Schedule of Potential Main Modifications

Ended on the 11 November 2021

Chapter 6



Page Number 124 126 , Policy HP01, Paragraph 6.13


Amend Policy to read:


A.  All new residential development should deliver an inclusive, accessible environment throughout.

a.  A.  On residential development proposals of 10 or more (net) additional dwellings the Council will require:

i.  a.  an appropriate mix of dwelling types, sizes and tenures to meet the identified housing needs in the borough as set out in the Council's most up to date housing need evidence Strategic Housing Market Assessment or any similar evidence for market and affordable units (such as the Council's Housing Strategy), to provide choice, and contribute towards the creation of sustainable, balanced and inclusive communities; and


ii.  b.  each dwelling to be constructed to meet requirement M4(2) accessible and adaptable dwellings, unless it is built in line with M4(3) wheelchair adaptable dwellings, of the Building Regulations 2015, or subsequent government standard.

b.  B.  On developments of 60 or more (net) dwellings the Council will require all of the above, and:

i.  a minimum of 5% of new affordable dwellings should be built to meet requirement M4(3) wheelchair accessible dwellings of the Building Regulations 2015, or subsequent government standard.

c. C.  On development sites of 500 100 or more dwellings the Council will require all of the above, and:

i.  a.  a minimum of 5% self-build homes which can include custom housebuilding provided there is a need as justified within the Council's most up to date evidence; and

ii.  b.  provision for other forms of Specialist Accommodation taking account of local housing need in accordance with the criteria set out in Policy HP04 Specialist Accommodation.

B.  D.  Where a development site has been divided into parts, or is being delivered in phases, the area to be used for determining whether this policy applies will be the whole original site. 

C.  E.  The inclusion of self-build and custom build homes and Specialist Residential Accommodation on smaller sites will also be encouraged.

Amend paragraph 6.13 to read:

The Council will also seek the provision of Specialist Accommodation on strategic residential schemes of 500100 dwellings or more, to ensure there will be sufficient housing to accommodate identified local need.


To make the policy effective and ensure that decisions are based on the most up to date housing need evidence.

To ensure needs are met based on current data available through the Self Build Register.




Page Number 127 , Policy HP02


Amend part B to read:

In justifying any change of use between residential use classes, proposals must demonstrate how they are responding to established housing need as demonstrated in the Council's most up to date housing need evidence Strategic Housing Market Assessment.


To make the policy effective by ensuring that decisions are based on the most up to date housing need evidence




Page Number 128 , Policy HP03


Amend Policy to read:

Proposals for new residential developments not allocated in the Plan:

A. a.  Proposals for new residential developmentshould take a design led approach to density which ensures schemes are sympathetic to local character and make efficient use of land

B. b.  Residential development proposals will generally be expected to achieve a net density of at least 35 dwellings per hectare net or higher, unless the special character of the surrounding area suggests that such densities would be inappropriate, or where other site constraints make such densities unachievable.

C. c.  Development proposals will be expected to achieve a higher density, generally above 65 dwellings per hectare net in the Town Centre, District Shopping Centres, and Local Centres listed below Strategic Policy PC08 4 Retail Hierarchy of Designated Centres, or other locations with public transport accessibility, subject to Policy HP14 Responding to Context and Policy HP16Building Design Strategic Policy BE14 Creating Successful Places.


To make the policy effective by ensuring appropriate densities are achieved throughout the borough




Page Number 129 , Policy HP04, Paragraph 6.25


Amend Policy to read:

A.  The Council will grant permission for  encourage and support proposals which contribute to the delivery of Specialist Accommodation, provided that the development: 

a.  meets demonstratable established local community need;

b.  is readily accessible to public transport, shops, local services, community facilities and social networks and, where appropriate, employment and day centres;

c.  would not result in the over concentration of any one type of accommodation;

d.  where appropriate, provides suitable landscaping and amenity space; and

e.  where appropriate, is in accordance with Policy NE10 New Development, Extension and Replacement of Buildings in the Green Belt.

B.  Subject to viability, where accommodation falls within use class C3 an appropriate proportion of affordable housing in accordance with Policy HP05 Affordable Housing will be required with the mix of tenures to meet identified needs negotiated by the Council.

C.  A condition may be imposed restricting occupation to persons requiring specialist accommodation where deemed necessary.

D.  Where a need for Gypsy and Traveller pitches are identified by the Council, Policy HP10: Proposals for Gypsies, Travellers and Travelling Showpeople Windfall Sites would apply.

