the road system can not cope as it stands. The additional construction traffic will only add to the problem. It will also create an unacceptable level of pollution from both the construction and then, once built, the additional environmental effect the additional housing and vehicles will generate. This is particularly relevant to the vast Dunton Garden Village site which will back on to the A127 and A128 junction, never mind the additional traffic that is going to head that way once the new Thames crossing is build. The developers always under estimate and the planning committees always accept that there will be less cars allocated to each property. In the relatively recent development of apartments that was built at the entrance to the village of West Horndon the cars now park on the road causing a danger to other road users and pedestrians. I fear the same will be replicated in all future developments planned which will lead to further snarling up of our road system. A high proportion of people living in and around Brentwood work and commute into London on a daily basis. The C2C trains running into London from West Horndon are already over-crowded and unable to cope with the number of passengers they have. Adding thousands of new commuters to the line, even if a new station were to be built, simply doesn't add up. The infrastructure simply can't cope. Brentwood is a pleasant place in which to live. I have lived here all my life and chose to remain when raising my family. I fear that the proposed developments will cause huge harm to the town and on a wider scale to the environment. The infrastructure we have will not cope and it will, as a result, become a place that I, and I fear many others, will have to leave. Please accept this as my formal objection to the planning proposals BBC have set out in their Brentwood Development Plan.

I Object to these plans because of the destruction of green belt land as well as additional congestion and pollution this will cause and the additional pressure on the public services. There would also be large destruction to the local wildlife.

I am writing with regards to the Honeypot Lane development. As a family we are strongly opposed to this. I live in Brook Road. We moved to the area 7 years ago from South Woodford and one of the main attractions was the large open space around the immediate area. We moved here from South Woodford. We bought our house in South Woodford taking into consideration the area around and unfortunately a large development was built on the land behind our house. I can't even begin to describe the difference in the through traffic, the effect on parking, the noise and the overall negative effect it had on what we used to enjoy about the area we lived in and this was the main reason we moved to a different area that offered all of the things that were no longer offered to us. Brook Road is already becoming a bit of a traffic through road, a lot more so than it used to be since the local pubs and restaurants started charging for their car parks to stop the people in the offices in Spital Road parking there all day. They now use Brook Road to park their cars. More traffic as a result of this development will cause more disruption and make it even more unsafe for our children in the whole of the Homesteads development. There are lots of children who live here and to potentially put them in more danger is unacceptable. The increased traffic will also have a huge negative effect on the state of our already very dangerous roads. I have lost count of the number of potholes and cracks and the general state of our roads in the Homesteads which is unsafe for both vehicles and pedestrians. More traffic will just add to this problem. This is both unfair and unacceptable. What will become of St Peter's school? Where will the residents of the new development send their children? There simply isn't the infrastructure to cope with this. Where will the new residents see a GP? All of the surgeries in Brentwood are full to the brim and find it difficult to cope with what is already a struggle to see patients in a timely manner. In the high street, where will everybody park? With the proposed developments on Chatham Way and William Hunter Way car parks it's going to be a huge challenge and have a huge impact on the already struggling businesses in our rapidly declining High Street. We strongly oppose this development.

I object to this revised local plan for the reasons as follows :-

The green fields around West Horndon are designated as Metropolitan Green Belt, put in place to stop the London sprawl.

Too much housing planned for Dunton Garden Suburb this planned housing should be distributed in the North of the borough as well as the South. We have a two track railway here C2C. Shenfield has more than double that number of tracks. With the additional benefit of cross rail.
The north of the borough also will benefit by the expansion of the A12.
The increase of traffic on the A127 (which is already at full capacity) and other local roads will cause traffic chaos in the area.
This higher level of road traffic will also be the source of much higher air pollution in the local residential area.
There will also be a much higher demand for school places and appointments at the doctors .
The added threat of flooding with the possibility of the surface water going into the Mardyke river from the huge development planned for Dunton Garden Suburb. Where as a much smaller development here and spreading the rest of the housing through out the borough would be a more sensible approach.



