Schedule of Potential Main Modifications

Ended on the 11 November 2021

Chapter 5



Page Number 64, Policy BE01, Paragraph 5.8 - 5.12


Delete policy BE01 and paragraphs 5.8 to 5.12.


To ensure consistency with national policy and effectiveness of the plan. The wording of this policy reads as a statement of intent so should be deleted.




Page Number 67 - 68, Policy BE02


Delete Policy BE02.


Policy has been covered by other policies, particularly BE03, BE04 and BE08, therefore should be deleted




Page Number 67 - 76, PolicyBE03, Paragraph 5.17 - 5.19, Paragraph 5.23 - 5.36, Figure 5.1, Figure 5.2


Move paragraph 5.17 - 5.19 and Figure 5.1 to sit after paragraph 5.35 to support Policy BE03: Carbon Reduction and Renewable Energy (now Policy BE01).

Amend Policy to read:


A. Proposals for renewable, low carbon or decentralised energy schemes will be supported provided they can demonstrate that they will not result in adverse impacts, including cumulative and visual impacts which cannot be satisfactorily addressed.

B.  A.  Carbon Reduction and Construction Standards

Development should meet the following minimum standards of sustainable construction and carbon reduction as set out below:

a. New residential All major development: will be required to achieve at least a 10% reduction in carbon dioxide emissions above the requirements of Part L Building Regulations; and

Minimum sustainable construction standards: In line with Part L Building Regulations.

On-site carbon reduction: in line with national nearly-zero carbon policy. If national nearly- zero carbon policy is unavailable, the previous target applies. However, the minimum improvement over the Building Regulations baseline may be increased to reflect the reduction in costs of more efficient construction methods.

Water efficiency: 110 litres per person per day limit. Major development is expected to provide more substantial water management measures, such as rain/grey water harvesting.

Delete the table under B.a

b. New non-residential development: will be required to achieve a certified BREEAM 'Excellent' rating under the BREEAM New Construction (Non-Domestic Buildings) 2018 scheme, or other equivalent standards to be achieved in the following categories: Man 02; Ene 04; Mat 03; Wst 01; Wst 03; LE 03.

On-site carbon reduction: in line with national nearly-zero carbon policy. If national nearly- zero carbon policy is unavailable, the previous target applies. However, the minimum improvement over the Building Regulations baseline may be increased to reflect the reduction in costs of more efficient construction methods.

Water efficiency: BREEAM 'Excellent' rating to be achieved in category Wat 01. Major development is expected to provide more substantial water management measures,such as grey waterharvesting.

Delete the table under B.b.

C. B. Renewable Energy

Application of Wherever possible, major development, where feasible, will be required to provide a minimum of 10% of the predicted energy needs of the development from renewable energy;. Where on-site provision of renewable technologies is not appropriate, or where it is clearly demonstrated that the above target cannot be fully achieved on-site, any shortfall should be provided through:

a. 'allowable solutions contributions' via Section 106 or CIL. These funds will then be used for energy efficiency and energy generation initiatives or other measure(s) required to offset the environmental impact of the development; or

b. off-site provision, provided that an alternative proposal is identified, and the measures can be secured.

D. C. Applications for major development, including proposals involving the redevelopment of existing floor space, should be accompanied by a Sustainability Statement (see Figure 5.1 Areas to be covered in the Sustainability Statement) as part of the Design and Access Statement submitted with their planning application, outlining their approach to the following issues:

i. adaptation to climate change;
ii. carbon reduction;
iii. water management;
iv. site waste management; and
use of materials.

E. D. Where it is not possible to meet these standards are not met, applicants must demonstrate compelling reasons and provide evidence, as to why achieving the sustainability standards outlined above for residential and non-residential developments would not be technically feasible or economically viable.;

F. Merge clause F with the former clause C (now clause B).

Amend paragraph 5.18 and 5.19 to read:

5.18 Sustainable design and construction are concerned with the implementation of sustainable development in individual sites and buildings. It takes account of the resources used in construction, and of the environmental, social and economic impacts of the construction process itself and how buildings are designed and used. Major development should also refer to Policy SP05 Construction Management.

5.19 The choice of sustainability measures and how they are implemented may vary substantially from development to development. However, the general principles of sustainable design and construction should be applied to all scales and types of development. The Sustainability Statement should demonstrate how proposals avoid increased vulnerability to the impacts arising from climate change through sustainable and resilient design. The Sustainability Statement should be proportionate to the proposed scale of development and clearly set out, providing sufficient detail on how sustainable design solutions have been integrated for both the construction and operation phases of the development. More guidance on areas to be covered in the Sustainability Statement is set out in Figure 5.1.

Amend Figure 5.1 to remove reference to Figure 5.2 and amend the paragraph under section Use of Materials to read:

[...] Although this is not a policy requirement, the Council will encourage all developers All new developments should be designed to maximise resource efficiency and identify, source, and use environmentally and socially responsible materials. [...]

Delete paragraphs 5.24, 5.25, 5.27, 5.28, 5.31, 5.33, 5.36 and Figure 5.2

Amend paragraph 5.23, 5.26, 5.29, 5.30, 5.32 to read:

5.23 Transport emission in the borough is also higher than the national average due to increased car ownership and access to vehicles. Over the period of the Plan, energy use and carbon emissions may increase by 10% following a 'business as usual' trajectory.

5.26 However, tThe Climate Change Act 2008 (2050 Target Amendment) Order 2019commits the UK Government by law to reducing greenhouse gas emissionsby at least 80% of 1990 levels to zero by 2050. In addition, as long as the UK is a member of the EU, it still has to comply with the EU's Energy Performance of Buildings Directive, which requires that by 2020 the demand from all new buildings in Member States is 'nearly zero-energy'. The Paris Agreement also has implications on the UK carbon reduction target.

5.29 The government originally set targets to ensure all new homes are zero carbon by 2016 and all new non-residential buildings are zero carbon by 2019.Improvements in resource efficiency to meet this the government's carbon target was were made through Building Regulations which set standards for design and construction that applies to most new buildings, regardless of type.In 2016, Part L of the Building Regulations introduced a change to the energy efficiency standard, raising it to the equivalent of Code for Sustainable Homes Level 4.

5.30 However, local authorities can still require energy efficiency standards above Building Regulation, as allowed by tThe Planning and Energy Act 2008 allows local authorities to set local targets for carbon emissions above Building Regulations. The Deregulation Act 2015 (S43) which removes this right has not been enacted, meaning authorities can continue to set policy above Building Regulations. and confirmed by the government in its summary response to the NPPF 2018 consultation.

5.32 To contribute to these targets As such, this policy requires an on-site reduction of at least 10 per cent beyond the baseline of part L of the current Building Regulations on major development. The minimum improvement over the Target Emission Rate (TER) will be increased in 2020 and over a period of time in line with the national zero-carbon policy and reflect the costs of more efficient construction methods. This takes into account the Local Plan Viability Assessment (2018)'s recommendation that the Council to only seek standards that are over and above those set out in Building Regulation in the case of major development where there is a requirement for 10% renewable energy.


To ensure that the policy is consistent with national policy, justified and effective.
Part A is covered by Policy BE04: Establishing Low Carbon and Renewable Infrastructure Network (now Policy BE03)

The Viability Assessment advises to only seek standards that are over and above the Building Regulation from major development where there is a requirement for 10% renewable energy.