Insert new paragraph after paragraph 6.25 to read:

In terms of housing, new potential builds for Supported Living could be beneficial to supply demand for this type of accommodation, and any specialist accommodation provision for people with disabilities could meet the need of the local population or individuals who would move to this area. The demand for adults with disabilities is considered under the Independent Living programme.


To make the policy effective and justified

To ensure the boroughs gypsy and traveller needs are met in full and allows for flexibility for additional pitches if needed.

As agreed with Essex County Council




Page Number 131-132 , Policy HP05, Paragraph 6.34


Amend policy to read:


A. The Council will require the provision of 35% of the total number of residential units to be provided and maintained as affordable housing within all new residential development sites on proposals of 10 11 or more (net) units or sites of 10 or less units which have a combined gross internal floorspace in excess of 1,000 square meters.

B.  In considering the suitability of affordable housing, the Council will require that:

a.  the tenure split be made up of 86% Affordable/Social Rent and 14% as other forms of affordable housing (this includes starter homes, intermediate homes and shared ownership and all other forms of affordable housing as described by national guidance or legislation) or regard to the most up to date housing evidence SHMA;

b.  the affordable housing be designed in such a way as to be seamlessly integrated to that of market housing elements of a scheme (in terms of appearance, build quality and materials) and distributed throughout the development so as to avoid the over concentration in one area; and

c.  the type, mix, size and cost of affordable homes will meet the identified housing need as reported by the Council's most up-to-date housing evidence Strategic Housing Market Assessment and Housing Strategy.

C.  In seeking affordable housing provision, the Council will have regard to scheme viability; only where robust viability evidence demonstrates that the full amount of affordable housing cannot be delivered, the Council will negotiate a level of on-site affordable housing that can be delivered taking into account the mix of unit size, type and tenure and any grant subsidy received.

D.  The Council will only accept off-site provision, or an appropriate financial contribution in lieu of on-site provision where it can be robustly satisfactorily demonstrated that on-site provision is not possible and that, in the individual case and to the satisfaction of the Council, the objective of creating mixed and balanced communities can be effectively and equally met through either off-site provision or an appropriate financial contribution in lieu or a combination of the two neither feasible nor viable.

E.  Where a site has been sub-divided or is not being developed to its full potential so as to fall under the affordable housing threshold, the Council will seek a level of affordable housing to reflect the provision that would have been achieved on the site as a whole had it come forward as a single scheme for the allocated or identified site.

Amend paragraph 6.34 to read:

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. The use of further viability assessments at the decision-making stage should not be necessary. It is up to the applicant to demonstrate whether particular circumstances relevant to the characteristics of the site and the proposed development justify the need for a viability assessment at the application stage.

Add new paragraph after 6.34 to read:

Where an applicant formally requests the Council to consider a reduced level of affordable housing, it will need to demonstrate that it is not possible to meet the full quota of affordable housing without prejudicing the delivery of housing on the site. It will also need to demonstrate to the satisfaction of the Council that, in the individual case, the objective of creating mixed and balanced communities can be effectively and equally met through either off-site provision or an appropriate financial contribution in lieu or a combination of the two. To this end, and in demonstrating the above, a full viability assessment would need to be submitted with a planning application which is based upon, and refers to, the Brentwood Local Plan Viability Assessment. Such an assessment should include evidence of what has changed since the adoption of the Plan which has impacted on viability and should reflect the government's recommended approach to defining key inputs as set out in National Planning Guidance.


To make the policy consistent with national policy and effective. To ensure that decisions are based on the most up to date housing need evidence.




Page Number 134-138, Policy HP06, Paragraph 6.50, Paragraph 6.51


Amend Policy to read:

All residential development shall comply with the following:

Internal Residential Space

A.  All new build housing will achieve appropriate internal space through compliance with the nationally-described space standard as summarised in Figure 6.3 or as may be superseded.

External Residential Space

B.  New residential units will be expected to have direct access to an area of private and/or communal amenity space. The form of amenity space will be dependent on the form of housing and could be provided in a variety of ways, such as a private garden, roof garden, communal garden, courtyard balcony, or ground-level patio with defensible space from public access. In providing appropriate amenity space, development proposals should:

a.  consider the location and context of the development, including the character of the surrounding area;

b.  take into account the orientation of the amenity space in relation to the sun at different times of year;

c.  address issues of overlooking and enclosure, which may otherwise impact detrimentally on the proposed dwelling and any neighbouring dwellings; and

d.  be designed to provide the amenity space to be of a shape, size and location to allow effective and practical use of and level access to the space by residents.