Basildon hospital and the small inadequate doctors surgery in West Horndon will not cope with the volume of people that you propose to house in this area. Especially as there is much more land available in the North of the borough and hospitals in nearby Chelmsford.

Whilst I agree with the development of housing on the Industrial site in West Horndon I am appalled to learn that you plan to leave and move parts of the Industrial Estate still within this location. We have had to put up with huge juggernaut lorries speeding through this village on roads not designed for this type of transport. Also to put a travellers site within the village, with all the problems this could cause. Who will want to purchase a house with that next door. The people in Crays Hill have had huge problems selling their homes and all the village children were taken out of the local school. Having recently experienced some members of the travelling community whilst visiting a Tesco store helping themselves to groceries and then leaving with out paying, it fills me with despair that you want to place them in this village.

I object to the proposed local plan due to the following reasons: Greenbelt land - of the 8000 proposed houses, half of these are planned on the borders of Basildon council's greenbelt. What surveys have been carried out regarding the protected species such as great crested newts, bats, dormice, badgers etc which have all been seen on the proposed site. Little concern has been given to the following things: doctors surgery, hospitals, schools, viability of scheme. The residents of Langdon hills struggle to get their children into a good primary and secondary school. The proposed 8000 homes will add to the already full schools within close proximity. Where will all these additional children go to school? A new secondary school needs to be built. The nhs is facing unprecedented cuts. The new homes with add pressure to Basildon hospital which is already under pressure. If Southend A&E closes then it is hard to see how Basildon will cope with this and the additional homes you want to build. Pollution - there are no main towns nearby to the proposed houses or schools, doctors or hospitals. You are encouraging people to use their cars for short journeys adding to the already dangerous pollution levels found at the fortune of war roundabout. There are no nearby transport links again making proposed residents even more reliable on their cars. Where are you expecting these additional 8000 households to see a gp? All gps in Brentwood and neighbouring Langdon hills are overrun. Have any viability assessments been made? With rising build costs plus all the additional costs for surveys, removal of protected species etc against low sales values (due to lack of resident amenities, public transport links etc) will leave very little in the pot for s106 contributions. Why can't the developer be liable for providing a school, doctors surgery or something like this? If the sales values from the housing are likely to rise from the viability discussions to actual completion - are you going to ensure the developer is required to pay you an overage? Unfortunately it feels as though this additional housing has not been thought through properly and how it will affect our already struggling public services.

I object to these proposals because of the following reasons:

Road Infrastructure

The road infrastructure is already under immense strain.

The local traffic comes to a standstill every time there's an issue in any of the surrounding main roads. Most mornings, it takes 15 to 20 minutes to get to the end of Billericay Road from our house (0.5 Miles).

If you add to this a significant increase in traffic on already poorly maintained roads, without any solution to the existing traffic issues, there will be constant standstill in the surrounding area.

Increased Pollution

Basildon Council already accepts that there are health issues for the local residents with the amount of traffic on the a127 and a128. Increased Pollution from a further 10k cars will exacerbate the strain on local NHS hospitals with an increase in respiratory and other health issues.

NHS facilities

A significant increase in population in the local area will require a significant increase in local NHS facilities. This fatally, has not been factored into the plan.

Unaffordable housing

The development will not provide housing affordable to first time buyers. Estimates for the house values from Savills starts at £525k. This is another fatal flaw in the plan as there is a requirement to provide affordable housing in the local area which this plan does not meet.