Requirements relating to water efficiency are moved to a new policy dedicated to the subject.

The pre-2020 requirements are no longer relevant. The remaining requirements are converted into clauses/sub-clauses.

The additional text is originally set out in Clause F, which is now merged with clause C, as both refer to renewable technologies.

To be consistent with recent changes to the legislation and Government's direction, published after the Plan was submitted




Page Number 77 , New Policy BE02, Paragraph 5.38 - 5.40


Insert a new policy to read:


A. Water Efficiency

Development should incorporate water conservation measures in the proposals and meet the minimum standards for water efficiency as set out below:

a. New residential development will be required to achieve limits of 110 litres per person per day.

b. New non-residential development is expected to meet BREEAM 'Excellent' rating in category Wat 01.

c. Major developments and high or intense water use developments (such as hotels) is expected to provide more substantial water management measures such as rain/ and grey water harvesting.

Waste Water and Sewage

B. Development proposals should:

a. seek to improve the water environment and demonstrate that adequate wastewater infrastructure capacity is provided;

b. ensure that misconnections between foul and surface water networks are eliminated and not easily created through future building alterations;

c. incorporate measures such as smart metering, water saving and recycling, including retrofitting and rain/grey water harvesting, to help to achieve lower water consumption rates and to maximise futureproofing;

C. Applications will need to demonstrate that the sewerage network has adequate capacity both on and off-site to serve the development and to assess the need to contribute to any additional connections for the development to prevent flooding or pollution of land and water courses. Where sewerage capacity is identified as insufficient, development will only be permitted if it is demonstrated that improvements will be completed prior to occupation of the development.


Water Quality

D. All development proposals should have regard to the Water Cycle Study and:


a. seek to improve water quality;

b. not cause deterioration in the quality of a water course or groundwater;

c. not lead to adverse impacts on the natural functioning of the watercourse, including quantity, flow, river continuity, groundwater connectivity, or biodiversity impacts;

d. where development is likely to have an impact, proposals must set out how impacts will be mitigate.

Move paragraph 5.38 - 5.40 on water efficiency to follow new Policy BE02 Water Efficiency and Management


All water efficiency and management requirements set out in policies BE02, BE03, BE18 and NE06 of the Submitted Plan should be contained within a dedicated policy. Whilst the Council considers these requirements sound, this modification is necessary to ensure the plan is effective and consistent with national policy

Originally set out in Policy BE02 criterion c of the Submitted Plan

Originally set out in Policy BE03 clause B.a. of the Submitted Plan

Originally set out in Policy BE03 clause B.b of the Submitted Plan

Originally set out in Policy BE03 clause B.a. and B.b of the Submitted Plan

Originally set out in Policy BE18, B.f of the Submitted Plan

Originally set out in Policy BE18, B.g of the Submitted Plan

Originally set out in Policy BE18, B.h of the Submitted Plan

Originally set out in Policy NE06 clause D and E of the Submitted Plan

These requirements provide clarity and certainty and ensure consistency with national policy.

To support the relevant requirement and ensure the policy is justified




Page Number 77 , Policy BE04, Paragraph 5.43, Paragraph 5.47, Paragraph 5.48


Amend policy to read:


A. Stand-alone rRenewable energy infrastructure

Community-led initiatives for renewable and low carbon energy, including developments outside areas identified in this Local Plan or other strategic policies that are being taken forward through neighbourhood planning, will be encouraged, subject to the acceptability of their wider impacts, including on the Green Belt.

Innovative approaches to the installation and/or construction of energy generation facilities or low carbon homes which demonstrate sustainable use of resources and high energy efficiency levels will be supported.


B. Decentralised energy infrastructure

a. The Council will work with developers and energy providers to seek opportunities to expand Brentwood's decentralised energy infrastructure.

Strategic development that could play a key role in establishing a decentralised energy network should engage at an early stage with the Council, stakeholders and relevant energy companies to establish the future energy requirements and infrastructure arising from large-scale development proposals and clusters of significant new development. Applicants of these sites will prepare energy masterplans which establish the most effective energy strategy and supply options.

b. New development proposals of over 500 dwelling units, or including brownfield and urban extensions at 500 units or more, or where the clustering of neighbouring new sites totals over more than 500 units, will be expected to should include energy masterplans to incorporate decentralised energy infrastructure in line with the following hierarchy:

i. where there is an existing decentralised heat network with sufficient capacity or the capacity to expand, new development will be expected to connect to it;

ii. where there is no existing decentralised heat network with sufficient capacity or the capacity to expand, new development will be expected to deliver an onsite heat network, unless it can be demonstrated to the Council's satisfaction that this would render the development unviable;

iii. where a developer is unable to deliver the a decentralised heat network, they need to it will need to be demonstrated to the satisfaction of the Council that they applicant hasve worked in detail with third parties (commercially or community) to fully assessed all reasonably available options for its incorporation and delivery and has the opportunity; iv.   where a heat network opportunity is not currently viable and no third party is interested in its delivery, the development should be designed the development to facilitate allow future connection to a heat network unless it can be demonstrated that a lower carbon alternative has been put in place.

c. C. New development will be expected to demonstrate that the heating and cooling systems have been selected according to the following heat hierarchy:

i. connection to existing CHP/CCHP distribution network;
ii. site-wide renewable CHP/CCHP;
iii. site-wide gas-fired CHP/CCHP;
iv. site-wide renewable community heating/cooling;
v. site-wide gas-fired community heating/cooling;
vi. individual building renewable heating.

C. Move Part C to A

D. Delete Part D

Amend paragraphs 5.43, 5.47 and 5.48 to read:

5.43 According to the International Renewable Energy Agency (IRENA, 2018), renewable energy will be cheaper than fossil fuels by 2020 thanks to as a result of improvements in technology. The recent Global Status Report by REN21 (2018) also states that renewable energy currently makes up a fifth of the world's electrical power supply, and its capacity has doubled over the past ten years. Renewables are experiencing a virtuous cycle of technology improvement and cost reduction. How policies can support the ability to connect with supply grid, rather than viability, will be the main challenge in the transition towards the low carbon future.

5.47 The East of England resource assessment and the Brentwood Renewable Energy Study 2014 suggest that there are unlikely to be major anchor and high heat density areas in the borough suitable for retrofit-only DH networks. New development will therefore play an important role in heat network development in the borough. Strategic allocations could play a key role in establishing a decentralised energy network, offering great opportunities to create or expand the borough’s decentralised energy infrastructure and were identified in the Brentwood IDP, these include:

i.    Sites in the South Brentwood Growth Corridor masterplan area including Brentwood Enterprise Park and Dunton Hills Garden Village;
ii.    Warley extension masterplan area;
iii.    Officer’s Meadows masterplan area.

5.48 According to the Brentwood Renewable Energy Study (2014), DH is a viable low and zero carbon energy solution for new development; the viability of DH and CHP schemes are improved with increased scale, density and mix of uses. Smaller sites close to large exiting loads, on the other hand, provide opportunities for collaboration which provides cost effective, energy efficient, low carbon heat and electricity. Therefore, applicants of strategic sites should engage at an early stage with the Council, stakeholders and relevant energy companies to establish the future energy requirements and infrastructure arising from large-scale development proposals and clusters of significant new development.