Delete part C-F (Housing Quality) of the policy

Amend paragraph 6.50 to read:

Applicants are also encouraged to consider external residential space size specifications as set out by the most up to date Essex Design Guide, prepared by Essex County Council.


To make the policy effective




Page Number 139 - 142, Policy HP07, Policy HP08, Paragraph 6.62, Paragraph 6.65, Paragraph 6.67, Paragraph 6.69, Paragraph 6.71, Paragraph 6.72


Merge Policies HP07 and HP08 into one policy and amend to read as follows:


In order to meet identified need, a total of 13 permanent pitches for Gypsies and Travellers as defined by national planning policy for the period 2016-2033 will be provided.

Delete criteria a and b of Policy HP07.

Delete Policy HP08 title.

The Council will support an application for planning permission on the following sites are removed from the green belt and are allocated for permanent Gypsy and Traveller accommodation, as shown on the Brentwood Policies Map and Appendix 5, and listed below, subject to compliance with identified. Proposals for these sites must comply with the specified requirements:

A.  Site Ref GT16

a.  Site Address: Oaktree Farm (Greenacres), Chelmsford Road

b.  Number of Pitches: 7 Allocated for 7 pitches

c.  Proposals for development at this site should comply with the following site-specific requirements: require

i.  A a landscape framework to be submitted to provide suitable boundary treatment to include a mixture of native trees and shrubs around the site to safeguard the character and appearance of the area.

ii.  Given the location of the site within the Green Belt for expansion will not be allowed.

B. Site Ref GT17

a.  Site Address: Hunters Green, Albyns Lane, Navestock

b.  Number of Pitches: 1 Allocated for 1 pitch

c.  Proposals for development at this site should comply with the following site-specific requirement:

i.  Given the location of the site within the Green Belt any proposals for expansion will not be allowed.

C.  Site Ref R01 (I) Dunton Hills Garden Village Strategic Allocation

Site Address: Dunton Hills Garden Village, West Horndon, Brentwood

Allocated for 5 pitches

Proposals for development at this site should comply with the site-specific requirements set out in policy R01(i).

Delete Appendix 5

Amend paragraph 6.62 to read:

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, taking into account the Essex Planning Officers' Association Protocol for Unmet Gypsy, Traveller and Travelling Showpeople Needs 2018 which has been developed collaboratively across Essex under the Duty to Cooperate.

Include following text as new paragraph after 6.65:

A total of 13 permanent pitches for Gypsies and Travellers as defined by national planning policy for the period 2016-2033 will be provided through the incorporation of a minimum of 5 serviced Gypsy and Traveller pitches as part of the Dunton Hills Garden Village allocation, to be delivered in the first five years of development. A further 8 existing pitches are to be regularised in accordance with Policy HP07.

Amend paragraph 6.67 to read:

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 were in the Green Belt. To be consistent with national planning policy, these sites have been removed from the green belt for the use as gypsy and traveller pitches only.

Amend reference in paragraph 6.69 from Policy HP08 to HP07

Amend paragraph 6.71 to read:

The approach not only secures the planning status of the current occupants, contributing to the specified needs, but also provides certainty in relation to the delivery of sites to meet the needs of the borough (13 pitches as identified in policy HP07) in Policy HP07 Provision for Gypsies and Travellers.

Amend reference in paragraph 6.72 from Policy HP08 to HP07


To make the policy consistent with national policy and effective




Page Number 143 - 144 , Policy HP09


Amend Part A of Policy to read:


The existing Gypsy and Traveller sites listed below, and as shown on the Brentwood Policies Map, are removed from the Green Belt and will be safeguarded from alternative development, unless it can be demonstrated that the site is no longer required to meet any identified Traveller need across the borough, or acceptable replacement accommodation can be provided.


To make the policy consistent with national policy and effective




Page Number 144-145 , Policy HP10, Paragraph 6.75, Paragraph 6.77


Amend Policy to read:


A. The local planning authority will allow consider proposals for the sub-division of allocated or authorised Gypsy, Traveller and Travelling Showpeople sites on a case by case basis, and provided that all the following criteria are met:

a.  the living environment of residents on the proposed site and neighbouring land is protected;

b.  sites are of a suitable size to enable the creation of additional pitches or plots;

c.  the sub-division of Gypsy and Traveller sites do not result in a total of more than 10 pitches on a site;

d.  there is no significant loss of soft and hard landscaping and amenity provision within the existing site, particularly where conditioned by a previous consent;

e.  there is no significant adverse impact on the intrinsic character and beauty of the countryside; and

f.  there is no adverse impact in terms of highways access and vehicle movement.

