6. Housing Provision

(6) Housing

Housing Mix

6.1 It is important that new housing development addresses local needs and contributes to the creation of mixed and balanced communities. A core planning principle in the NPPF is that every effort should be made objectively to identify and then meet the housing needs of an area. This means providing sufficient good-quality housing of the right types, mix, sizes, and tenure in the right places, which will be attractive to and meet the identified needs of different groups in society, including families with children, first-time buyers, older people, people with disabilities, and people wishing to build their own homes. Well-designed housing should also be accessible and adaptable to meet people's changing needs and helping to sustain independent living.

6.2 The amount and distribution of housing to be delivered in the borough over the Plan period is established through Policy SP02 Managing Growth. Policy HP01 Housing Mix seeks to ensure that residential development proposals deliver housing in a way that contributes to the rebalancing of the housing stock to ensure it better reflects the identified needs and demands for housing of the existing and future communities of the borough.

6.3 The NPPF requires local planning authorities to plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community, including, but not limited to, those who require affordable housing, families with children, older people, people with disabilities, travellers, people who rent their homes and people wishing to commission or build their own homes. Across the borough, there is a need to rebalance the housing market to provide a range of housing that will meet the changing needs of communities.

6.4 The Council's Strategic Housing Market Assessment (SHMA) Part 2 (2016) provides a detailed assessment of the housing required to meet existing and future needs across the borough. Proposals should respond to other up-to-date and relevant local evidence where available, such as the Council's Housing Strategy.

(2) 6.5 The Council's latest SHMA indicates that the greatest need for Market housing is two-bedroom units, closely followed by a need for family housing consisting of three or more bedrooms. Figure 6.1 below will be used to inform negotiations between the Council and developers to determine the appropriate mix of housing. The final mix of housing/types will be subject to negotiation with the applicant.

Size of new Market housing required up to 2033
Dwelling Size	Indicative Mix
One bedroom	3.8%
Two bedrooms	35.8%
Three bedrooms	30.2%
Four or more bedrooms	30.2%
Total	100%

(2) Figure 6.1: Indicative Size Guide for Market Housing

6.6 Census data^[1] indicates an above average proportion of the borough's households contain older persons, at 24.1% compared to 22.3% regionally and 20.5% nationally. The proportion of the borough's population living beyond 65 years of age is set to rise during the Plan period, from 14,564 residents in 2013 to 21,093 residents in 2033, a rise of 44.8%, meaning a significant proportion of projected households are likely to have a household representative aged 65 or over.

6.7 The government position is that older persons should remain at home rather than enter residential facilities (use class C2) where appropriate. This combination of factors shows the need for homes that are adapted and further adaptable for a less mobile population. It is expected that all dwellings on major residential schemes achieve requirement M4(2) accessible and adaptable dwellings, or M4(3) wheelchair adaptable dwellings of the Building Regulations 2015.

6.8 Government research^[2] shows that, based on English Partnerships figures from 2011-2012, nearly 30% of households have at least one person with a long-term illness and over 3% have one or more wheelchair user.

6.9 While nationally 3.3% of households have a wheelchair user, for households living in affordable housing this rises to 7.1%. The rates are also higher for older households; and given that the number of older person households in the borough is set to increase over the period to 2033, the Council seeks to ensure 5% of affordable housing development on proposals of 60 or more dwellings archives requirement M4(3) wheelchair accessible dwellings.

6.10 The development of self-build properties by individuals or community groups (including Community Land Trusts) can also contribute to meeting the need for additional housing within the district and provide a more diverse housing stock. Self-build plots are plots of land which are made available for individuals to design and build their own home whereas custom build plots are provided by site developers to the specification of individuals which may or may not follow a basic design pattern.

6.11 To assist in the delivery of a choice of accommodation, the provision of self and custom housebuilding plots is required to be made available on strategic residential schemes of 500 dwellings or more. A figure of 5% of the total dwelling numbers shall be made available for sale as self or custom housebuilding plots whilst there is an identified need on the Council's Self-build and Custom Housebuilding Register. The Council will have regard to the information in its Self & Custom Housebuilding Register when negotiating the mix of plots to come forward as self or custom build and will secure this through S106 or other legal agreements. Self-build/custom build homes will not be considered as an alternative to, or replacement for, the affordable housing requirements set out in Policy HP05 Affordable Housing

6.12 Where a site has five or more self or custom build dwellings the Council may require these dwellings to be developed in accordance with an agreed design code. Where plots have been available at market value and marketed appropriately for at least three years and have not sold, the plot(s) may remain on the open market as self or custom build or be offered to the Council or a Housing Association before being built out by the developer.

6.13 The Council will also seek the provision of Specialist Accommodation on strategic residential schemes of 500 dwellings or more, to ensure there will be sufficient housing to accommodate identified local need as set out in Policy HP04 Specialist Accommodation. The Council will have regard to the information in its AMR 'Specialist Accommodation Report' when negotiating the mix and type of units to come forward as Specialist Accommodation and will seek to secure this through S106 or other legal agreements.

6.14 Where an applicant considers that it is not feasible or viable to meet the requirements as set out in Policy HP01, the Council will expect this to be demonstrated with robust evidence and may negotiate a proportionate housing mix which is achievable, account will be taken of the nature, constraints, character and context of the site.

6.15 Conditions may be used to ensure particular housing types provided, remain available in perpetuity and by tenure.

6.16 The Essex Design Guide 2018 seeks to provide residential development which is flexible and adaptable throughout its lifetime. The Design Guide includes guidance on cross cutting themes, one of which is specifically in relation to the ageing population.

Protecting the Existing Housing Stock

6.17 As demonstrated in this Plan, there are substantial needs for additional housing in the borough. The Council's work to determine land supply has demonstrated that to meet this need the release of some of the Green Belt is necessary and justified. Taking these factors together, the Council considers that it is important to resist the net loss of existing dwellings.

Residential Density

6.18 Efficient land use is essential in a borough like Brentwood where land is scarce and enables new homes to be provided without encroaching on the countryside. Good design makes it appropriate to develop in a way that is sympathetic to local character, uses land efficiently and creates or maintains a high-quality living and working environment. The right density will depend on the scheme, dwelling mix, site characteristics and location.

6.19 Proposals for housing developments should promote an effective use of land in line with the NPPF. Policy HP03 Residential Density sets out the Council's expectations on the net density of sites in the borough, supporting development proposals that make efficient use of land and discouraging low density development to ensure optimal use of each site.

