It's stated that the Sustainability Appraisal is a "systematic process". Note that the "Site Options Appraisal Findings Table C" from the original AECOM Interim SA
(Ref: AECOM Interim SA Report, Feb 2016; http://www.brentwood.gov.uk/pdf/12022016101306u.pdf) contained "24 Appraisal Criteria". The updated AECOM Interim SA (January 2018), now contains just "17 appraisal criteria". What has happened to 7 of the criteria in this systematic update; including removal of "Protected Urban Open Space" of which some sites performed poorly in 2016 (sites 044 & 178). Suggest to delete the word "systematic" unless justification for the change in criteria is provided.

Every methodology has its weak points however I support this approach

As regards the Interim SA, I value the biodiversity objective highly and so, when balancing various competing objectives, I would like serious note to be taken of paras. 7.3, 10.3 and other allied references such as 10.10. Whatever the eventual outcome, the need to achieve net biodiversity gains will be important.

ECC acknowledges that the Interim SA Report identifies a good range of both high level and more focused options for exploration, with a clear narrative throughout as to what constitutes a 'reasonable alternative'. This is an important step at this stage in the context of the plan-making process to date and the issues that BBC has faced.

ECC considers that Table 6.2 presents a thorough and useful number of options / permutations related to a spatial strategy for the Plan area. The findings of the Interim SA in regard to the 'preferred allocations' however is similarly high level and is limited to the identification of general cumulative impacts over a broad area. It is considered that the Interim SA should offer more commentary and recommendations regarding the assessment of sites at the 'local / micro level' in order to justify some of the high level conclusions. This is in light of the wide range of impacts identified within the individual site assessments in Appendix III which do not appear to be elaborated on.

ECC also recommends further cumulative impacts could be identified at a more local level. This could serve to further assist BBC in both the site selection of small sites in an area, and also the development of site specific policies at the Regulation 19 stage.

ECC notes that the Interim SA takes the same approach as the 2016 Interim SA when arriving at reasonable alternatives, which seeks to develop the reasonable alternatives for strategic level growth arising from work undertaken in 2015/2016, rather than the overall SA process. ECC recommends that a comprehensive audit trail of those alternatives that have been considered and subject to SA throughout the plan-making process should be produced, including detailing the reasons for rejecting and progressing alternatives at each stage. In addition, the cumulative assessment of the 'givens', for the purposes of satisfying the requirements of SA, should be presented, alongside their cumulative impacts to inform the strategy proposed.

In paragraph 6.3.2 of the Interim SA, reference is made to significant concerns raised to the DHGV allocation in the 2016 consultation having been addressed. ECC seeks clarification as to how these concerns have been addressed, particularly those raised in the ECC response to the BBC 2016 Draft Local Plan.

ECC would draw attention to a number of the conclusions on the Draft Plan in Chapter 10 of the Interim SA, which appraises the Draft Local Plan. It is clear that a significant amount of work is still to be undertaken to address concerns and uncertainties, and ECC seeks clarification that these matters will be addressed as part of the preparation of the pre-submission plan.

Areas of concern as to certain conclusions in the SA are as follows:

* Air Quality - concludes that no significant effects are likely to occur, however highlights there is considerable uncertainty at the current time ahead of further work still to be undertaken, including highway modelling;
* Climate Change - concludes that no significant effects are likely to occur, however highlights there is considerable uncertainty, with further work still to be undertaken, in relation to how the Plan can reduce CO2 emissions, including from transport;
* Economy and Employment - concludes possible significant effects, but uncertainty in the absence of detailed transport modelling;
* Landscape - concludes that there are likely to be significant negative effects; further work required to identify developable parts of sites and strategic open space and landscaping;
* Soil and Contamination - concludes that there are likely to be significant negative effects; an increase in the number of homes required is likely to increase the amount of agricultural land to be lost, some of which is likely to be 'best and most versatile';
* Water Quality and Water Resources - concludes effects are currently uncertain; need for detailed examination of waste water treatment capacity, and further work for robust DM policy to be in place.

ECC welcomes the comments in relation to the following:
* Biodiversity - further work to focus on borough-wide and site specific policy on ensuring development achieves net biodiversity gains
* Community Infrastructure - work on-going to understand issues, working with partners including ECC
* Flooding - thematic and site specific policies to be examined further including master planning and SUDs
* Waste - some waste infrastructure capacity issues locally to be addressed

In terms of assessing heritage in the SA, it is clear that listed buildings and conservation areas have been considered, however there is no reference to the extensive archaeological remains within the Borough. ECC considers that a Historic Environment Characterisation report, including consideration of archaeology, should support the preparation of the draft Local Plan.

ECC also recommends that Section 13.1.2 incudes a bullet point on the impacts for archaeology and historic landscape.