5.52 Brentwood Borough has relatively high levels of domestic gas and electricity consumption, therefore building-scale technologies have the potentials to meet the borough's domestic energy demands. Building scale technologies often comprise permitted development and can be included in new development or retro-fitted to existing units. Building scale technologies with the greatest potential include rooftop solar technologies and biomass boilers in the commercial and industrial sector.


To make the policy effective

Part A is largely covered by Green Belt and design policies; it overlaps with part C and therefore should be combined with C.

Originally set out under part C

To remove irrelevant or outdated content




Page Number 82 , Policy BE05, Paragraphs 5.53 - 5.56


Delete Policy BE05 and supporting text paragraphs 5.53 to 5.56.


The requirements of this policy are covered by design, environment and green belt policies, and therefore should be deleted




Page Number 83 , Policy BE06, Paragraphs 5.57 - 5.61


Delete Policy BE06 and supporting text paragraphs 5.57 to 5.61.


The requirements are set out in Building Regulations




Page Number 84 , Policy BE07


Amend Policy to read:


A. All Ddevelopmentproposals should minimise internal heat gain and the risks of overheating through design, layout, building orientation and use of appropriate materials.

B. Major development proposals should demonstrate how they will reduce the potential for overheating and reliance on air conditioning systems by:

a. minimising internal heat generation through energy efficient design;

b. reducing the amount of heat entering a building through orientation, shading, albedo, fenestration, insulation and the provision of green roofs and walls;

c. managing the heat within the building through exposed internal thermal mass and high ceilings;

d. provide maximising passive ventilation; and

e. where necessary, providing mechanical ventilation and active cooling systems providing active cooling systems.


To ensure the policy is effective




Page Number 85 , Policy BE08, Paragraph 5.68


Amend policy to read:


A. All developments should incorporate appropriate Sustainable Drainage Systems (SuDS) for the disposal of surface water, in order to avoid any increase in surface water flood risk or adverse impact on water quality.

B. Development within areas identified as a Critical Drainage Area (CDA) on the policies map, should optimise the use of Sustainable Drainage Systems by providing an individually designed mitigation scheme to address the site-specific issues and risk, as informed by a site specific Flood Risk Assessment. This could be provided as part of the Drainage Strategy and must address any issues highlighted in the Surface Water Management Plan, where relevant.


B. Applications must meet the following requirements:

a. Quantity

i. C. Greenfield developments, major development and all development within a Critical Drainage Area must achieve a greenfield runoff rate. Where it is demonstrated that this is not possible on brownfield developments, SuDS features will be required to reduce discharge to previous greenfield rates or achieve a then a runoff reduction of 50% minimum should be achieved. The technical approach should be justified in the Drainage Strategy. reduction of brownfield run-off rates;

ii.  D. sites over 0.1 hectares in Flood Zone 1 will be Applicants are required to submit a surface water dDrainage sStrategy. Larger sites over 1 hectare in Zone 1 or all schemes in Flood Zone 2 and 3 must be accompanied by a Flood Risk Assessment (FRA); for all major development as well as for all development within a Critical Drainage Area. The Drainage Strategy must include a SuDs Management Plan setting out the long-term management and maintenance arrangements.

b. E. Quality SuDs will be required to meet the following design criteria:

i.  a. the design must follow an index-based approach when managing water quality. Implementation in line with the updated CIRIA SuDS Manual[1] is required. Source control techniques such as green roofs, permeable paving and swales should be used so that rainfall runoff in events up to 5mm does not leave the site;

c. Amenity and Biodiversity

i.  b. SuDS should be sensitively designed and integrated into the Green and Blue infrastructure to create high quality public open space and landscaped public realm, in line with STRATEGIC Policy NE02: Green and Blue Infrastructure;

c. maximise opportunities to enhance and located to promote improved biodiversity net-gain;

d. improve the quality of water discharges and be used in conjunction withwater use efficiency measures; , river water quality, enhanced landscape and good quality spaces that benefit public amenities in the area;

iii.  redeveloped brownfield sites should disconnect any surface water drainage from the foul network;

e. function effectively over the lifetime of the development;

iii.  f. the preferred hierarchy of managing surface water drainage from any development should be managed in accordance with this hierarchy: firstly, is through infiltration measures, secondly attenuation and discharge to watercourses, and if these cannot be met, through discharge to surface water only sewers;

g. have regard to Essex County Council SuDS Design Guide 2020, or as amended.

iv.  F. Wwhen discharging surface water to a public sewer, developers will be required to provide evidence that adequate capacity exists in the public sewerage network fully to serve the proposed development, in line with policy requirements in BE02 Water Efficiency and Management.

G. Development proposals should be designed to include permeable surfaces wherever possible. Proposals for impermeable paving, including on small surfaces such as front gardens and driveways, will be strongly resisted unless it can be suitably demonstrated that this is not technically feasible or appropriate.

Amend paragraph 5.68 to read:

SuDS must have regard to the criteria outlined in the Essex County Council SuDS Guide. The Environment Agency introduced a new classification system in 2011 enabled by The European Water Framework Directive. This system allows for more rigorous and accurate assessment of water quality. Some water bodies will never achieve good ecological status, however, because they have been physically altered for a specific use, such as navigation, recreation, water storage, or flood protection.


To make the policy effective, justified, and consistent with national policy

To clarify that this is about surface water flooding, as opposed to fluvial flooding covered by NE06 of the Submitted Plan

To ensure the mitigation measures highlighted in the Surface Water Management Plan are addressed

To align with the recommendations of the Surface Water Management Plan

The new sub clauses E.b to E.d are mostly split from the original clause (c.i.) into separate sub clauses

To refer to relevant guidance




Page Number 88, Policy BE09


Amend Policy to read:


A. The Council will supportinvestment in proposals for high quality communications infrastructure and superfast broadband, including community-based networks, particularly where alternative technologies need to be used in rural areas of the borough.
B. Applications Proposals from service providers for new or the expansion of existing communications infrastructure (including telecommunications masts, equipment and associated development, and superfast broadband) are will be supported subject to the following criteria:

a. evidence is provided to demonstrate, to the Council's satisfaction, that the possibility of mast or site sharing has been fully explored and no suitable alternative sites are available in the locality including the erection of antennae on existing buildings or other suitable structures;
b. evidence is provided to confirm that the proposals would cause no harm to highway safety;
c. the proposal hassympathetic design and camouflage, having regard to other policies in the Local Planno unacceptable impact on the character and appearance of the area, landscape or heritage impacts or unacceptable impacts on the natural environment;
d. the proposal has been designed to minimise disruption should the need for maintenance, adaption or future upgrades arise;
e. the proposal will not cause significant and irremediable interference with other electrical equipment, air traffic services or instrumentation operated in the national interest; and
f. the proposal conforms to the latest International Commission on Non-Ionising Radiation Protection (ICNIRP) guidelines, taking account of the cumulative impact of all operator equipment located on the mast/site where appropriate (i.e. prevent location to sensitive community uses, including schools).