6.20 The Council considers it reasonable to expect proposals to achieve densities of at least 35 dwellings per hectare except where this would harm the special character of an area, have an adverse transport impact or cause harm to residential amenities. Densities of 65 dwellings to the hectare or more will generally be expected in locations well served by retail, commercial and community facilities and services, and/or locations with good public transport accessibility.

(2) 6.21 Hutton Mount is a residential area with a character and nature which are important to the economic and social well-being of the borough. The low density-residential development is set within well-landscaped gardens served by attractive tree-lined private roads. Generally the dwellings, which are of individual styles, are set well apart, and it is the generous distance between buildings which is a significant factor in contributing to the character of the area. This mature, well-landscaped and spacious residential area has a distinctive character, which is worthy of retention. Any new or in-fill development will respect the existing character and density of the area and have a minimum plot size of 0.1 ha, building line frontage of not less than 18.3m, and no part of any building shall be closer than 1.2 m to the plot boundary.

6.22 To determine how much land is required to meet housing requirements, consideration has been given to the number of homes a given area can sustainably accommodate based on site and location characteristics. Efficient land use is critical to the delivery of this Plan. Without it, there will be more pressure to release Green Belt to accommodate new development or, alternatively, the number of new homes delivered will fall short of that planned and what would otherwise have been provided.

(3) Specialist Accommodation

6.23 The NPPF requires local planning authorities to plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community.

6.24 There are certain groups of people within the community that need specialist residential accommodation that caters for their specific needs. This form of accommodation includes, but is not limited to, housing for older people such as Independent Living schemes for the frail elderly, homes for those with disabilities and support needs, residential institutions and culturally appropriate accommodation for those Gypsies and Travellers or Travelling Showpeople who no longer exercise a nomadic lifestyle and where the Planning Policy for Traveller Sites does not apply. Policy HP04 Specialist Accommodation is intended to support the delivery of this national policy requirement.

(1) 6.25 The Council's SHMA Part 2 provides a detailed assessment of the housing required to meet existing and future needs across the borough. The SHMA indicates that if occupation patterns of Specialist Residential Accommodation for older people remain at current levels, there will be a requirement for 494 additional specialist units to 2033. Essex County Council's Independent Living Programme is encouraging the provision of Specialist Residential Accommodation in Essex as a means to provide housing for people over the age of 55 whose current home no longer meets their needs. Brentwood has an ageing population which has clear implications for the future delivery of housing over the Local Plan period. Essex County Council (ECC) is the provider of social services in Brentwood. ECC's approach to Independent Living (Extra Care) encourages the provision of specialist accommodation in Essex as a means by which older people can continue to live healthy and active lives within existing communities. This approach to meeting the specialist accommodation needs of older people is intended to reduce the demand for residential/nursing home care across the County. Independent Living schemes are part of a wider accommodation pathway to enable older people to remain as independent as possible with the right housing and support to meet their needs. The Council will work with Essex County Council to secure provision of suitable sites.

6.26 The SHMA Part 2 will be used alongside other relevant local evidence, such as the Brentwood Gypsy and Traveller Accommodation Assessment and Housing Strategy, to inform a 'Specialist Accommodation Report', produced and updated regularly as part of the Councils ongoing Authority Monitoring commitments.

6.27 The Council will refer to the latest 'Specialist Accommodation Report' during negotiations with developers in establishing local need and securing the provision, and where relevant location, of the most appropriate Specialist Accommodation. The final type, tenure and quantum of specialist accommodation provision will be determined through negotiations on individual planning applications and will be secured through S106 or other legal agreements.

6.28 In the monitoring of this policy there will be a need to ensure the Council is satisfied with the provision of specialist accommodation being delivered, if a shortfall in provision is identified the policy will be reviewed as necessary.

Affordable Housing

6.29 Affordable housing is defined as housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsidised route to home ownership and/or is for essential local workers); the definition includes, but is not limited to, social rented/affordable rented and intermediate housing as well as starter homes. To be 'affordable', the cost of housing must be low enough for eligible households to afford based on local incomes and house prices.

6.30 A growing number of households in the borough cannot afford to buy or rent on the open market. House prices in Brentwood are among the highest in Essex. A shortage of affordable housing leads to overcrowding, poor health, inability to achieve a decent standard of living and personal aspirations such as living independently, having children, being part of family or social network of choice – all factors that contribute to the sustainability of neighbourhoods.

6.31 The provision of affordable housing to meet identified need is an important objective of the Local Plan. To assess this need, the Council, commissioned consultants to produce a Strategic Housing Market Assessment (SHMA) Part 2, which was published in June 2016, and uses the national planning practice guidance to calculate the level of affordable housing need. This assessment identified that the annual level of need for affordable housing in the borough is 107 households per year.

6.32 Chapter 5 of the NPPF sets out that in delivering a sufficient supply of homes, local planning authorities should (amongst other things, where they have identified that affordable housing is needed) set policies for meeting this need, specifying the type of affordable housing required, and expect it to be met on-site unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified and the agreed approach contributes to the objective of creating mixed and balanced communities.

6.33 There is a significant need for affordable housing in the borough as evidenced in the Council's SHMA which supports an affordable housing target of 35% on major developments.

6.34 The local plan viability assessment demonstrates that the thresholds of affordable housing contributions identified in the Local Plan are achievable and the cumulative impact of policies in the local Plan will not put development at risk.

6.35 The Council's SHMA indicates that within the affordable housing sector there is a need for 86% affordable/social rent. Figure 6.2 below will be used to inform negotiations between the Council and developers to determine the appropriate tenure and mix of affordable housing.

6.36 Whilst the Council's starting point in any affordable housing negotiations is that a scheme is viable at the percentages and tenure splits set out within Policy HP05, the policy recognises that there may be sites on which the provision of affordable housing to the percentages or tenure splits set out, would render a development unviable or would prejudice the realisation of other planning objectives that need to be given priority.

Size & Tenure of all affordable housing required up to 2033
Tenure	% Split	Indicative Size
		One bedroom	Two bedrooms	Three bedrooms	Four/+ bedrooms	Total Size
Affordable rent / Social rent	86%	31%	24%	19%	26%	100%
Other forms of affordable housing	14%	28%	36%	24%	12%	100%
Total Tenure	100%

Figure 6.2: Indicative Size Guide for Affordable Housing

6.37 In these circumstances, the applicant will be required to provide a level of on-site affordable provision which can be viably delivered. In doing so, the percentage of on-site provision not met may be made up from financial contributions in lieu of the on-site requirement subject to viability. The Council will normally take into account exceptional site costs and the existing use value of the site but would not consider the price paid for the site to be a relevant factor as this should have taken account of policy requirements. The Council will take an 'open book' approach to negotiation and may require viability assessments to be scrutinised by independent consultants at cost to the developer.