ECC welcomes the draft HRA screening report and the references to co-operating with other Essex local planning authorities (LPAs) on a strategic mitigation scheme for recreational disturbance (RAMS) to deliver measures to avoid adverse impacts on site integrity on European sites. The emerging RAMS is being co-ordinated by ECC for the 11 Essex LPAs needing to provide mitigation measures.

ECC recommends that references to developer contributions towards the Essex Coastal RAMS need to be clear. These should be sought from developers (not new residents), to avoid impacts from recreational disturbance, in combination with other plans and projects. A reference to the need for project level HRA for developments not proposing to contribute to the RAMS may also be helpful. This could be to secure bespoke mitigation measures in certain cases. Furthermore it is recommended that a reference is also made to project level HRA's, to ensure applicants minimise likely impacts from the developments alone in terms of layout.

ECC welcomes the acknowledgement for the need for a mitigation strategy for Epping Forest Special Area of Conservation (SAC) to deal with increased atmospheric pollution, and looks forward to receiving more details on modelling.

ECC notes that the evidence base for the Local Plan includes a Local Wildlife (LoWS) Review (2012) which enables consideration to be given to minimising impacts of site allocations on these non-statutory designated sites for biodiversity. However ECC advises that BCC should carry out assessments in relation to the preferred site allocations, including DHGV, to establish if they contain Priority habitats and species which could meet the criteria for new LoWS.

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

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

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

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

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

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

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

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

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

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


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

The consultation document proposes a large number of possible sites for the development of residential and business properties. The supporting evidence on critical strategic infrastructure is poor; indeed they are described as "interim" and leave many issues not assessed. Of these the flood risk assessment for the area of West Horndon is a key missing assessment. West Horndon is recovered fen land and as such has poor natural drainage which was made much worse when in the 1800s the railway line was constructed. Subsequent industrial and residential development has only made matters even worse. Over many years there have been a number of significant incidents with properties being seriously flooded. Following floods in the early 1980s surface water drainage was improved but the risk is still significant and during the winters of both 2012 and 2013 properties were once again flooded. The NPPF is very clear (paragraphs 94 & 100 - 103) that any development must take full account of flood risk before development is considered. Given the lack of detailed flood risk assessment it is impossible for anyone to come to a view on the use of any of the sites in the West Horndon area because they cannot understand the flood risk. Thus, I question if this consultation is valid given the public are being asked to comment on something that no one can take an informed view of because of the lack of supporting evidence. The spatial strategy identifies the A127 corridor as an appropriate location for the development of new homes and business and employment opportunities. At first sight this is a reasonable approach, however there is no supporting evidence that infrastructure in the corridor could cope with the additional load such development would create. Currently the A127 is at or over capacity much of the time as is the C2C railway line. Given that other local authorities are proposing development that would need to be supported by the transport infrastructure of the A127 corridor there is no clear evidence that it will be possible to upgrade the current road and rail systems to cope with the additional housing/business development being proposed in this consultation document. I should point out that the rail line is only two tracks and Fenchurch Street station only has 4 platforms. It is hard to conceive that a significant increase in capacity can be created as there is no physical room for more platforms at Fenchurch Street and the line west of Upminster runs through dense residential development and thus the opportunity for upgrade must be minimal. Similarly, the A127 (which is only two lanes in each direction) west of Upminster also runs through residential areas thus increasing the number of lanes to increase capacity must be questionable. While I recognise the upgrade of strategic transport infrastructure is not within the remit of BBC, developing a Local Development Plan (LDP) in the absence of information about the critical infrastructure is a nonsense. The LDP should make it clear that any proposal is totally dependent on appropriate infrastructure upgrades being planned and implemented concurrently with the proposed development. I also point out that the trains from Brentwood and Shenfield are on the new Cross-Rail line and thus the capacity is significantly improved. There are plans to upgrade much of the A12 to three lanes in each direction - so with respect to transport infrastructure corridors it is the A12 corridor that would seem most appropriate to consider for residential and business development opportunities than the A127 corridor. This site, south of the Grade 2 listed East Horndon Hall is being proposed for development as an industrial site. This land is Green Belt and thus any development is inappropriate. The NPPF clearly states that for development to take place in the Green Belt very exceptional circumstances need to be demonstrated. None are. This land is also subject to flooding - it regularly has standing surface water and acts as a storage buffer which prevents flooding of the surrounding land including residential areas. The planning application 17/01597/EIASO which first proposed this site for development as a business park includes a surface water flood assessment which only looks at a superficial level at the site itself. This is contrary to the NPPF (paragraph 102) which requires a flood risk assessment that demonstrates that any such development does not increase flood risk elsewhere. Given the history of flooding in this area (properties were flooded, and the main road blocked in December 2012) this site is clearly inappropriate for any development. These now aging industrial sites are appropriate for redevelopment and redevelopment to residential (or part residential) use is appropriate for this brown field land. In broad outline I support these sites being redeveloped. However, there are a number of concerns that must be taken into account. 1. Access - the current access arrangement date back to the late 1930s when the site was first built. The amount of traffic in those days was significantly lower than today. The current land use means that much of the traffic is large HGV lorries which are large and easy to see. Redevelopment to mixed residential and business use will increase the number of cars and light van traffic which will increase the risk of accidents. There already a large number of small shunt accidents in the vicinity of the entrance to this site. Thus, it is imperative that before any redevelopment takes place vehicle and pedestrian access is properly resolved; 2. West Horndon is a rural community and the development must be sympathetic to this. This site is quoted as being 17.06ha. Given that rural residential development should be at about 30 properties per hectare the 580 quoted seems to be very much at the top end of the appropriate number; 3. Although West Horndon is identified as a transport hub on account of the Railway Station, access is only east/west so most residents will definitely need cars. It is imperative that the design of the site is such that car parking is at a higher level than is normal for transport hub locations. West Horndon already has significant residential parking problems and this redevelopment must not make that worse. Thus, the design and number of properties must be able accommodate sufficient parking. Design is for the normal planning process, but I would suggest that for the strategic purposes of the LDP the number of properties should not exceed 500 - reduced as necessary according to how much of the site remains in business employment usage. Broadly I support the development of these sites for employment. They are situated close to the M25 as a major transport link and their use especially for enterprises which use large amounts of HGV traffic would be welcomed as that would reduce HGV traffic through residential areas like the village of West Horndon. There are potential issues about access to these sites for staff working there, there is at present no public transport access. This detail will need to be dealt with at the full planning application stage. This area is Green Belt and thus development seems inappropriate. However, I do recognise that Brentwood is ~89% greenbelt and that opportunities for non-green belt development are limited. Given the strategic housing allocation central Government is imposing on BBC this area probably needs to be considered as an option. I point out that green belt to the north of the Borough is open and that development in such areas could be undertaken to make an isolated village(s). The Dunton Hills site is almost the last green belt gap between Upminster (London) and Southend thus the development of this site would basically create continuous development between London and Southend. This would seem to be contrary to the principles set out in the NPPF. I also question the ability to construct sufficient transport infrastructure to support the development, but I can find no assessments examining this situation in appropriate detail. However, given the situation BBC finds its self in Dunton Hills Garden Village (DHGV) may be the least worst option to meet the strategic housing allocation. If this is to proceed it must be done in such a way that the impact on the surrounding area and communities is limited to a minimum. To this end the western side of the site needs to be restricted and turned into a buffer zone e.g. by creating a woodland. This would have the effect of visual separation between the two villages and would also mitigate some of the potential flood risk that the development would create. It would also make future attempts to expand the development and join the two villages much more difficult. This approach is consistent with the guidance in the NPPF for change of use of green belt land. I suggest that the site map is modified to make it clear that there must be a buffer zone between the DHGV and the A128. If this development does proceed it will generate traffic between it and the railway station in West Horndon. Parking is already a problem in the village of West Horndon and it is essential that means to minimise and manage this are sought and incorporated at the very outset of planning. The current plan suggest that the required G&T site are developed and located adjacent to new residential developments as they are constructed. My understanding from the results previous consultations is that G&T communities prefer sites to be away from business and residential areas. Indeed, one G&T site situated just north of the A127/A128 junction has to my knowledge not been used in over 30 years. I understand this is because it is too close to other developments. This aspect of the site plan allocation needs a total rethink.