To make the policy effective




Page Number 89 , Policy BE10


Amend Policy to read:


A. To support Brentwood's economic growth and productivity now and in the future, all development proposals should:

a. Provision of Provide up to date communications infrastructure should be designed and installed as an integral part of development proposals. As a minimum, all new developments must be served by the fastest available broadband connection, installed on an open access basis. This includes installation of appropriate cabling within dwelling dwellings or and business units as well as a fully enabled and full connection of the developed areas to the full main telecommunications network;

b. ensure that sufficient ducting space for future digital connectivity infrastructure (such as small cell antenna and ducts for cables, that support fixed and mobile connectivity and therefore underpins smart technologies) is provided where wherever appropriate possible;

c. support the effective use of the public realm, such as street furniture and bins other installations, to accommodate new state of the art well-designed and locatedintegrated mobile digital communication infrastructure;

B. When installing new and improving existing digital communication infrastructure in new development, proposals should:

a. identify and plan for the telecommunications network demand and infrastructure needs from first occupation;

b. include provision for connection to broadband and mobile phone coverage across the site on major developments;

c. b. take into account the Highway Authority's land requirements so as not to impede or add to the cost of the highway mitigation schemes where the location and route of new utility services is in the vicinity of the highway network or proposed new highway network;

d. c. ensure the scale, form and massing of the new development does not cause unavoidable interference with existing communications infrastructure in the vicinity. If so, opportunities to mitigate such impact through appropriate design modifications should be progressed including measures for re-siting, re-provision or enhancement of any relevant communications infrastructure within the new development;

e. d. demonstrate that the siting and design of the installation would not have a detrimental impact upon the visual and residential amenity of neighbouring occupiers, the host building (where relevant), and the appearance and character of the area;

f. e. seek opportunities to share existing masts or sites with other providers; and

g. f. all digital communication infrastructure should be capable of have the capacity to respond responding to changes in technology requirements over the period life of the development.

C. Where applicants can demonstrate, through consultation with broadband infrastructure providers, that superfast broadband connection is not practical, or economically viable:

a. the developer will ensure that broadband service is made available via an alternative technology provider, such as fixed wireless or radio broadband; and

b. ducting to all premises that can be accessed by broadband providers in the future, to enable greater access in the future. Or D. TheOnly where this is not practicable or viable, the Council will seek developer contribution towards off-site works to enable those properties access to superfast broadband, either via fibre optic cable or wireless technology in the future to provide like capacity.


To make the policy effective




Page Number 92, Policy BE11, Paragraph 5.90, Paragraph 5.91, Paragraph 5.92, Paragraph 5.93, Paragraph 5.96 b., Paragraph 5.102


Delete Policy BE11 and replace with the below text:


In order to support and address the cumulative impacts of planned and other incremental growth, allocated development within the Local Plan and any other development proposals shall (where appropriate) provide reasonable and proportionate contributions to required mitigation measures to strategic transport infrastructure, including:


a. circulation arrangements, public realm and multimodal integration around Brentwood, Shenfield and Ingatestone stations;

b. circulation arrangement and public realm around West Horndon station, and the creation of associated multimodal interchange through phases to support new residents and employees;

c. improvements to the highway network as deemed necessary by transport evidence or as agreed by National Highways and Essex County Council as appropriate, other statutory bodies, stakeholders and passenger transport providers; and

d. additional and/or improved pedestrian, cycling infrastructure and bus services connecting development to key destinations such as railway stations, education facilities, employment, retail and leisure.

Insert the following paragraph at the beginning of paragraph 5.90:

Strategic transport infrastructure is that which is critical to the delivery of the Local Plan as such their timely provision must be in place in order to support development. Strategic transport infrastructure are assigned a priority category 1 in the Infrastructure Delivery Plan.

Insert the following paragraph after paragraph 5.91:

The Council's positive approach to planning may require it to use its compulsory purchase powers under section 226 of the Town and Country Planning Act 1990. That power gives the Council a positive tool to help bring forward necessary works to support planned growth in the borough, where strong planning justifications for the use of the power exist and statutory requirements are satisfied.

Amend final sentence of paragraph 5.92 to read:

The Council will work with partners to improve the station environment at both Brentwood and Shenfield stations, specifically in terms of non-motorised users and enhanced public transport access, with new improved forecourt and pedestrian crossing facilities.

At the end of the first sentence of paragraph 5.93 update reference to Transport Assessment from 2018 to 2021.

Insert an additional sentence at the end of paragraph 5.96 point b. to read:

Where appropriate contributions will therefore be sought from nearby developments.

Insert a new point (iv) under paragraph para 5.102 to read:

iv. The A127 Task Force has representation from all South Essex authorities including BBC. This Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long term phasing. Whilst the A127 is the main focus ECC would be looking to work collaboratively with BBC and other councils in the area.


To provide clarity and make the policy effective

To provide clarity on the role of strategic transport infrastructure and reference to the Infrastructure Delivery Plan where further information on this would be found.




Page Number 99 - 100 , Policy BE12, Paragraph 5.108, Paragraph 5.109, Paragraph 5.110


Delete Policy BE12.

Move paragraphs 5.108, 5.109 and 5.110 to after 5.141


To make the plan effective. Limited-car development principle in sustainable locations is covered by the Parking Standards.




Page Number 100 - 101 , Policy BE13, Paragraph 5.112 - 5.115, Paragraph 5.118


Amend Policy to read:


A. Sustainable modes of transport should be facilitated through prioritised in new developments to promote accessibility and integration into with the wider community and existing networks. Priority should be given to cycle and pedestrian movements and access to public transport.
B. Development proposals should seek to provide appropriate provision for the following sustainable measures as appropriate:

a. the provision of pedestrian, cycle, public transport and where appropriate, bridleway connections within development sites and to the wider area, including key destinations;
b. the criteria of safe, secure, well connected and attractive layouts which minimise the conflict between traffic, cyclists, and pedestrians, and allow good accessibility for  passenger transport bus services within sites and between sites and adjacent areas, and where appropriate improve areas where passenger public transport, pedestrian or cycle movement is difficult or dangerous.
c. the provision of community transport measures promoting car pools, car sharing, voluntary community buses, cycle schemes;
d. safeguarding existing and proposed routes for walking, cycling, and public transport, from development that would prejudice their continued use and/or development; and
e. any development requiring a new road or road access, walking and cycling facilities and public transport, will be required to have regard to the adopted Essex County Council's Development Management Policies or successor documents, in order to assess the impact of development in terms of highway safety and capacity for both access to the proposed development and the wider highway network.

Amend supporting text paragraph 5.112- 5.115 to read:

5.112 This policy seeks to encourage ensure that development proposals will be designed to promote people to make sustainable travel choices by improving choices and making development easily accessible by different modes of transport, especially walking, cycling and public transport. An important policy tool to achieve this is the modal hierarchy. All major development should follow the modal hierarchy by providing access for all of the following (most preferable first, least preferable last):

a. walking and providing access for all, including people with mobility impairment;
b. cycling;
c. public transport;
d. powered two wheelers;
e. commercial vehicles and taxis;
f. car sharing;
g. electric and low emission vehicles;
h. private cars.

5.113 Streets account for a major part of public spaces; high quality streets are therefore fundamental to the character and efficient functioning of a place and play a fundamental role in moving people around safely, improving public realm and providing spaces for people to come together. New major development should create permeable, accessible, inclusive and multifunctional streets that promotes active lifestyle and integrates different modes of transport in line with Policy HP13 Creating Successful Places. Barriers to walking should be addressed in development proposals, to ensure that walking is promoted and that street conditions, especially safety/security and accessibility for disabled people, are enhanced. Walking networks and facilities in and around all new developments should be direct, safe, attractive, accessible and enjoyable.