B.  It will be necessary for the application to demonstrate the need for the additional provision in relation to the requirement of Policy HP07, the lack of alternative provision and specific circumstances of the applicant.

B. The sub-division of plots/pitches on additional sites that might come forward within the green belt will be considered against green belt policy.

Amend paragraph 6.75 to read:

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. This policy applies to existing pitches and plots listed in Policy HP08 as well as those identified for allocation in Policy HP07.

Amend paragraph 6.77 to read:

As All safeguarded sites (with exception to Dunton Hills Garden Village allocation) remain washed over by are being removed from the Green Belt, as required by the National Planning Policy Framework and Planning Practice Guidance for Gypsy and Travellers. 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 the lack of alternative accommodation requires an additional pitch. Only if such need can be demonstrated will the Council look into support such an application in accordance with criteria set out in Policy HP10.


To make the policy effective and consistent with national policy, by allowing for flexibility for additional pitches within the allocated site boundary.




Page Number 146-147 , Policy HP11, Paragraph 6.78, Paragraph 6.79


Amend Policy to read:


A.  Planning permission for Gypsy and Traveller caravan sites and sites for Travelling Showpeople (as defined in the governments Planning Policy for Travellers) on unallocated land outside development frameworks, and outside the Green Belt, will only be granted in accordance with all the following criteria:

a.  the site is well related to existing communities and accessible to local services and facilities, such as shops, primary and secondary schools, healthcare and public transport;

b.  safe and convenient vehicular access to the local highway network can be provided;

c.  essential services (water, electricity and foul drainage) are available on site or can be made available on site;

d.  there is no significant adverse impact on the intrinsic character and beauty of the countryside;

e.  the site would not lead to the loss of, or adverse impact on, important historic and natural environment assets;

f.  there is no significant risk of land contamination or unacceptable risk of flooding;

g.  the site provides a suitable living environment for the proposed residents and there is no significant adverse impact on the amenity of nearby residents;

h.  the site is of sufficient size to accommodate the proposed number of caravans, vehicles and ancillary areas; and

i.  the capacity of the site does not exceed 10 pitches or plots; and

j.  i.  plots for Travelling Showpeople should also be of sufficient size to enable the storage, repair and maintenance of equipment.

B. Sites within the Green Belt will need to demonstrate very special circumstances which clearly outweigh the harm to the Green Belt and any other harm in addition to the criteria A above. Gypsy and Traveller sites are inappropriate development in the Green Belt. Any proposals in the Green Belt would have to demonstrate they comply with National and Local Policy regarding development in the Green Belt. If, through the application of such Policy, provision of a Gypsy and Traveller site in the Green Belt is considered acceptable in principle, the proposed development is required to comply with the criteria set out within this policy.

Amend paragraph 6.78 to read:

It is recognised that during the Plan period, there may be a demonstrable need for additional pitches to those safeguarded or allocated through the Local Plan. This policy applies to non-allocated or safeguarded sites which may come forward during the Plan period in built-up areas and the countryside.

Amend paragraph 6.79 to read:

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.


To make the policy consistent with national policy and effective

Covered by criteria A.h

To provide clarity




Page Number 147-148 , Design and Place-making section, Paragraph 6.81 - 6.118


Move the section on Design and Place-making including all relevant policies and supporting text to sit within 'Chapter 5 - Resilient Built Environment'.

Reorder and amend paragraphs 6.81 through 6.84 to read as follows (Numbering to be determined):

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

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 to 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 the coherent integrationed of new development into the natural, built and historic environment.

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 developments within or in the vicinity of Brentwood Town centre, applicants should also refer to take into account the Brentwood Town Centre Design Plan and Design Guide. 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. 6.118 Proposals should refer to also take into account 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 a Healthy Life and 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.


To make the Plan effective. As this section deals with design aspects of the built environment rather than housing provision

To remove unnecessary references




Page number 148, Policy HP12


Amend the policy to read:


To plan for and build inclusive environment that supports our residents and communities, the Council will require new development proposals work will partners, stakeholders and developers to:

a.  provide access to good quality community spaces, services and amenities and infrastructure that accommodate, encourage and strengthen communities and social interaction for all users;

b.  create places that foster a sense of belonging and social interaction community, where communities individuals and families can develop and thrive;

c.  ensure that streets and public spaces are planned for everyone to move around and spend time in comfort and safety, are convenient and welcoming with no disabling barriers to the disabled or impaired, providing independent access without additional undue effort, separation or special treatment;

d.  ensure buildings and places are designed in a way that everyone regardless of their ability, age, income, ethnicity, gender, faith, sexual orientation can use confidently, independently, with dignity and without engendering a sense of choice and dignity, avoiding separation or segregation; and

e.  ensure that new buildings and spaces are designed to reinforce inclusivity of neighbourhoods and are resilient and adaptable to changing community requirements.