1) Green belt. The ever-increasing pressure for more roads and housing means it is vital the council should do everything it can to protect and invest in the Green Belts that we have. Development on Green Belt land is supposed to be tightly controlled - its purpose is to serve as a buffer between towns and between towns and the countryside. Green Belt land also brings social, environmental and economic benefits. They are responsible for food production, flood prevention, climate change mitigation and more. We should be protecting them and not recklessly building on them. 2) Health. The nearest Health Centre appears full to capacity and can take weeks to obtain an appointment if required. How will this improve if additional houses are built? 3) Education. Blackmore school is full. The parked cars for the school line Nine Ashes road at 8:45 and 15:00 Monday - Friday. The ones that can't fit on the road park down Woollard Way. How will the school accommodate the additional influx whilst striving to achieve the best Ofsted award it can? Will the educational needs of the current pupils be undermined due to the additional pupils? 4) Transport. The bus service is part-time. Is this sufficient? The village is already busy with traffic and parked cars throughout the day - more noticeably in the morning and evening rush hour periods, making parking to access local amenities extremely difficult. Will additional housing improve this already unsatisfactory situation? 5) Disruption. How long will it take to build the additional houses earmarked for Blackmore and is this acceptable to current residents?
6) Land permanent loss of viable agricultural land. The risk of increasing frequency and severity of flooding. The clay soil in the area already makes drainage very difficult and the Green Belt land helps greatly in removing excess rainfall. Will building on this land make the flood risk better or worse?

I object to these proposals because it will destroy our greenbelt land. The increase in people living in the area will strain our already overloaded hospitals, schools etc. The road infrastucure is not sufficient for the extra households, which are already incredibly congested, and the extra houses and traffic as a result will cause in increase in pollution and destroy the areas for our natural wildlife.

Having looked through your on-line information, I would like to stress one particular point, in that, there are a great many people of pensionable age who would like to move from their own homes to retirement living and there are simply not enough builds of this sort in the Brentwood area to allow it. My own experience of moving 18 months ago was that I did not own one of the more expensive houses in Shenfield, but even so, there was nowhere I could move to within Shenfield/Billericay/Brentwood at an affordable price and so, luckily, I found a flat at x (address), residential flats for over 60's. This would not have been my first choice but it is actually ideal and I would like this sort of accommodation to be high on your list of new housing - it should also be kept in mind that in addition this releases larger, older, existing properties and maybe the number of new builds could then be lessened. It makes sense and with GOOD planning, may make the need to swallow up our fields and open spaces less likely. I would also like to say that an improvement on the type of shops in Brentwood would be a great advantage. At the moment we have so very few shops of quality and if we had, this would enhance the quality of the high street in general - which, by the way, would also benefit from cleaning. In short, whatever your plan, please give more thought to the existing residents, doctor and hospital facilities, which at the moment are woeful, schools and traffic all of which will be made unbearable by the addition of new housing with all that brings.

I am writing to express my total opposition to Honeypot Lane being proposed as a preferred site under the local plan and wish to see the site removed as a preferred site for additional homes.

My reasons are as follows:
For years Honeypot Lane has been used as a rat run. The Lane - note a Lane not a road - would not cope with the significant extra traffic that 200 homes plus a Care Home would bring if it were used as an access to/from the proposed site. It is narrow and has been designated a 20-mph limit area for good reason.

There is a major safety issue - there have been accidents in Honeypot Lane due to the speed of traffic, even though it is a restricted speed area.

In addition, any such development would put lots of extra pressure on the pinch point in Weald Road, which at the moment is too narrow for two cars to pass each other on route to or from the High Street.

If cars cannot reach the High Street via Weald Road, the traffic will then impact on other cut-through roads, e.g. Sandpit Lane, Park Road etc. to Ongar Road or London Road, bringing major congestion and the increased probability of accidents. In the case of vehicles heading for the A12/M25, Honeypot Lane will grind to a halt and the Homestead estate will also be swamped with vehicles. In fact, all surrounding roads that provide access will be affected.
When there are problems on the A12/M25, which occur with great regularity, the resulting extra traffic trying to avoid the town centre is already a problem; these extra cars will just exacerbate the chaos and will add to the impact on Brentwood.

The impact of the additional movements of a possible 500 extra cars, together with parcel/shopping delivery and other vehicles, from the proposed development to Brentwood/Shenfield stations, local schools, access to the A12 and M25, together with its effect on all the surrounding roads, which were not built for this volume of traffic, will bring even more disruption at crucial times of the day. Any construction traffic will make the resultant traffic chaos unimaginably worse.

There have already been a significant number of houses built in the vicinity of Brentwood town centre in recent years; this further proposed development will add to the over-development.