5.114 Cycling is a space efficient mode compared to cars so making streets attractive for cycling can bring benefits to all road users while also improving the experience of living, working and getting around. Although further consultation will be required, once finalised the Brentwood Cycling Action Plan (2018) can:

a. identify how cycling levels can be increased in the borough;
b. enable any funding for new cycling schemes in Brentwood to be prioritised;
c. create a usable, high-quality cycle network that connects residential areas with key employment locations, rail stations and town centres; and
d. create opportunities to increase recreational cycling in Brentwood.

5.115 Cycling will should be promoted through the provision of improved cycle parking and other facilities and new cycle routes as part of highway infrastructure improvements/traffic management measures and, where appropriate, in association with planning permission for new development. Development should facilitate and encourage cycling to reduce car dependency and the health problems it creates. When providing for cycle parking, cycle parking areas should be secure and covered, and allow easy access for occupiers and their visitors, and provide facilities for all, including disabled cyclists. This could include identifying and reserving specific spaces which provide step-free cycle parking and opportunities for people using adapted cycles, as well as providing facilities for other non-standard cycles such as tricycles, cargo bicycles and bicycles with trailers. Space for folding bicycles should be provided as well as space for conventional bikes to cater for rail commuters. However, space for folding bicycles is not an acceptable alternative to conventional cycle parking as these are less popular in some areas, tend to be less affordable and present difficulties for some users. Surface level parking is preferable to stacked parking which may be difficult for some people to use. Visitor parking should be quickly and easily accessible to front entrances of buildings and not require cyclists to visit parts of a site restricted to occupiers only. Developers should refer to the vehicle parking standards set out in the Essex Parking Standards (2009) or as amended, in line with Policy BE17 Parking Standards.

Amend paragraph 5.118 to read:

The design of streets, parking areas, and other transport elements should reflect current national guidance, including the National Design Guide and the National Model Design Code. The Essex County Council's Transportation Development Management Policies provide further detail on requirements relating to accessibility and access, including Transport Assessment and Statement thresholds for each land use category.


To make the policy consistent with national policy and effective




Page Number 103 , Policy BE14, Paragraph 5.119


Amend Policy to read:


A.The Council will facilitate and support sustainable passenger transport services operating in Brentwood to help deliver the vision of the Local Plan.B. Development proposalsshouldprotect and enhance existing passenger transportand their capacity. C. Proposed new community facilities, schools, and specialist older persons housing, where reasonable and proportionate, should are required to provide pick-up and drop-off facilities (with appropriate kerbs) for passenger transport close to the principal entrance suitable for minibuses, school buses, taxis, and/or ambulances.

Insert an additional paragraph after paragraph 5.119 to read:

Consideration should be given to sustainable passenger transport provision as set out within Essex County Council Development Management Policies.


To make the policy effective




Page Number 104 , Policy BE15


Amend Policy to read:


A. The Council will seek appropriate infrastructure forAll development proposals should wherever possible maximise the opportunity of occupiers and visitors to use electric and low emission vehiclesat new developments B. This could include, but is not limited to, and maximise the provision of electric vehicle charging / plug-in points and/or the space and infrastructure required toprovidethis them in the future.


To make the policy effective




Page Number 107 , Policy BE16, Paragraph 5.128 - 5.132


Amend Policy to read:


A. Developments must should seek to ensure that they will not have an unacceptable transport impact and/or any significant impact from the development on the transport network (in terms of highway safety, capacity and congestion) and on highway safety can be effectively mitigated to an acceptable degree. 

B. New development proposals will be required to be supported by:

a. Submit Travel Plans, Transport Assessments and/or Statements in accordance with the thresholds and detailed requirements for each land use category as set out in the Essex County Council's Development Management Policies or its successors; and engage in an appropriate and proportionate assessment process with National Highways where development has a likelihood to have a material impact on the Strategic Road Network which is not otherwise catered for by programmed works or improvements;

b. where necessary, provide reasonable and proportionate financial contributions and/or take reasonable measures mitigation measures necessary to:

i.  mitigate the cumulative transport impact of the development to an acceptable degree, including relevant highways measures identified in the IDP Part B; and

ii.  accommodate the use of sustainable modes of transport. This could includeing borough-wide sustainable transport measures identified in the IDP Part B, investment in infrastructure, services, Low Emission Zone, or measures to promote behavioural change measures (including enforcement) to encourage the use of sustainable modes of transport. Such measures should be provided to meet the first or early occupation of a site in order to influence travel behaviour from the outset.

Move paragraph 5.129 to precede 5.127, and amend to read:

5.129 Development resulting in an unacceptable impact on highway safety, or significant and harmful residual cumulative impacts on the road network will be prevented or refused on highways grounds, unless any impact will be effectively mitigated to an acceptable degree, in line with the NPPF (2018).

Amend paragraph 5.128 to read:

5.128 Joint working is being has been undertaken with National Highways, Essex County Council (highways authority), developers and all relevant partners to identify necessary mitigations at key junctions, to consider address the cumulative impact of growth within the borough over the Plan period, and to consider the wider planned growth on the local and strategic route network. In addition to strategic transport infrastructure, a number of highways junction improvements will need to be made to facilitate new growth, these are assigned a priority category 2 in the Infrastructure Delivery Plan.

Delete paragraph 5.130

Amend paragraph 5.131 to read

5.131 As noted earlier in this chapter, providing physical improvements to the highway will only have a short-term impact; therefore it is important to invest in long term alternatives. The Council will work with developers, highways authority and service providers to consider potential sustainable transport measures that could assist in reducing the impact of developments on the overall road network. The Transport Assessment (PBA, 2018The Transport Assessment (Stantec, 2021) identifies a number of non-highway mitigation measures sustainable transport measures package that could be implemented in Brentwood Borough; feasibility analysis for some of these measures are being considered in the in the Brentwood IDP as part of a long-term assessment. These include: are listed in the IDP with priority category 3 which may be revised from time to time.

i. School Clear Zone;

ii. Park and Ride/ Cycle/ Stride;

iii. 'Quietway' cycle routes;

iv. Low Emission Zone;

v. Banning all large freight vehicle from stopping deliveries within the Central Brentwood zone and A128 corridor during AM/PM peaks;

vi. Car-limited development at appropriate locations;

vii. Pedestrian wayfinding system;

viii. Multiple service app making access to smart car hire/ community buses/ booking bikes/ bike hire schemes etc. easier;

ix. Encourage clean vehicles and introduce electrical parking points to encourage use of such vehicles and plan and deliver other IT infrastructure required to allow future implementation of emerging SMART systems;

x. Multi-modal integration at rail stations.

Delete paragraph 5.132.

Insert an additional paragraph after 5.132 to read:

Applicants are expected to consult with the Highways Authority on transport matters and adhere to Essex County Council's development management policy requirements (or equivalent) in respect of Travel Plans, Residential Travel information Packs and other highways considerations. Please refer to the Essex County Council Highways Authority Development Management Policies.


To make the policy effective and justified

To ensure that non-strategic mitigation measures identified in the IDP (not covered by Policy BE11) would also be considered

To removes confusion because some of the identified borough-wide sustainable transport measures, as opposed to on-site sustainable transport measures, do not need to be provided to meet the first or early occupation of a site.