Include paragraphs 6.87 to 6.88 as supporting text after policy HP12 (now the new Policy BE15) and amend as follows:

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. Inclusive and safe design principles should therefore be integral to the design and layout of the scheme, ensuring that people of all ages and abilities are able to benefit from high quality, accessible, safe and secure environments. This can be achieved by good natural surveillance, well-used accessible and legible walkways, appropriate lighting, active frontages and a lack of potential hiding places. Optimising site layout and building design are also effective measures. The Council strongly encourage the use of 'Secured by Design' principles to help reduce crime and improve perceptions of safety.

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.


To make the policy effective




Page Number 149-150 , Policy HP13, Paragraph 6.85 - 6.117


Amend Policy to read:


A.  Proposals that will be required to meet high design standards to and deliver safe, inclusive, attractive and accessible places will be supported. They Proposals should:

a.  provide a comprehensive design approach that delivers a high quality, safe, attractive, inclusive, durable and healthy places in which to live and work in;

b.  make support the efficient use of land and infrastructure, through uses, mix and density/development intensity;

c.  deliver sustainable buildings, places and spaces that can adapt to changing social technological, economic, and environmental and climate conditions;

d.  consider sustainable design and layout at the earliest stage of design, where landscaping, public frontages, building orientation and the impact of microclimate can be considered within the layout to positively enhance the townscape and provide attractive places that improve people's health and sense of vitality;

e. d.  create permeable, accessible and multifunctional streets and places that promotes active lifestyles and integrates different modes of transport, parking and servicing;

e.  respond positively and sympathetically to their context and build upon existing strengths and characteristics, and where appropriate, retain or enhance existing features which make a positive contribution to the character, appearance or significance of the local area (including natural and heritage assets);

f.  integrate and enhance the natural environment by the inclusion of features which will endure for the life of the development, such as planting to enhance biodiversity, the provision of green roofs, green walls and nature based sustainable drainage;

g.  where applicable, ensure that new streets are tree-lined and opportunities are taken to incorporate trees elsewhere in developments;

h.  employ the use of high quality street furniture, boundary treatments, lighting, signage, high quality materials and finishes to help create a durable development with local distinctiveness;

i.  avoid unacceptable overlooking or loss of privacy;

j.  safeguard the living conditions of future occupants of the development and adjacent residents;

k.  sensitively integrate parking places and functional needs for storage, refuse and recycling collection points;

l.  mitigate the impact of air, noise, vibration and light pollution from internal and external sources, especially in intrinsically dark landscapes and nature conservation, as well as residential areas;

f.  access, routes and connectivity for cyclists and pedestrians through and out from development sites should be superior to that provided for motorists so that walking and cycling becomes the natural choice for journeys around the locality;

g.  ensure public and private amenity spaces of both existing and future development are inclusive, usable, safe and enjoyable; these include indoor and outdoor space, outlook, natural lighting, ventilation, matters of privacy, overlooking;

h.  create a range of opportunities for natural surveillance and observation;

j.  integrate a mix of building typologies that meet the diverse needs of people in the borough;

k.  meet the principles of inclusive design, active design principles, and facilitate an inclusive environment for people of all abilities and age, ethnicity, gender, economic circumstances, and faith;

l.  be designed to minimise criminal activities or perceived threat of crime and improve community safety; and

m.  respond positively to the context, for example by reusing sustainable materials, finishes and street furniture that are suitable to the location and context.

B.  Successful Proposals for major development of the sites will require should be supported ing documents such as a strategic masterplan, by an area specific masterplan,. Where appropriate,the Council will consider the use of a complementary design guide/code, to help guide the necessary design coherence across the entire development site,. irrespective of who delivers the different locations or components of the scheme. Design proposals will be expected to:

a.  demonstrate early, proactive, inclusive and effective engagement with the community and other relevant partners;

b.  have regard to Supplementary Planning Documents and Guidance published by the Council, Essex County Council and other relevant bodies;

c.  address feedback from the Council through its Pre-application Advice Service and where appropriate, feedback from an independent Design Review Panel.