The noise and pollution resulting from the A12 is already a problem; further building would only exacerbate the problem.

Our nearest local schools, St. Peter's and Holly Trees, are already oversubscribed. Therefore, this will add to the traffic chaos surrounding Brentwood when parents have to travel further afield to take their children to schools out of area.
Our local doctors' surgeries are already at capacity - in fact, it already takes 3 to 4 weeks to obtain an appointment.

The proposed site is already subject to flooding. In fact, there is a stream that runs through it, which flows from the higher ground around the High Street/London Road.
If any new development were built on this proposed area, then it would increase the risk of flooding to other nearby areas - water will always find a way out. The houses would have huge problems obtaining buildings insurance, if indeed it were possible at all, in light of Insurance companies reviewing their stance due to an increase in flooding claims and the effects of climate change. It seems totally irresponsible to consider building homes on land that will flood, especially in light of the
effects of previous planning disasters which have seen residents forced out of their homes in places like Cumbria, Somerset and in the Thames Valley.

It is to be pointed out the Brook Road, Talbrook, etc.- nearby roads - have their names for a reason! Drainage has always been a problem in Honeypot Lane, which I am sure even your own records will confirm.

Wildlife, such as bats, badgers, pheasants, foxes, newts, etc. use the proposed site and nearby area.
In addition to the above, I would draw your attention to the following further arguments against the suggested development at Honeypot Lane.
You are suggesting a major development on greenfield site on the edge of the built up area. When the site was originally put forward the Council, rejected it because it did not meet the Spatial Strategy.
The spatial strategy states that:
"To meet local needs fully there will be limited release of Green Belt for development within transport corridors, in strategic locations to deliver self-sustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries to avoid further sprawl and
provide development swiftly."

And that all development sites will be identified having regard to whether they:
a) are accessible to public transport, services and facilities;
b) will have no significant impact on the Green Belt, visual amenity, heritage, transport and environmental quality including landscape, wildlife, flood-risk, air and water pollution; and
c) are likely to come forward over the Plan period.
The plan provides no details to support the proposal, only the boundaries and location of the proposed site, and the number of dwellings it might accommodate. There is no explanation as to why the site is thought to be suitable for this scale of development.
The proposal makes reference to an evidence base and infrastructure but is only able to say that an "Infrastructure Delivery Plan is forthcoming". No other evidence is put forward. National guidance states that Local Planning Authorities should assess the quality and capacity of infrastructure, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, and flood risk, and its ability to
meet forecast demands. This has not been done.

Local residents are being asked to comment on a major proposal, having been presented with only an outline of what is proposed. It is not known the refore what benefits, if any, there might be for the area, or how the scheme might seek to mitigate against the many harmful impacts.
The Borough Council are therefore attempting a consultation exercise on a proposal which is at best sketchy, is poorly researched, and premature in terms of an evidence base. Overall therefore it is illconceived. The National Planning Policy framework says that local planning authorities should aim to involve all
sections of the community in the development of Local Plans and in planning decisions, which should facilitate neighbourhood planning.

It also says that: "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable
development of the area, including those contained in any neighbourhood plans that have been made."

In passing the Localism Act the Government has said that: "Too often, power was exercised by people who were not directly affected by the decisions they were
taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them."

The plan and the consultation process have so far been a top down process, with little regard for the involvement of the local community.

The National Planning Policy Framework states that:
"The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."

The proposal is within the Green Belt. National planning guidance is clear that development in the Green Belt is by definition inappropriate and harmful.
Exceptional circumstances must exist to justify the loss of Green Belt land. The Government has clarified that housing demand is unlikely to constitute the exceptional circumstances to justify such loss.

The site would project out into open Green Belt land, bounded only by narrows lanes, with open fields beyond.

Whether new development can be proved to be sustainable is central to planning policy. Sustainable is defined as "ensuring that better lives for ourselves don't mean worse lives for future generations". In practice the essential requirement is that new homeowners will not be over dependent on the car for journeys to work, school, shops, leisure activities, and other services and amenities.