To provide clarity by reference to relevant items in the Infrastructure Delivery Plan

To refer applicants to the relevant document, as Travel Information Packs are not a policy requirement of the Local Plan, but rather a requirement of the Highways Authority, set out in the Essex County Council Development Management Policies




Page Number 107 , Policy BE17, Paragraph 5.136


Amend policy to read:


A. The Council will refer developers to the Development proposals should comply with must take account of the Essex Parking Standards – Design and Good Practice (2009), or as subsequently amended set out in the most up-to-date Essex Parking Standards. Schemes should comply with design standards and provision levels for uses and transport modes specified. The decision-maker will have regard to these standards when determining planning applications.

B. In the following circumstances,the parking standards may beflexibleto minimise pressure on land and encourage alternative modes of transport:

a. office developments in urban areas that are well-connected by public transport and have good accessibility through walking and cycling; 
b. retail and mixed-use development in the Town Centre, District Shopping Centres and Local Centres that has access to shared car parks with different facilities/users at different times; and 
c. commuter parking provision at train stations. 

Proposals which do not conform to make provision below these standards should be supported by evidence detailing the local circumstances that justify deviation from the standard. should be supported by evidence detailing the local circumstances that justify deviation from the standard.

Amend paragraph 5.136 to read and update NPPF reference from July 2018 to 2021: 

Brentwood Borough Council adopted the Essex Parking Standards - Design and Good Practice (2009) as a Supplementary Planning Document (SPD) in 2011 and will expect these standards to apply until such time as they are revoked or superseded by other standards.


To make the policy effective and provide clear reference to the latest adopted Parking Standards, which, although do not form part of the development plan, are a material consideration as a SPD.

As the Parking Standards - Design and Good Practice (2009) has flexibility for such circumstances

To provide clarity




Page Number 111 , Policy BE18, Paragraph 5.142, Paragraph 5.144, Paragraph 5.145, Figure 5.3, Paragraph 5.146, Paragraph 5.157


Move Policy BE18 and its supporting text in chapter 8.


Delete the existing wording and replace with the following new wording to read:

A. Brentwood’s network of green and blue infrastructure (GBI) will be protected, enhanced and managed to provide a multi-functional, high quality open space resource, capable of delivering opportunities for recreation, health and wellbeing, ecological connectivity, biodiversity net-gain as well as wider ecosystem services for climate change adaptation.

B. New development is expected, where possible and appropriate, to maximise opportunities to enhance or restore existing GBI provision and/or create new provision on site that connects to the wider GBI network. Its design and management should also respect and enhance the character and distinctiveness of the local area.

C. Developments on sites containing or are adjacent to a water course or water body (Blue Infrastructure) are required to ensure there is no adverse impact on the functioning or water quality of the Blue Infrastructure. Proposals that maximise opportunities to enhance or restore Blue Infrastructure and incorporate these features into the public realm of the development will be supported. An adequate undeveloped buffer zone should be applied as necessary to mitigate flood risk, in line with Policy NE09 and/or support sustainable drainage, in line with Policy BE05.

D. Proposals should provide appropriate specification and maintenance plans for the proposed green and blue infrastructure throughout the life of the development.

Amend paragraphs 5.142 to read:

Green and Blue Infrastructure

5.142 There are a number of definitions of g Green and blue infrastructure (GBI) is a network of multi-functional share the same notion in which GBI can be understood as natural or semi-natural networks of green (soil covered or vegetated) and blue (water covered) spaces and corridors, in either an urban or rural setting, that connects, maintains and enhances ecosystem services. GBI should thread through and surround the built environment and connect the urban area to its wider rural hinterland. iIt is capable of delivering a wide range of environmental and quality of life benefits for local communities by providing recreational or cultural experiences. It can also help support a number of strategic objectives across policy areas, such as promoting public health and wellbeing, mitigating and adapting to climate change (heat risk, flood risk, sustainable drainage), improving water and air quality, as well as conserving habitats and contributing to biodiversity net-gain. supporting and enhancing biodiversity and geodiversity, improving air and/or water quality, enhancing and conserving the historic environment, as well as enriching the quality of life of local communities. Figure 5.3 defines the different types of GBI. They include those found in Brentwood, but also additional types that could be delivered as part of new development.

Delete paragraph 5.144

Amend paragraph 5.145 to read:

5.145 A well connected GBI network will play a crucial role in maintaining the Borough's distinctive 'Borough of Villages' character. The Council will take a strategic approach to maintaining and enhancing networks of GBI, ensuring a variety of managed, multi-functional open spaces, coherent ecological green corridors, water courses and water bodies to promote a resilient and sustainable built environment, The Council will protect and enhance local distinctiveness and plan positively for the creation, preservation and enhancement of networks of biodiversity and GBI in line with the Council's Green Infrastructure Strategy (2015). As part of planning for infrastructure provision, t The Council will work with statutory bodiesand wider stakeholders, including developers to conserve, enhance and maintain the natural environment. infrastructure providers, including Essex County Council and utilities companies and consider the roles of developers in providing and maintaining the GBI that is required as a result of new growth.

Insert a new paragraph after paragraph 5.145 to read:

Open Spaces

Open spaces take many forms and all are an integral component of the GBI network, forming key destinations. The designated Urban Open Spaces, as depicted on the Policies Map, represent green spaces in urban settlements that provide an important multi-functional local resource to residents and therefore, are to be protected. They are made up of different types of open spaces, including parks, sports grounds and playing fields (including playing fields forming part of an education establishment), woodlands, and amenity green space. However, Brentwood has direct access, via the Public Rights of Way network, to extensive publicly accessible parks, including Country Parks such as Hutton, South Weald and Thorndon within the surrounding countryside also identified on the Policies Map. There will be a presumption against the development of open spaces which provide a significant amenity resource.

Amend figure 5.3 to read:

Type of GI

GBI Typologies

Key Policy Elements

GBI sub-types

Urban Open Spaces

Designated green spaces in existing settlement (urban) areas, of various typologies that are to be protected.

NB. These were previously partly identified by the 'Protected Open Space' designation is the replacement Local Plan 2005.

Parks and Gardens

Country Parks, Borough Pparks and Recreation Grounds, Historic Registered Parks and Gardens.

Ecological assets and natural and semi-natural greenspaces (urban / rural)

Special Sites of Scientific Interest (SSSI), Local Nature Reserves (LNR), Local Wildlife Sites (LoWS), Woodlands, Geological Assets, Grasslands, Thames Chase Forest., other assets.

Green Corridors

Hedgerows, amenity grasslands/greenspace or green verges along major road corridors and major rail corridors, cycling routes/ network, pedestrian paths and rights of way, and Protected Lanes.

Green and b Blue cCorridors

Main rivers (e.g. Rivers Roding, Ingrebourne, Wid and Mardyke), large ordinary/non-main river watercourses, major tributaries, wetland. hedgerows, major road corridors, major rail corridors, cycling routes/ network, pedestrian paths and rights of way, Protected Lanes.

Sports and Recreation Grounds Outdoor sports facilities and provision for children and teenagers

Natural green surfaces: Play pitches that are green/permeable in nature such as: tennis courts, bowling greens, sports pitches/fields, golf courses, school and other institutional playing fields, and other outdoor sports areas. Green formal/informal recreation areas for children/ teenagers.