6.38 Only where it can be demonstrated that providing any affordable housing on-site is not viable or feasible will the Council consider accepting financial contributions in lieu of on-site provision.

6.39 The Council encourages applicants to work with registered providers and to engage with them and the Council's housing department at an early stage in the planning process, further guidance on early engagement and preferred partner registered providers is provided in the Housing Strategy.

Standards for New Housing

Internal Space Standards

6.40 The government's Housing Standards Review 2015 published internal space standards which local authorities could apply to new build residential development using planning policy. The council requires the use of these standards for new build development as set out in Policy HP06 and supports these standards for all new residential development.

6.41 The provision of sufficient space within new homes is an important element in improving the quality of life and well-being of Brentwood residents and new dwellings should provide sufficient space for basic daily activities and needs. The need for minimum internal space standards in the Borough is reported in the Council's AMR.

6.42 In order to ensure that homes meet the needs of local residents, regardless of their income level, it is important that internal space standards are improved alongside the overall housing mix. New homes created through residential conversions and homes created by changes of use from non-residential land uses should seek to meet or exceed the standards as far as it is practicable to do so.

6.43 To meet the needs of occupiers, all new residential development should be built in accordance with the nationally described space standard. The standard requires that:

1. A dwelling provides at least the Gross Internal Area (GIA) and built-in storage area set out in Figure 6.3
2. A dwelling with two or more bedspaces has at least one double (or twin) bedroom
3. In order to provide one bedspace, a single bedroom has a floor area of at least 7.5 sqm and is at least 2.15 m wide
4. In order to provide two bedspaces, a double (or twin bedroom) has a floor area of at least 11.5 sqm
5. One double (or twin bedroom) is at least 2.75 m wide and every other double (or twin) bedroom is at least 2.55 m wide
6. Any area with a headroom of less than 1.5m is not counted within the GIA unless used solely for storage (if the area under the stairs is to be used for storage, assume a general floor area of 1 sqm within the GIA)
7. Any other area that is used solely for storage and has a headroom of 900-1500 mm (such as under eaves) is counted at 50% of its floor area, and any area lower than 900 mm is not counted at all
8. A built-in wardrobe counts towards the GIA and bedroom floor area requirements, but should not reduce the effective width of the room below the minimum widths set out above. The built-in area in excess of 0.72 sqm in a double bedroom and 0.36 sqm in a single bedroom counts towards the built-in storage requirement
9. The minimum floor to ceiling height is 2.3 m for at least 75% of the GIA.

Minimum gross internal floor areas of storage (square metres)
Number of bedrooms	Number of bedspaces	1-storey dwellings	2-storey dwellings	3-storey dwellings	Built-in storage
Studio	1 person	39(37)	N/A	N/A	1.0
1 Bedroom	2 person	50	58		1.5
2 Bedroom	3 person	61	70		2.0
	4 person	70	79
3 Bedroom	4 person	74	84	90	2.5
	5 person	86	93	99
	6 person	95	102	108
4 Bedroom	5 person	90	97	103	3.0
	6 person	99	106	112
	7 person	108	115	121
	8 person	117	124	130
5 Bedroom	6 person	103	110	116	3.5
	7 person	112	119	125
	8 person	121	128	134
6 Bedroom	7 person	116	123	129	4.0
	8 person	125	132	138

Figure 6.3: Nationally Described Space Standard

External Residential Space

6.44 External amenity space can make an important contribution in improving the quality of life and well-being of Brentwood residents as well as supporting and enhancing local biodiversity. Gardens, in particular, are an important environmental resource and are a component of Brentwood's greenery character. They form part of an area's development pattern, providing a setting for buildings, which in turn informs the prevailing privacy and amenity enjoyed by residents. They provide a semi-natural habitat for local wildlife and corridors for the movement of wildlife through the urban environment. Collectively, they help to mitigate fluvial and surface water flooding in the more built-up parts of the borough.

6.45 The NPPF sets out the need to secure high-quality design and a good standard of amenity for all existing and future occupants of land and buildings.

6.46 External amenity space should be sufficient to accommodate:

• a table and chairs suitable for the size of dwelling;
• where relevant, provision of a garden shed for general storage (including bicycles if garage provision or cycle storage to the frontage of the dwelling is not possible);
• space for refuse and recycling bins;
• an area to dry washing;
• circulation space; and
• an area for children to play in.

6.47 External residential space would not include car parking or turning areas. Suitable arrangements for access to refuse and recycling bins should be made to prevent bins/bags being transported through dwellings.

6.48 One-bedroom dwellings would not be expected to provide space for children to play, due to the lower likelihood of children occupying these units. Dwellings with more than one bedroom would need to take space for children to play into account.

6.49 Where it is appropriate and viable to do so, developments with flats will need to provide high-quality shared amenity areas on site to meet the needs of residents, including play space for children, in addition to private amenity space and cycle storage.

(1) 6.50 Applicants are also encouraged to consider external residential space size specifications as set out by the Essex Design Guide, prepared by Essex County Council:

• New development on sites larger than 0.1 hectares or at densities above 50 dwellings per hectare should provide at least 25 sqm of private external space for each home;
• Exceptionally, apartments adjacent to and overlooking a park or other large public space of high amenity value could be provided with a smaller amount of communal space. In this instance, apartments should also have balconies with a floor area of at least 5 sqm;
• At least 60% of the private communal space should receive direct sunlight for a minimum of four hours a day in June;
• A gross floor area of 5 sqm per balcony should be provided for houses or apartments with more than one bedroom if private external space size specifications cannot be met.

6.51 This policy should be read in conjunction with Policy HP16 Building Design, Policy HP18 Designing Landscape and the Public Realm, and Policy BE19 Access to Nature. Applicants should also refer to best practice and guidance on achieving quality design for all new residential development, as set out in the Essex Design Guide.

(3) Gypsies, Travellers and Travelling Showpeople

6.52 The Council has a duty to identify land to meet the local needs of Gypsies, Travellers and Travelling Showpeople; national planning policy seeks to ensure fair and equal treatment for travellers.

6.53 In doing so, government guidance sets out the approach Local Authorities should take when making provision for Gypsy and Travellers. It requires Local Authorities to make their own assessment of need, develop fair and effective strategies to meet need through the identification of land for sites, to plan for sites over a reasonable timescale, to increase the number of traveller sites in appropriate locations in order to address under provision and maintain an appropriate level of supply.