A.  Development proposals for large complex allocation sites will be expected to be developed in partnership with the Council, infrastructure providers and other relevant organisations, through a collaborative masterplanning approach.

C.  C The Council may, at its discretion, appoint an independent Quality Design Review Panel to review the detailed design proposals, to provide additional rigour to the design-thinking process, thereby ensuring the longer-term sustainable success of the development.

D Development proposals should submit be supported by a supporting statement setting out the sustainable long-term governance and stewardship arrangements for the maintenance of supporting infrastructure including community assets, and open spaces; the statement should be proportionate with to the scale of the scheme and quantum of infrastructure being delivered.

In addition, proposals should reflect the requirements of Brentwood Borough's Masterplan requirements where applicable.

Delete paragraphs 6.86, 6.89, 6.90

Reorder and amend paragraphs 6.85, 6.91, 6.92, 6.93, 6.94, 6.95, 6.96 as follows (Note: paragraph numbering used for this are those found in the Pre-Submitted Plan but will be changed - numbering to be determined):

Delivering High Quality Design

[unnumbered paragraph above 6.96] Achieving well-designed places is fundamental to creating distinctive and sustainable communities. It also ensures the development will function well over the lifetime of the development, ensuring that the design of the buildings and places have taken a proactive approach to mitigating and adapting to climate change. All proposals must clearly demonstrate that a comprehensive design approach has been used to inform the development and The Council expects all the that all issues within this policy to be are positively addressed through the Design and Access /Planning Statements that accompany applications. Additionally, sustainable development must also factor in how supporting infrastructure will be maintained throughout the life-time of the development. The design should therefore, factor in the lifespan of materials being used, and provide details for how these assets will be maintained over time, such as stewardship arrangements, where necessary.

6.93 The Council will require design to be addressed through early engagement in the pre-application process on major and strategic developments and in connection with all heritage sites. Where appropriate, the Council will require the use of masterplans and design codes to clearly set out the design rationale of the development site. For major sites/strategic sites and complex developments, design codes will need to be prepared in Applicants should work collaboratively with those affected by their proposals to evolve designs that take account of the views of the community conjunction with the Council and local stakeholders to and ensure proposals have responded positively to local knowledge and context of the site appropriate character and high-quality design is delivered throughout. Reference to existing Masterplans must be made, as applicable.   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. Applicants that can demonstrate early, proactive, inclusive and effective engagement with the community will be looked on more favourably than those that cannot. 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. Where a site and involves more than one developer, a collaborative masterplanning approach is expected to set out ensure the coherent application of design principles for the across the whole development of the site. The level of prescription will vary according to the nature of the site and the development proposed. The Council may, at its discretion, appoint an independent Quality Design Review Panel to review the detailed design proposals, to help provide additional rigour to the design-thinking process, thereby ensuring the longer-term sustainable success of the development.

Insert paragraphs 4.1 and 4.2 after paragraph 6.93

Local Character and Context

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.

6.96 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. 6.94 Brentwood's environment, its significant These 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.

6.92 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 should clearly show an analysis of the site context, indicating the opportunities and constraints, and an explanation and justify ication of the principles that have informed the design rationale.

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.

6.95 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 Proposals should either enhance local distinctiveness it or will seek to introduce distinctiveness to poor quality areas lack of character. When undertaking context appraisals and Design and Access Statements , applicants should consider and set out in the Design and Access Statement the following:

i.  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;
ii.  the environmental context: open spaces, bio-diversity structure, landscape character, areas liable to flood;
iii.  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;
iv.  the spatial context: identifying the development site's position within the urban hierarchy;
v.  the operational context: showing how infrastructure and facilities are used and their capacity to accommodate further demands;
vi.  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
vii.  the historic context: seeking to encourage new development that respects, incorporates and fits and is informed in with by the character of and traditional historic form of the settlement in which of the Essex towns and villages the development will take place within.


Design Considerations

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

6.102 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.

6.116 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.

Insert the following paragraph after 6.117 to read:

Trees that line new streets are considered part of the GBI of the developments and as such proposals should provide appropriate long-term maintenance of newly-planted trees throughout the life of the development, in line with Strategic Policy NE02 Green and Blue Infrastructure


To make the policy effective, and consistent with national policy




Page Number 151 , Policy HP14, Policy HP15, Policy HP16, Paragraph 6.94 - 6.106


Delete Policy HP14 - HP16.

Move their supporting text to support policy HP13.

Delete paragraph 6.97, 6.99, 6.100, 6.105, 6.106.


To make the Plan effective.