The proposed site is on the western edge of the town, over 1 kilometre from the centre of the town and further still from Brentwood railway station and access to the A12/M25. If the residents of the new development have no choice but to make most journeys by car, the site does not offer a sustainable location.
A development of some 200 houses would increase traffic levels on roads and junctions that are already inadequate.

There is no indication as to where the main access to the site would be located, or what improvements to Honeypot Lane and Weald Road might be necessary, if indeed they are feasible, or how they will be funded.

The Council's website indicates that the impact and the need for infrastructure supporting new development will be considered in greater detail by the Infrastructure Delivery Plan and the Local Plan.

Council have only just on (29th January) launched an infrastructure Delivery Plan website. There is no information about Honeypot Lane. The proposals are not clear on the mix and proportion of land uses, with what appears to be a leaning
towards an almost wholly residential scheme. There is no question that a development of the scale proposed will greatly increase the volume of
traffic passing through the surrounding residential streets. Overall the concern is that the people of the local community are most likely to suffer the harmful
impacts of the development by way of increased traffic, overlooked gardens and properties, loss of rural character, without any discernible benefits.

There is no evidence that the Council has carried any assessment of drainage in the area. National guidance states that: "Local Plans should develop robust and comprehensive policies that set out the quality of developments that would be expected of the area, responding to local character and being visually attractive."
A local planning authority should also submit a plan for examination which is "sound", in respect of how it is prepared, whether proposals are properly justified, whether it can be delivered, and whether it is consistent with national policy.

Given the level and extent of the concerns as set out above, the plan clearly has fundamental shortcomings. It is not therefore sound or robust.
In view of the aforementioned, we contend that the posited development of Honeypot Lane be scrapped and that the faceless land owners, who are not part of the local community, are informed that their speculative venture has failed, as a result of overwhelming location opposition and for the many reasons referred to above.

1. The building of unaffordable houses for people and destroying Greenbelt for monetary gain for the developers is unacceptable & immoral. The LDP shows land miss represented as Brownfield when it is most certainly Greenbelt in the current house market, householder need to upgrade by 200,000 pounds at least, this housing is not affordable for our younger generations

2. Our precious greenbelt provides fresh air alleviating pollution from east the A127, as records show the A127 is exceeding levels of pollution & there is now talk of emission charge ! The woodland & Greenbelt are needed to counteract these pollution levels.

3. These areas have inhabitants of precious Wildlife & will be adversely affected & lost forever -sites of SSI are in place for a reason as is protected Greenbelt -this can not be the allocated

4.All of our facilities are stretched -overburdened roads , GP surgeries ,schools , hospitals -A127 , A128 & Billericay roads are at a standstill certain times of the day -roads are at breaking point . There is no infrastructure for these said unaffordable
Houses. The area is highly congested already causing pollution

5.The figures are completely manipulated why If this is a local plan it is common knowledge that the homes are for executive for those coming from outside if the area .

6.the actual numbers of houses needed is not quantifiable not necessary or needed with the EU brexit we have no idea how many people will be here after these figures you have grabbed we're prior to the referendum last year

I strongly object to all of your planning proposals to build on 2005 designated Greenbelt for a number of reasons.

Our precious greenbelt provides fresh air alleviating pollution from east the A127, as records show the A127 is exceeding levels of pollution & there is now talk of emission charge ! The woodland & Greenbelt are needed to counteract these pollution levels.

These areas have inhabitants of precious Wildlife & will be adversely affected & lost forever -sites of SSI are in place for a reason as is protected Greenbelt -this can not be the allocated

All of our facilities are stretched -overburdened roads , GP surgeries ,schools , hospitals -A127 , A128 & Billericay roads are at a standstill certain times of the day -roads are at breaking point . There is no infrastructure for these said unaffordable
Houses. The area is highly congested already causing pollution


Actual numbers of houses needed is not quantifiable not necessary or needed with the EU brexit we have no idea how many people will be here after these figures you have grabbed we're prior to the referendum last year.