6.54 In August 2015, a new definition of Gypsy and Traveller was introduced into the Planning Policy for Traveller Sites (PPTS):

'Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family's or dependants' educational or health needs or old age have ceased to travel temporarily, but excluding members of an organised group of travelling showpeople or circus people traveling together as such.' (PPTS) (DCLG, 2015)

6.55 Responding to the new guidance and the need to update evidence on the level of need, the Council alongside other Essex Local Authorities undertook a Gypsy and Traveller Accommodation Assessment (GTAA) in 2016.

6.56 This identified those Gypsies, Travellers and Travelling Showpeople which should be planned for in accordance with the PPTS, as they retain a nomadic lifestyle, and those which should otherwise have their specific cultural needs of living accommodation met in accordance with the Equalities Act 2010, the Children's and Families Act 2014 and the Human Rights Act 1998, but no longer exercise a nomadic lifestyle and where the PPTS does not apply.

6.57 In respect of those Gypsies and Travellers or Travelling Showpeople, who do not meet the PPTS definition, who may be able to demonstrate a need for culturally appropriate accommodation under Equalities legislation, the Council will continue to assess and plan to meet their needs through Policy HP04 Specialist Accommodation, as part of its wider responsibilities to plan to meet the accommodation needs of its settled community.

6.58 The Brentwood GTAA covers the period 2016 to 2033 and identifies a requirement of 11 additional Gypsy and Traveller pitches to be developed by 2033 for those who meet the PPTS definition of 'travelling'.

6.59 Despite achieving a good response rate for the completion of interviews, it is acknowledged in the GTAA that it was not possible to determine the travelling status of all Gypsy and Traveller households in the borough, and a proportion of these may meet the definition provided in the PPTS. The Council's GTAA consultants Opinion Research Services therefore advise in the GTAA that an allowance of 10% is a realistic assumption of those that are recorded as 'unknown' who may in fact comply with the revised definition; this increases total need to 12 pitches.

6.60 Since completion of the GTAA a Gypsy and Traveller pitch at Cottage Garden, Pilgrims Hatch, has been granted planning consent for the change of use to a detached dwelling (14/01069/FUL), to replace this lost traveller site a requirement for an additional pitch is added to the total requirements of Gypsy and Traveller pitches identified in the GTAA, further increasing the total need to 13 pitches.

6.61 No current need has been identified in the borough for accommodation for travelling showpeople, however, any need that arises over the life of the Plan will be addressed using the criteria based Policy HP11 Proposals For Gypsies, Travellers and Travelling Showpeople on Windfall sites.

6.62 The Gypsy and Traveller Accommodation Assessment finds no evidence of need for a transit site specifically within Brentwood Borough. Further work is currently being undertaken by Essex County Council to consider the need for transit provision across Essex as a whole. Should such a need be identified within Brentwood in the future this will be considered through the review of the Local Plan.

Provision for Gypsies and Travellers

6.63 The PPTS requires local planning authorities to identify and update annually, a supply of specific deliverable sites sufficient to provide five years' worth of sites against their own locally set targets. The Council's GTAA identifies the need for Traveller pitches in the borough over the period of the Local Plan.

6.64 In identifying the provision of sites to meet Gypsy and Traveller needs, a sequential approach to site identification has been adopted, based upon best practice, as set out in Figure 6.4.

Sequential Approach	Commentary
Step 1 - use of vacant pitches	No vacant pitches available to meet needs
Step 2 - potential additional provision from existing expired temporary sites	GTAA does not count tolerated pitches as components of need therefore the identification of pitches on all expired temporary sites within the borough cannot be counted towards meeting need
Step 3 - un-authorised sites that may potentially be suitable for regularisation	8 pitches identified on two suitable sites through HELAA and site assessment process
Step 4 - potential intensification of existing sites	The HELAA and site assessment process identify potential however delivery of such sites cannot be guaranteed
Step 5 - potential extension of existing Traveller sites or sites which could be regularised	Discounted as extension on all existing sites would result in development in Green Belt
Step 7 - new Traveller sites in non-Green Belt areas	No suitable sites identified through HELAA and site assessment process
Step 8 – new Traveller sites in Green Belt areas with a focus on strategic larger allocations	5 pitches identified through HELAA and site assessment process as part of Dunton Hills Garden Village Strategic Allocation

Figure 6.4: Provision of Gypsy and Traveller Sites – A Sequential Approach

6.65 The sequential approach sets out a clear strategy to minimise the use of greenfield Green Belt land for development, existing sites are promoted before new sites are identified. The approach also shows that there is insufficient suitable land located outside the Green Belt to meet the identified need of Gypsy and Traveller pitches.

6.66 For the Traveller sites identified as being suitable for regularisation, alterations to the Green Belt boundary are not proposed so sites will remain washed over by the Green Belt. Very special circumstances will have to be demonstrated at the development management stage. Policy HP08 Regularising Suitable Existing Traveller Sites seeks to provide a case upon which very special circumstances may be demonstrated.

6.67 The Council has carried out an assessment of potential Gypsy, Traveller and Travelling Showperson sites for allocation through its Housing and Economic Land Availability Assessment (HELAA) and found some to be suitable in HELAA terms. However, it is recognised all are in the Green Belt.

6.68 With 89% of the borough within the Green Belt, serving to limit development opportunities, combined with a lack of alternative provision, it has been necessary to determine whether the need for Traveller sites justifies making an exception to the default national policy position, namely traveller sites being inappropriate development in the Green Belt.

6.69 Given that the above sites are in existing use by Travellers and will make a positive contribution to meeting the borough's identified need (as specified in Policy HP08) subject to the granting of planning permission; coupled with a lack of alternative provision in areas outside the Green Belt. In this context, and considering what may contribute to very special circumstances, the Council has taken a proactive approach, through the plan making process, to identify suitable existing traveller sites in the Green Belt suitable for regularisation.

6.70 This approach, whilst not a perfect solution, responds directly to a demonstrable need and does not create a precedent for the consideration of other sites in the future.

6.71 The approach not only secures the planning status of the sites for the current occupants, contributing to the specified need, but also provides certainty in relation to the delivery of sites to meet the needs in Policy HP07 Provision for Gypsies and Travellers.

6.72 The sites identified through Policy HP08 will still be subject to the usual planning legislation and applications will need to be submitted to formally authorise their permanent Traveller use. Applicants will be expected to comply in full with the requirements of the policy; it will also be necessary to restrict the occupancy to ensure that the site as a whole is retained for traveller occupation.

Safeguarding Permitted Sites

6.73 Across the borough, there are many existing sites which have planning permission for traveller use. Most of these were granted permission several years ago with conditions limiting occupation to those falling within the traveller definition applicable at the time and often specific to named occupants.