Amenity greenspace

Amenity greenspace, village greens, commons, other informal greenspace, Protected Urban Open Space, Local Green Space.


Typically Parish and Council owned/ managed.

Statutory and Non-statutory allotments; community gardens

Cemeteries and churchyards

Public and privately-owned facilities.

Classified lLandscapes and accessible urban fringe countryside

Ancient Landscapes, fringe countryside

Garden Land

Private back gardens, private amenity green space on estates or private communal gardens that are entirely to the rear or within the curtilage of a dwelling or dwellings, as originally designed

Other GI

Private gardens, green walls, green roofs, estate greenspace, etc

The supporting text following Policy BE18 is proposed to be amended as follows:

Amend paragraph 5.146 to read:

5.146 This policy is in line with the NPPF, as well as the government's latest environment plan: A Green Future: Our 25 Year Plan to Improve the Environment which sets out a long-term vision for England's environment post-Brexit., along with some medium-term aspirations for progress, and some shorter-term actions. The 25 Year Environment plan stresses the importance of good-quality green and blue infrastructure (GBI) and commits to creating a 'national framework of green infrastructure standards, ensuring that new developments include accessible green spaces and that any area with little or no green space can be improved for the benefit of the community'. The Local Plan policies This policy will seeks to achieve well managed, high quality multi-functional Green and Blue Infrastructure to ensure opportunities are maximised for recreation, health and wellbeing, a net gain for biodiversity, as well as help achieve additional benefits for air quality and climate adaptation. by providing new green spaces including hHigh quality green and blue infrastructure should be built into the designs proposals and/or masterplans of new development, wherever possible.

Retain paragraphs 5.147 to 5.156

Amend paragraph 5.157 to read:

5.157 This policy should be read in conjunction with Policy BE08 BE05 Sustainable Drainage, Policy HP18 Designing Landscape and the Public Realm, Policy BE19 Access to Nature, Policy NE01 Protecting and Enhancing the Natural Environment, Policy NE03 Trees, Woodlands and Hedgerows and Policy NE06 NE09Flood Risk.


To make the policy effective and consistent with national policy

Clause A, B and C ensures a strategic approach to GBI maintenance and enhancements of GBI networks in line with para 174 of the NPPF, while also being mindful of the additional strategic benefits it can achieve for climate adaptation.

Clause C specifically talks about blue infrastructure to align with paragraph 174 (e) of the NPPF, ensuring that development does not contribute to unacceptable water pollution and wherever possible, helps improve water quality.

Clause D ensures there is adequate provisions in place to enable its effective management into the future

The open spaces set out on the policies map capture all known public open spaces of significant amenity value within settlement boundaries. To help clarify the differences between these open spaces within settlement boundaries and other open spaces, for example the Country Parks within the Green Belt, it will refer to these as ‘urban open spaces’. Policy BE22 has been amended to ensure all open spaces are protected. Figure 5.3 defines the different open space typologies.




Page Number 115-116 , Policy BE19, Paragraph 5.158, Paragraph 5.159, Paragraph 5.160, Paragraph 5.161


Delete Policy BE19 and supporting text paragraphs 5.158 to 5.161 as repeats provision in other policies, including Policy BE18 (now Strategic Policy NE02) Green and Blue Infrastructure and Policy NE03 Trees, Woodlands, Hedgerows.


To make the plan effective. Policy BE19 is covered by other policies in the plan




Page Number 116 , Policy BE20, Paragraph 5.162 - Paragraph 5.173


Move Policy BE20 to Chapter 8 after the new Policy NE05 (originally Policy BE22) Open Space and Recreation Provision.

Amend Policy BE20 to read:


A. Planning for The provision of allotment space should, where possible and appropriate, be an integral part of the green and blue infrastructure provision in residential development.

B. Provision of space areas for personal and community gardening and food growing will be favourably considered.

C. The change of use or development of designated allotment sites will not be permitted unless it can be demonstrated that provision is no longer required or that an alternative provision can be provided.

Amend paragraphs 5.162 to 5.164 to read:

5.162 Local cCommunity food growing space not only helps to improve social integration and community cohesion but can also contribute to improved mental and physical health and well-being. It supports healthy living by enabling residents make more sustainable food choices, protects local ecosystems and fosters community spirit and enterprise. It also helps reduce the carbon footprint of food production by minimising CO2 emissions from transporting food and is beneficial for air quality by helping to reduce pollution.

5.163 The wider benefits of growing produce are identified in the Brentwood Open Space, Sport and Leisure Assessment (2016) which highlights that providing opportunities for people to grow their own food contributes to sustainability, health and social inclusion.

5.164 The Council therefore aims to safeguard land for garden and its existing allotments, promotes local food growing by and encourage ing development proposals to include spaces for residents and communities to grow their own food. This would enable and support healthy lifestyles, in line with the NPPF (2018, paragraph 91).

Delete paragraphs 5.165 to 5.167 and 5.169 and 5.172.

Amend paragraphs 5.168, 5.170, 5.171, 5.173 to read:

5.168 There are currently 16 known allotment sites in Brentwood, as illustrated on the Policies map. Ten of these sites have The Council are proposing to declare all existing Council owned allotment sites in the borough as having statutory status so they enjoy the and are therefore, afforded additional legal protection provided by the Allotments Act 1925. Policy NE06 applies to all statutory and non-statutory allotments equally. Further engagement work is also required to understand whether the current allotment infrastructure have opportunities to accommodate additional growth or additional provision will be needed.

5.170 When allotments or community gardens are provided on site as part of a development, developers should also provide sufficient information to address the long-term maintenance, in line with the requirements of STRATEGIC Policy NE02: Green and Blue Infrastructure. should pay for the future maintenance and management of the allotments and arrange for a management body to undertake that responsibility for the life of the development. Where, land is transferred to the Borough or Parish Councils, an agreed maintenance contribution should be made. It is expected that the developer will maintain the allotment for twelve months before it transfers it to the borough or relevant parish council with the payment of a commuted sum to cover 20 years maintenance. Developer contributions for off-site provision could include the enhancement of nearby allotment facilities.

5.171 Innovative solutions to small scale food growing space will be are encouraged, such as green roofs/walls, re-utilising existing under-used spaces and incorporating spaces for food growing in new schools.

5.173 This policy should be read in conjunction with STRATEGIC Policy BE18 NE02: Green and Blue Infrastructure. , Policy BE23 Open Space, Sport and Recreational Facilities.


To make the policy effective

To clarify that the policy applies to both statutory and non-statutory sites, and highlights how many of the allotments are public allotments




Page Number 117 , Policy BE21, Paragraph 5.174 - 5.177


Move Policy BE21 to Chapter 8. Amend Policy to read:


Proposals for development on sites that form part of an existing allotment, garden, or group of gardens will only be permitted where:


a.  sufficient garden space and space around existing dwellings is retained, especially where these spaces and any trees are worthy of retention due to their contribution to the character of the area and their importance for biodiversity;

b.  the form, height and layout of the proposed development is appropriate to the surrounding pattern of development and the character of the area in line with Policy HP14 Responding to Context;

c.  the amenity and privacy of neighbouring, existing and new residents properties is are protected; and

d.  provision is made for adequate amenity space, vehicular access arrangements and parking spaces for the proposed and existing properties. ; and

e.  there is no detrimental effect on the potential comprehensive development of the wider area.