Page Number 155-156 , Policy HP17, Paragraph 6.107 - 109


Delete Policy HP17 and supporting text paragraphs 6.107, 6.108, 6.109 as covered by heritage and flood risk policies within the Plan.


To make the Plan effective.




Page Number 156-158 , Policy HP18, Paragraph 6.110 - 6.118


Delete Policy HP18

Move paragraphs 6.116, 6.117, 6.118 to support HP13

Delete paragraphs 6.110, 6.111, 6.112, 6.113, 6.114, 6.115


To make the Plan effective.




Page Number 159-161, Heritage section, Paragraph 6.125, Policy HP19, Paragraph 6.128 - 6.131, Appendix 6


Move the section on Heritage including all relevant policies and supporting text to Chapter 5.

Amend paragraph 6.125 to read:

Non-designated heritage assets can include buildings, places, lanes or areas of cultural and/or local significance, or non-designated archaeological sites and deposits 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.

Amend Policy HP19 to read:


1.  All Designated Assets

A.  Great weight will be given to the preservation of a designated heritage asset and its setting. All dDevelopment proposals that affecting a designated heritage assets, including a listed building, conservation area, registered parks and gardens, or scheduled monument, and their settings will be required to:

a.  i.  conserve, sustain and wherever possible enhance designated and non-designated heritage the significance of the assets and its settings (including views into and out of conservation areas and their settings); and be sensitively sited and integrated in accordance with advice in accordance with national policy and guidance;

b.  ii.  submit be supported by a Heritage Statement providing sufficient information on the significance of the heritage asset (according to its importance), the potential impacts of the proposal on their character and significance of the asset and its setting, and how the a proposal has been designed modified to take these factors into account. The Statement should make an assessment of the impact of the development on the asset and its setting and the level of harm that is likely to result, if any, from the proposed development; mitigate harm; where archaeological potential is identified this should include an appropriate desk-based assessment and, where necessary, a field evaluation; and

c.  iii.  provide clear justification for any works that would lead to any harm or substantial harm to the a heritage asset through detailed analysis.

B.  Proposals that make sensitive and appropriate use of heritage assets, particularly where these bring redundant or under used buildings or or buildings areas, especially any on the English Heritage's at At Risk Register, into appropriate use consistent with their conservation status will be supported encouraged.

C.  When considering proposals for development that affect non-designated heritage assets the Council will take into account the scale of any harm or loss and the significance of the heritage asset as set out in accordance with national policy and guidance. Proposals designed to enhance an asset and/or its setting and which reinforce its significance and contribution to the character of an area will be supported.

D.  Development proposals that would be likely to cause either less than substantial or substantial harm to, or loss or partial loss of, a designated asset or its setting will be assessed in accordance with the statutory framework and national planning policy.

E.  Where a proposed development involves the loss or partial loss of a designated asset, applicants will be required to record and advance understanding of the asset in a manner proportionate to its importance and the impact which will be caused.

2.  Conservation Areas

In addition to satisfying the relevant criteria in 1 above:

i.  permission for proposals which involve the demolition or partial demolition of a building in a conservation area will only be granted subject to a condition and/or a planning obligation (as appropriate) that no demolition will take place until an enforceable contract has been let for the carrying out of the new development.

ii.  development will be permitted in a conservation area where the siting, design and scale of the proposed development would preserve or enhance its character or appearance and important views into and out of the area are preserved or enhanced.

3.  Non-Designated Heritage Assets

Development proposals that affect non-designated heritage assets and their settings, including protected lanes, should seek to preserve and wherever possible enhance the asset and its setting. When considering proposals which are likely to cause harm to such an asset consideration will be given to:

i.  the significance of the asset and its setting;

ii.  the extent to which the harm has been minimised; and

iii.  the extent to which the benefits of the proposal outweigh the harm

4.  Specific Requirements

Specific requirements in relation to particular heritage assets identified in housing allocation policies should be read alongside the overarching requirements of this policy.

Insert additional paragraphs before paragraph 6.128 to read:

Historic Records

All development proposals should be based on a full understanding of the significance of heritage assets, both within the proposed development site and within the surrounding area. This should be established by reference to relevant and available sources of historic environment information. Heritage assets are depicted on the Policies Map, however applicants are advised to consult the Essex Historic Environmental Record held by Essex County Council as well as any records held by Historic England and other sources to ensure the most up to date records are reviewed before submitting an application. It is also advised that early engagement is sought with the Council's Historic Buildings Advisor through pre-application consultation.