6.74 Policy HP09 ensures that existing sites which have planning permission or lawful use for gypsy or traveller use, will be safeguarded to guarantee that the permitted use as a traveller site is not lost through the grant of any subsequent planning permission, or relaxation of planning conditions, to allow for other types of development.

Sub-division of Pitches or Plots

6.75 It is recognised that during the Plan period, there may be a demonstrable need for additional pitches on those sites safeguarded or allocated through the Local Plan, to meet the changing needs of the households on the sites.

6.76 With 89% of the borough within the Green Belt, serving to limit development opportunities, the sub-division of existing sites to provide more pitches could be a suitable way to increase provision within existing lawful sites without the need to consider the allocation of additional sites upon plan review.

6.77 As all safeguarded sites (with the exception the Dunton Hills Garden Village allocation) remain washed over by Green Belt, very special circumstances will have to be demonstrated at the development management stage. Therefore, in the application of this policy, a key issue will be establishing a demonstrable need for an additional pitch coupled with a lack of suitable alternative accommodation; as such the Council will require the applicant to clearly demonstrate the need for an additional pitch, and that the lack of alternative accommodation requires an additional pitch. Only if such need can be demonstrated will the Council look to support such an application in accordance with the criteria set out in Policy HP10.

Proposals for Gypsies, Travellers and Travelling Showpeople on Windfall Sites

6.78 This policy applies to non-allocated or safeguarded sites which may come forward during the Plan period in built-up areas and the countryside.

6.79 The policy excludes land in the Green Belt. National planning policy establishes a general presumption against inappropriate development in the Green Belt. The definition of inappropriate development includes Gypsy and Traveller sites and Travelling Showpeople sites. Subject to the best interests of the child, personal circumstances and unmet need are unlikely to clearly outweigh harm to the Green Belt and any other harm so as to establish very special circumstances.

6.80 When permission is granted, appropriate conditions or planning obligations will be imposed to ensure occupation of the site is restricted to those persons falling within the appropriate definition of Gypsies and Travellers and may also include conditions relating to landscaping and boundary treatments.

Design and Place-making

Good Design

6.81 Good design is a key aspect of sustainable development and is intrinsic to good planning. The built environment, the architecture and sense of place that it comprises of, are things that no one can avoid, and upon which people from every age and background have a view. The form, layout and character of buildings and public spaces contribute greatly in building communities, creating quality of life, improving health and well-being, making effective use of land, and facilitating activities and services.

6.82 The term 'high quality design' is frequently used yet is frequently misunderstood as architectural styles. Although visual appearance and the architecture of individual buildings are very important factors, high quality and inclusive design go beyond aesthetic considerations and address the connections between people and places and integrated new development into the natural, built and historic environment.

6.83 The Council attaches great importance to high quality and inclusive design for all development - including individual buildings, public and private spaces and wider area development schemes.

6.84 The Essex Design Guide 2018 is a useful starting point for a development and provides guidance regarding amenity standards, layouts and case studies. The Essex Design Guide also contains five cross cutting themes (ageing population, digital & smart technologies, health & wellbeing, active design, garden communities. For area within or in the vicinity of Brentwood Town centre, applicants should refer to the Brentwood Town Centre Design Plan and Design Guide^[3]. The Design Plan sets out how future development opportunities can collectively enhance Brentwood Town Centre, whilst Design Guide provide specific design guidance for development proposals in the area.

6.85 The NPPF is clear that applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Therefore, early discussion with the Council and the local community about the design of emerging schemes is important for clarifying expectations and reconciling local and commercial interests.

6.86 Different elements of place making may be more or less important than others, depending on the nature and complexity of the site and its surroundings.

6.87 A key aspect of design that should be integral in all development proposals is its role in creating a safe and accessible environment which minimises the opportunities for terrorism, crime and disorder, anti-social behaviour and the fear of crime, without being overbearing or undermining community cohesion. This can be achieved by good natural surveillance, well-used walkways, appropriate lighting and a lack of potential hiding places. Optimising site layout and building design are also effective measures.

6.88 Inclusive design approach should be integrated in proposals in the outset. Enabling everyone to have safe access to places regardless of their age, ability, ethnicity, gender, faith, economic circumstance will create more inclusive communities, and improve the quality of life for people with a range of health conditions and older people. The Essex Design Guide 2018 provides guidance on residential development which is flexible and adaptable throughout its lifetime.

6.89 Reliable, high speed internet has become a necessity for many people and is likely to become more so in the future. Developments should provide current best practice high speed connections direct to each premises, domestic or commercial in line with Policy BE10 Connecting New Developments to Digital Infrastructure. Development should provide the technologies which are considered best practice available at the time of development. Connections to other digital technologies should likewise be incorporated at the time of construction, to give occupiers the early benefit of the new technologies and to avoid disruptive and unsightly retrofitting.

6.90 Mitigation solutions through design for poor air quality and noise exposure from both external and internal sources should be integral to development proposals and be considered early in the design process. Especially in urban areas or areas that are close to key traffic routes, roundabouts and junctions.

6.91 An important part of making successful places is to ensure that new buildings are attractive, appropriate in their setting and fit for purpose. Their massing, scale and layout should enhance, activate and appropriately frame the public realm, complement the existing streetscape and surrounding area.

6.92 The Council expects issues within Policy HP13 Creating Successful Places, Policy HP14 Responding to Context, Policy HP15 Permeable and Legible Layout, Policy HP16 Building Design and Policy HP18 Designing Landscape and the Public Realm, to be positively addressed through the Design and Access Statements that accompany applications. The Design and Access Statements will show an analysis of the site context, and an explanation and justification of the principles that have informed the design rationale.

6.93 The Council will require design to be addressed in the pre-application process on major developments and in connection with all heritage sites. For major sites/strategic sites and complex developments, design codes will need to be prepared in conjunction with the Council and local stakeholders to ensure appropriate character and high-quality design is delivered throughout. Reference to existing Masterplans must be made, as applicable. Design codes will usually be prepared between outline and reserved matters stage on larger sites, especially those whose development will be spread over long periods and involve more than one developer to set out design principles for the development of the site. The level of prescription will vary according to the nature of the site.

6.94 Brentwood's environment, its significant natural and historic features are of high value and need to be protected and enhanced by means of improving the quality of development. Proposals that show a thorough understanding of the context of the site and demonstrate how the design proposal is sympathetic to its context, reinforcing local distinctiveness and sense of place are more likely to be successful.