Amend paragraphs 5.174 to 5.177 to read:

5.174 As the The definition of Previously Developed Land within the NPPF excludes private residential gardens. and allotment, inappropriate The development of garden land and allotment sites will be resisted, . P unless proposals that are considered to be appropriate on garden or allotment sites in fulfil the requirements of accordance with the criteria set out in this policy and will still be assessed against other relevant policies within this Plan.

5.175 Allotments and gardens Garden Land (includes private back gardens and private amenity areas or private communal gardens) forms an important part of the network of Green Infrastructure and an integral part of the urban layout and assist in defining the character of the residential area. Garden Land provides a semi-natural habitat for local wildlife and corridors for the movement of wildlife in the urban area. Collectively, they help to mitigate fluvial and surface water flooding in the built-up parts of Brentwood. Private gardens also form an important amenity resource for private dwellings as well as They form part of an area's development pattern, providing a setting for buildings. They are an important environmental resource and are a vital component of Brentwood's character.

5.176 However, it should also be noted that, If designed appropriately, some forms of redevelopment and infill development, which are well designed and which makes efficient use of land, will continue to be a valuable additional source of housing supply. and need not be inappropriate. Proposals will be considered on a case-by-case basis, taking into account the nature and scale of the proposed use, its context and the quality of the design and whether the remaining area of garden is sufficient to meet occupier needs. This will depend upon the size of the dwelling and the Council will take into account the relevant guidance in the Essex Design Guide in making its assessment as well as other relevant policies in this plan.

5.177 For policies and guidance relating to garden and open space, In this regard, applicants should also refer to Policy HP06 Standards for New Housing, and Policy BE23 NE05 Open Space, Sport and Recreational Facilities, and Recreation Provision, as well as the Brentwood Town Centre Design Guide. and Essex Design Guide.


To ensure the policy is effective and justified




Page Number 119 , Policy BE22, Paragraph 5.178 - 5.183


Merge Policy BE22 and BE23, and move the policy to Chapter 8.

Amend policy to read:



A.  All open spaces, including the designated Urban Open Spaces, as identified will be protected and where necessary enhanced to ensure access to a network of high quality provision and opportunities for sport, play and recreation within the borough. The loss of Open Spaces and any ancillary facilities, such as sports, play and recreation provision, will not be permitted unless it can be demonstrated that:

a.  an assessment has been undertaken which clearly shows the provision and the function it performs is surplus to requirements; or

b.  the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable, accessible location within the local catchment area; or

c.  the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss.

A. B.  New development proposals are expected to provide functional on-site open space and/or recreational amenities and may, where appropriate, be required to also provide a financial contribution towards new or improved facilities within the borough is required to maximise opportunities to incorporate new publicly accessible, high quality and multi-functional open space and/or, where appropriate, enhance existing provision that will serve the new and existing community, through improved connections, biodiversity net-gain and high quality sport, play and recreational amenities.


B. C.  The amount and type of provision required will be determined according tothe size, nature and location of the proposal, quantity and type of open space needed, and existing provision accessible to the proposal. All payments will be in line with the Policy BE23 Open Space, Sport and Recreational Facilities. the Council's identified needs, as set out it its Open Space and Play Pitch Strategy and adopted open space standards; with regard to children's play space, the Council will seek proposals which meet the Fields in Trust minimum standards (see Figure 5.5).

C. D.  Where it can be clearly demonstrated that proposals are not able to incorporate new provision or enhance existing provision to serve the new community, then a A commuted sum may be requested for in line with Policy MG05 Developer Contributions where such contributions will provide alternative or enhanced and conveniently accessible off-site open space provision.

a.  proposals where strategic open space requirements cannot be met within the site;

b.  local and strategic open space in developments of single person households or of dwellings for the elderly (where however some compensating increase in private amenity space may be required); or

c.  a Town Centre, District Shopping Centre or Local Centre location within Brentwood or where

D. E.  it is justified by an outstanding urban design approach based on site constraints and opportunities.

All open space provision should be fully equipped to meet the needs of users as agreed by the Council, reflecting acceptable distance and minimum size criteria for different types of open space as set out in the Council's Open Space Standards (refer to Figure 5.4). Proposals for the inclusion or enhancement of supporting and ancillary uses and facilities on open space, such as sport, play and other supporting recreational provision, should meet the following criteria:

a.  the proposed facilities help improve the quality of the open space and promote inclusive access to a wide range of users and recreational interests;

b.  are demonstrably ancillary to the use of open space and its primary function, e.g. play/sports fields;

c.  help to contribute to both the character and amenity of the area and are appropriate and proportionate to the function and nature of the open space;

d.  do not have a detrimental impact on the environmental function of the open space.

F.  Maintenance Plans should be submitted at planning application stage for all new facilities provided for exercise or recreation purposes. This is to secure quality over the long term and clarify responsibilities from the outset. to ensure their long-term quality and management.

Delete clause E

Move paragraph 5.178 to 5.179 to after Policy BE22 (now Policy NE05), to precede paragraph 5.180.

Delete paragraph 5.180-5.183


To make the policy consistent with national policy, effective and justified

Policy BE22 and BE23 to be merged as they contain overlapped or duplicated requirements

This is originally set out in clause A of BE23. Amended to protect existing open space and ancillary facilities.

To address the need for new provision.

To address how new provision will be determined.

To provide clarity on what is meant by 'fully equipped'

The sub clauses guide applicant to ensure the emphasis should be on ensuring inclusive, accessible provision that does not impact the function of the open space.

Clauses D and C from BE22 and BE23 respectively are combined here, to set out the requirement for management plans

No longer relevant to the policy or is covered in the introductory text of green infrastructure.




Page Number 120 , Policy BE23, Paragraph 5.184 - 5.185


Delete Policy BE23, merge key requirements and relevant supporting text with Policy BE22.

Amend the below supporting text and move all to Policy BE22 after 5.183 to form the new Policy NE05.

Delete paragraph 5.184

Insert new paragraph to precede paragraph 5.185 to read:

Open Space Needs and Adopted Standards

The Council's Open Space, Play Pitch and Leisure Assessments provide an overview of the existing provision across the borough, as well as known deficiencies. All major development proposals should investigate and maximise opportunities to enhance open space and play, sport and recreation facilities where possible and appropriate, particularly in areas of deficiency in quantity and quality. New development can help to enhance provision even where it is not feasible to deliver new public open space on site. This could include improving access, through public realm enhancements, to existing nearby facilities or alternatively, contributions will be sought where appropriate.


Amend paragraph 5.185 to read:

5.185 All proposals, where appropriate, will be required to comply with the Council's identified needs and open space standards as set out in Figure 5.4 or any subsequent update, to inform the design of the proposals and planning application process. These take account of recommendations in Oopen Sspace and Ssports facilities evidence, i.e. Brentwood Play Pitch Strategy (2018), Brentwood Open Space Strategy (2008-2018), the Leisure Strategy and Play Strategy (2018). With regard to children's play space, the Council will seek proposals which meet the Fields in Trust minimum standards as set out in Figure 5.5.


To ensure the plan is effective

To ensure the amended policy is justified.



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