The Council recognise that on occasion heritage assets are not always documented of fully understood and could be identified through the development process; for example revealed by local groups through the consultation process or during preliminary site investigations undertaken by an applicant. In these circumstances the Council expect a positive approach to ensure the significance of these non-designated heritage assets are appropriately conserved and enhanced.

Amend paragraph 6.128 and insert new paragraph after to read:

Heritage Statement

6.128. All development proposals that are likely to have an impact on a heritage asset or its setting must be accompanied by a Heritage Statement that When submitting planning applications, applicants are required to clearly describes the significance of both the heritage assets and the setting as well as proportionately and assesses how the proposal impacts upon it, in relation to its form, fabric, setting, architectural or historic relevance. The level of detail needed should be proportionate to the scale and nature of the proposal and the importance of the asset itself. affected, together with a. A schedule of works should be included. analysing the impact of the proposal on the form, fabric and setting of the heritage asset and any features of historic or architectural interest. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed, using

The Council advise that applicants seek advice from specialist historic environment consultants where necessary, to carry out appropriate assessments. appropriate expertise where necessary.

In respect of the loss of any asset the Council will require applicants to record the significance of any asset to be lost in a manner proportionate to its importance and the impact. The applicant should deposit such evidence to the Essex Historic Environment Record.

Delete paragraphs 6.129 to 6.131


Amend definition of 'Heritage Asset' in Appendix 6 - Glossary as follows:

Any structure, building, system facility and/or provision required by an area for its social and/or economic function and/or wellbeing including (but not exclusively): footways, cycleways and highways; public transport; drainage, SuDs and flood protection; waste recycling facilities; education and childcare; healthcare; sports, leisure and recreation facilities; community and social facilities; cultural facilities, including public art; emergency services; green infrastructure; open space; affordable housing; live/work units and lifetime homes; broadband and facilities for specific sections of the community such as youth or the elderly.

A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage assets include designated heritage assets and assets identified by the local planning authority (including local listing).


To make the policy consistent with national policy and effective

To provide clarity.




Page Number 161-163 , Policy HP20


Delete Policy HP20

Retain paragraph 6.132 to 6.139 to support Policy HP19 (now BE16)


To make the Plan effective.




Page Number 161-163 , Policy HP21, Paragraph 6.141, Paragraph 6.144


Delete Policy HP21 and paragraph 6.141

Retain paragraph 6.140, 6.142 to 6.144 to support Policy HP19 (now BE16)

Amend paragraph 6.144 to read:

6.144 In order to ensure a high standard of design and materials, outline applications will not be accepted.


To make the Plan effective.




Page Number 164-167 , Policy HP22, Paragraph 6.151, Paragraph 6.152


Delete Policy HP22

Retain paragraphs 6.145 to 6.152 and Figure 6.5 to support Policy HP19 (now BE16)

Amend paragraph 6.151 to read:

6.151 In line with other policies within the Local Plan, Mmaterial 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. Any proposals that would have a materially adverse impact on the physical appearance of Protected Lanes or generate traffic of a type or amount inappropriate for the traditional landscape and nature conservation character of a Protected Lane, will not be permitted.

Retain paragraph 6.152 and insert new paragraphs after to read:

Mitigating Impacts

The heritage environment should be considered as an integral component of Brentwood's public realm and contribute positively to maintaining sustainable communities and must therefore, meaningfully inform the design of development. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), requires clear and convincing justification. Applicants are expected to demonstrate how the heritage assessment (as documented in the Heritage Statement) has appropriately informed and guided the design of the proposal to ensure they do not impact the architectural details and qualities of the asset. Proposals should be of the highest architectural and urban design quality, having regard to and respecting local character and other policies in this plan. Development proposals that appropriately preserve or help to better reveal and enhance heritage assets and their setting will be supported.

Heritage-led Regeneration

A Heritage at Risk programme has been implemented by Historic England. It protects and manages the historic environment so the number of 'at risk' historic places and sites across England is reduced. The Heritage at Risk Register identifies those sites that are most at risk of being lost as a result of neglect, decay or inappropriate development. Proposals which seek to bring such assets back into appropriate use and help revitalise neighbourhoods in accordance with national policy will be supported.


To make the Plan effective.




Page Number 167-168 , Policy HP23, Paragraphs 6.156 - 6.158


Delete Policy HP23.

Move paragraphs 6.153 to 6.158 to support policy HP19 (now BE16), amend paragraph 6.156 as follows:

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


To make the plan effective as this policy is covered by HP19 setting out policy consideration for heritage asset, which includes sites of archaeological interest and scheduled monuments etc.



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