6.95 The context of a development is the setting of a site or area, a proposal that responds positively to its context is one that will either enhance it or will seek to introduce distinctiveness to areas lack of character. When undertaking context appraisals and Design and Access Statements^[4], applicants should consider^[5]:

1. the built context: providing a demonstrable appreciation of built form in the vicinity covering analyses of building style, form, height and as well as the pattern of streets and spaces, morphology, skylines and landmarks;
2. the environmental context: open spaces, bio-diversity structure, landscape character, areas liable to flood;
3. the functional context: examining the existing activities and functions in the vicinity of the site including the existing pattern of uses, economic development initiatives, health, education & community facilities and public art;
4. the spatial context: identifying the development site's position within the urban hierarchy;
5. the operational context: showing how infrastructure and facilities are used and their capacity to accommodate further demands;
6. the community context: seeking to determine the reasonable and realisable needs and demands for space within an area and to associate these demands with the known existence of vacant or under-used space and the potential for creating new space; and
7. the historic context: seeking to encourage new development that respects and fits and is informed in with the character of traditional historic form of the Essex towns and villages the development will take place within.

The Council expects all the issues within this policy to be positively addressed through the Design and Access /Planning Statements that accompany applications.

6.96 Where development is in the vicinity of any of Brentwood's distinctive natural, cultural or historic assets, delivering high quality design that complements the asset will be essential.

6.97 Having identified and responded to the opportunities and constraints of the surroundings are prerequisite to creating successful places that are attractive, enjoyable and available to everyone. Such places are important to the quality of life in Brentwood.

6.98 Permeable and legible layout is at the heart of good design and making successful places. Applicants are encouraged to optimize the layout, including spaces between and around buildings, to form a coherent pattern of streets and blocks. The overarching layout of a site should be informed by its context rather than technical demands of traffic.

6.99 The resulting street system should be well-connected and offers a choice of direct routes to all destinations, as well as allows easy, effective orientation and navigation. The streets, especially in residential schemes, should be designed around pedestrian use or cycleways, with particular attention given to ensuring accessibility and safety to the elderly or disabled.

6.100 Another key consideration when designing a site layout is the nature and function of the spaces between buildings. Site layout should ensure that buildings relate successfully to one another and have no adverse impact on the amenity of occupiers. Spaces that are safe and welcoming in the long-term are those that eliminate the opportunity for anti-social activity through the placing of building fronts and treatment of spaces.

6.101 Existing landscape features on site such as trees, ponds and built-forms of value could also be integrated in the layout to establish a sense of place and/or a sense of legibility. The incorporation of existing landscape features is particularly important to people with dementia, as familiar landmarks can serve as visual cues to aid in wayfinding.

6.102 Attention should be paid to the design of the parts of a building that people most frequently see or interact with, i.e. the ground plane and its legibility, use, detailing, materials and entrances.

6.103 New developments should be designed and managed so that online deliveries and goods deliveries can be received without causing unacceptable disturbance to residents and traffic.

6.104 Bin storage for dry recyclables and waste should be considered in the early design stages to help improve recycling rates, reduce smell and vehicle movements, and improve street scene and community safety.

6.105 Buildings and the spaces around them, landscape, public realm and boundary treatment should be thought about holistically; these external spaces are as important as the building itself.

6.106 This policy should be read in conjunction with Policy BE01 Future Proofing, Policy BE02 Sustainable Construction and Resource Efficiency, Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency, BE07 Managing Heat Risk, Policy BE10 Connecting New Development to Digital Infrastructure, Policy BE17 Parking Standards, Policy HP06 Standards for New Housing, Policy HP13 Creating Successful Places, Policy HP14 Responding to Context, Policy HP15 Permeable and Legible Layout, Policy HP18 Designing Landscape and the Public Realm, Policy BE18 Green and Blue Infrastructure, and Policy BE19 Access to Nature. Applicants should also refer to best practice and guidance set out in the Essex Design Guide.

6.107 Hard surfacing of front gardens to provide car parking can be harmful to the appearance of residential areas, giving rise to the loss of walls, hedgerows and other features which may contribute positively to its character. In addition, where either side of a street are paved over, it makes the road appear wider and may result in reduced on-street parking and increased traffic volumes and speeds. This creates a much less pleasant living environment for residents.

6.108 The replacement of front gardens with hard surfacing can place extra pressure on surface water drainage resulting in increased runoff with the potential for increased surface water flooding, increased pollution of watercourses and a negative impact on biodiversity and wider ecological networks. Under the Highways Act, it can be an offence to drain water from a property on to the footway.

6.109 Where permission is required, proposals will be assessed in terms of their impact on surface water flooding in an area, impact on the character and setting of an area, and whether they would result in a net loss of biodiversity.

Landscape and Public Realm

6.110 The public realm, also known as public space or public domain, comprises features such as streets, paths, squares and urban green spaces. The success of places is ultimately judged by how enjoyable they are to use or visit. In the public realm, the space between buildings, how it all comes together, how grey and green infrastructure is integrated, how built form and spaces relate, matter as much as the buildings themselves. How buildings and adjacent spaces function and relate to each other has a strong bearing on how safe, convenient and attractive a place looks and feels as a whole. These qualities matter in development of all sizes.

6.111 Well-designed landscape and public realm are fundamental to health and well-being. Creating a well-used and active public realm also helps to foster a sense of community and reduces crime. Applying the principles of this policy will help ensure that new development positively enhances the public realm, securing improvements where needed for the Plan period and beyond.

6.112 The design, layout and landscaping of development scheme should support active lifestyle, community interaction and economic vitality. Proposals should seek to join up the landscape features and open spaces to create coherent linked landscape networks which can be used to encourage people to be active. It should facilitate the use of public transport, walking and cycling, make it easy for people to get around by means other than the car.

6.113 Landscaping and urban greening should be designed to ecologically enhance and, where appropriate, physically connect existing parks and open spaces. Green space can be used as a community resource and provides recreational benefits, aids social cohesion, improves quality of life and increases property values. Trees and plants contribute to tackling climate change as well as providing habitats for different species.

6.114 There has been substantial clinical evidence^[6] to suggest that exposure to an outdoor green environment can considerably reduce stress. Simply being able to view nature can produce significant recovery or restoration from stress within 3-5 minutes. The provision of shade, shelter, resting points and seating, a refuse receptacle as well as natural surveillance, make such places more attractive to use. In addition, they are equally accessible to people with a wide range of physical and mental abilities. The Council therefore encourages making effective use of green spaces to better support the broad needs, including mental health needs, of Brentwood residents.

6.115 In light of forecast increase in the number of older people in Brentwood over the coming years, it is vital to accommodate the needs of people with a range of health conditions and older people.Policy HP13 Creating Successful Places provides the principles of inclusive design to enable an increasingly aging society to get out and about in the areas in which they live and connect with other people and services in the immediate neighbourhood and beyond. Accommodating the needs of older people requires the introduction of standardised measurements and designs that enable dwellings to withstand the loads of mobility or safety aids. The Building Regulations Part M4 Category 2 (Accessible and Adaptable Dwellings) should be adopted into all new designs so as to correctly address such fundamentals of accessibility and approach. New homes should also consider designing to accommodate the shift towards digital healthcare.

6.116 Stimuli targeted at each of the senses (sight, scent, touch, sound and taste) should be incorporated into the landscape structure from the outset, to ensure that the development caters for people of all physical and mental abilities. This relates to both the natural, soft elements of the landscape – such as planting – and hard elements like sculptures, water features and furniture. Planning for users of all abilities and ages from the beginning can reduce the need for costly future adaptations.

6.117 The lighting of the public realm needs careful consideration to ensure it is appropriate to address safety and security issues and make night-time activity areas and access routes welcoming and safe, while also minimising light pollution.

6.118 Proposals should refer to the most up to date urban design principles and guidance, including Brentwood Town Centre Design Guide, Essex Design Guide 2018, Manual for Streets, Building for Life, Secured by Design. This policy should be read in conjunction with Policy HP06 Standards for New Housing, Policy HP13 Creating Successful Places, Policy BE18 Green and Blue Infrastructure and Policy 22 Open Space in New Development.

(1) Heritage

6.119 Brentwood Borough is rich in heritage assets - built, landscape and cultural. Brentwood's organic growth is recognisable by the historic settlement patterns for its villages and hamlets, these are largely sited on routes to and from London and East Anglia and often interspersed by high quality green infrastructure.

(1) 6.120 Brentwood's landscapes and villages are well documented by the Historic Environment Records^[7], its places, green areas and distinctive characteristics are often joined by historic thoroughfares which have grown over centuries into main routes following the urban expansion in the town at the end of the 19^th century.

6.121 The Council positively encourages the enhancement and understanding of the significance of heritage assets and apportions great weight to the protection of the heritage assets in any decision-making process for future development.

Heritage Assets

6.122 In Brentwood Borough, there are more than 500 entries on the statutory list of buildings of architectural or historic interest^[8], 12 scheduled monuments and 2 Grade II* registered parks and gardens. In addition, the borough contains 13 designated Conservation Areas.

6.123 Understanding the significance of heritage assets whether of national designation or local significance is fundamental to their care, protection and long-term conservation. The term 'heritage assets' refers to those buildings, places or areas of national importance, registered on the Statutory list, but also includes those buildings, places or areas that are of local significance, these are referred to as non-designated heritage assets.

6.124 Designation affords a building, site or area of special interest and value which is protected under law or policy.

(1) 6.125 Non-designated heritage assets can include buildings, places, lanes or areas of cultural and/or local significance which whilst not nationally designated make a positive contribution to the Historic Environment and its understanding. In decision making, proposals which affect locally listed heritage assets and/or their setting, must take into account the strong requirement for their retention and the enhancement of their significance locally.

6.126 Locally listed buildings within the borough are to be recorded on a live database. Whilst the Local Listing Programme is at embryonic stage, this list and its future enrichment is essential in conserving local distinctiveness and community engagement in the historic environment. The Council supports the ethos of local listing and the opportunities it brings to engage a diverse range of stakeholders into the management and education of the local historic environment.

6.127 The Council will apply a level of protection to and keep under review its heritage assets in order to preserve, and where appropriate enhance their special architectural or historic interest. A high standard of design for all new development affecting Heritage Assets and their setting is required.

6.128 When submitting planning applications, applicants are required to describe the significance of any heritage assets affected, together with a schedule of works analysing the impact of the proposal on the form, fabric and setting of the heritage asset and any features of historic or architectural interest. The level of detail needed should be proportionate to the scale and nature of the proposal and the importance of the asset itself. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed, using appropriate expertise where necessary.

6.129 The NPPF is clear that when considering the impact of a proposed development on the significance of a designated heritage asset, the more important the asset, the greater the weight should be given.

6.130 Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.

6.131 Early engagement with the Council's Historic Buildings Advisor is encouraged through pre-application consultation.

6.132 Listed buildings are defined under Section 1 of the Planning (Listed Buildings and Conservation Areas) Act 1990, as 'buildings of special architectural or historic interest'. The Secretary of State is required to compile or approve listed buildings for the guidance of local planning authorities. There are 512 listed buildings^[10] within the borough, consisting of:

• 12 buildings of Grade I (buildings of exceptional interest)
• 27 buildings of Grade II* (particularly important buildings of more than special interest)
• 473 buildings of Grade II (buildings of special interest, which warrant every effort being made to preserve them).

6.133 This policy addresses the statutory considerations of the Planning (Listed Buildings and Conservation Areas) Act 1990 which provides specific protection for buildings and areas of special architectural or historic interest as well as relevant polities within the NPPF.

6.134 Where there is evidence of deliberate neglect of or damage to a heritage asset the deteriorated state of the heritage asset will not be taken into account in any decision.

6.135 Works such as the demolition, alterations (both internal and external) or extensions that would affect a listed building's character will require listed building consent.

6.136 Proposals affecting listed buildings should refer directly to the statutory list of Buildings of Special Architectural or Historic Interest^[11]. Under the Planning (Listed Buildings and Conservation Areas) Act 1990 owners have a responsibility to look after listed buildings in order to prevent deterioration and damage. The Council will intervene, where necessary, by issuing an Urgent Works or Repairs Notice.

6.137 National policy and guidance promotes the use/reuse of heritage assets for viable uses consistent with their conservation and the positive contribution that they can make towards economic vitality. Changes of use of a listed building need to be compatible with the building's character and should not have an adverse impact on its context. Proposals for the change of use of a listed building in the Green Belt will also be assessed against development in the Green Belt policies within this Plan.

6.138 Proposals will be required to take a practical approach towards the alteration of listed buildings to comply with the Equality Act 2010 and subsequent amendments, provided that proposed alterations and changes to access are sympathetic and ensure the building's special interest remains unharmed. Applicants should refer to the Historic England Easy Access to Historic Buildings (2015) as a basis for practical guidance.

6.139 The Council intends to compile a local list of buildings which contribute positively to the character of the area due to their townscape value and merit, type of construction, architectural quality or historic association. The Council will apply similar levels of preservation to its locally designated heritage assets and their settings in line with national policy and guidance to ensure a high standard of design for all new development affecting the character or setting of its built, natural and historic environment. Whether a building is locally listed will be a material consideration in determining planning applications in order to retain important original features and fabric, and control alteration or extension to maintain the character of the buildings in recognition of their contribution to local distinctiveness, sense of place, identity and character.

6.140 Conservation Areas are defined under Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990, as 'Areas of Special Architectural or Historic Interest the character or appearance of which it is desirable to preserve or enhance'. With a rich and varied cultural heritage, Brentwood has 13 designated Conservation Areas within the borough. Conservation Areas are shown on the Brentwood Policies Map.

6.141 This policy addresses the statutory considerations of the Planning (Listed Buildings and Conservation Areas) Act 1990. It should be read in conjunction with Policy HP19 Conservation and Enhancement of Historic Environment and Brentwood's Conservation Area Appraisals.

6.142 The Council will seek to promote high quality new development of exceptional design that makes a positive contribution to local character and respects the historic context. Development proposals in a Conservation Area should make reference to the relevant Conservation Area appraisal.

(1) 6.143 There will be a presumption against the demolition of buildings or other features that positively contribute to the character or appearance of a Conservation Area, in the absence of detailed and acceptable proposals for replacement development. Use of non-traditional materials, will not normally be permitted on, or in proximity to, listed buildings or in Conservation Areas. For advice on this matter, applicants should consult local expertise and refer to published guidance, such as Valuing Places: Good Practice in Conservation Areas by English Heritage (2011).

6.144 In order to ensure a high standard of design and materials, outline applications will be accepted.

Local List

6.145 Locally listed buildings will be a material consideration in determining planning applications: the retention of important features and fabric and the impact of proposals upon the local significance and understanding of a locally listed building will be a material consideration.

6.146 There are a number of country lanes and byways which are of historic and landscape value, and which make an important contribution to the rural character of the borough. The Council will seek to prserve these lanes and byways as far as possible, including their trees, hedgerows, banks, ditches and verges, which contribute to their character, and by resisting development proposals which have a detrimental effect upon them.

Protected Lanes

6.147 The greater part of the road network in the Essex countryside derives from at least as far back as the medieval period. Much of it undoubtedly existed in Saxon times. These lanes are part of what was once an immense mileage of minor roads and track-ways connecting villages, hamlets and scattered farms and cottages. Many were used for agricultural purposes, linking settlements to arable fields, grazing on pasture, heaths and greens; and other resources such as woodland and coastal marsh.

6.148 Before metalled road, with wide verges and linear roadside green with ditches and interspersed with ponds for transporting, feeding and watering livestock on route to market. These lanes are an important part of the Essex landscape, providing insight into the development of a landscape and the relationship of features within it over time. They have considerable ecological value as habitats for plants and animals, serving as corridors for movement and dispersal for some species and acting as vital connections between other habitats; and promoting well-being.

6.149 The Protected Lanes in Brentwood are listed below:

National Street Gazetteer Name (NSG)	Location	Lane ID
Days Lane	Doddinghurst	BRWLANE1
Wenlocks Lane	Blackmore	BRWLANE2
Lincolns Lane	Coxtie Green	BRWLANE3
Hay Green Lane	Wyatt's Green	BRWLANE4
Mill Lane	Navestock Health	BRWLANE5
Sabines Road	Sabines Green	BRWLANE6
Back Lane	Doddinghurst	BRWLANE7
Dark Lane	Great Warley	BRWLANE8
Sandpit Lane	South Weald	BRWLANE9
Little Hyde Lane	Fryerning	BRWLANE10
Mill Green Road	Mill Green Common	BRWLANE11
Ingatestone Road	Mill Green Common	BRWLANE13
Ivy Barns Lane	Mill Green Common	BRWLANE12

Figure 6.5: Protected Lanes in Brentwood

6.150 Recent assessment of the Protected Lanes^[12] and update^[13] in Brentwood has confirmed that these features remain and in the majority of instances, the designation for protection is recommended for retention. One lane has been identified as at risk, partly due to damage as a result of its increased use as a cut through in the recent past when the Ongar Road suffered a major collapse, that is Sandpit Lane. The Council will be taking a watching brief on this lane, aware that some damage has already taken place. Brentwood Borough is therefore retaining the designation of all of the Protected Lanes with a review proposed for the next edition of the Local Plan.

6.151 In line with other policies within the Local Plan, material increases in motorised traffic using a Protected Lane due to development proposals must be assessed and action/infrastructure to influence user behaviour and encourage more sustainable modes of transport, will be required.

6.152 The Council would consider exploring options and partnerships for influencing user behaviour and applying intelligent and positive measures of highway management that will serve to encourage local journeys to be made on bicycle or foot, and for recreation, and reduce the impact of vehicles on the historic fabric of lanes, whilst maintaining their local character.

Archaeological Heritage

6.153 The historic environment of Brentwood has developed through a history of human activity that spans over 450,000 years. Much of the resource lies hidden beneath the ground in the form of highly sensitive and non-renewable archaeological deposits. Other elements such as the historic landscape, the pattern of field, farms, woods and historic settlements which characterise the borough are a highly visible record of millennia of agriculture, industry, settlement and commerce.

6.154 Brentwood has a large number of sites of archaeological importance that are worthy of preservation for the future. Essex Historic Environment record identifies 636 sites within the borough of known archaeological interest. These include isolated discoveries like Stone Age flint axe, below ground evidence of prehistoric, Roman, Saxon and medieval occupation and upstanding post medieval and modern structures. Of known sites, 12 are scheduled ancient monuments, maintained by the Secretary of State under Section 1 of the Ancient Monuments and Archaeological Areas Act 1979, ensuring ultimate responsibility for the preservation, treatment, repair and use of each monument.

6.155 For applications affecting a scheduled monument and its setting, early stage consultation with English Heritage will be required to gain scheduled monument consent. For non-statutory historic environment assets applicants should consult the Council and as appropriate, Essex County Council historic environment advisors, regarding the nature, setting and management of the borough's historic environment.

6.156 As a finite and non-renewable resource, archaeology can become highly fragile and vulnerable to damage or destruction. The Council will adopt a presumption against proposals which would harm the setting of archaeological remains of national or local importance, whether scheduled or not.

6.157 In cases where development will impact upon sites of known archaeological interest or potential, the results of a field evaluation/assessment will be necessary prior to the determination of the application. Applicants will be required to arrange for an archaeological investigation setting out appropriate measures of protection, management or mitigation including excavations and recording prior to development.

6.158 This policy should be read in conjunction with Policy HP19 Conservation and Enhancement of Historic Environment.