Page 3 Para. 5: While this document is primarily a consultation on sites, we have also updated our vision, strategic objectives and spatial strategy to reflect progress made on the technical evidence and review of representations. Comment/Objection: Whilst there may have been a review of representations, there has been no formal, detailed response to representations made by PLNRA since March 2016. Page 4 Para. 7: Evidence in its broadest sense means anything that informs the plan-making process, including the Sustainability Appraisal, Duty to Cooperate discussion, consultation responses, and technical evidence. Comment/Objection: There is no evidence in any section of the Draft Local Plan that PLNRA responses to the plan have been taken into account and that detailed sustainability and technical evidence submitted have been analysed and given appropriate consideration. Page 4 Para. 8: A Consultation Statement detailing previous representations has been published alongside this document. Comment/Objection: There are various references to previous historic consultation exercises undertaken, but an up-to-date document detailing the 2016 representations has not been found yet, other than reference to the numbers of responses made. Page 4/5 Para 9: Support for protecting the Green Belt and environmental assets, and building upon brownfield land only were strong themes in the consultation feedback. A number of stakeholders objected to the Dunton Hills Garden Village in principle and the extent of development along the A127 corridor. A wide range of comments were also raised on the need for additional plan evidence. Comment/Objection: Sites 044/178 are greenfield protected urban space sites. The Dunton Hills development is mentioned specifically, but the Priests Lane sites, which attracted a high proportion of objections, are not mentioned. Page 6 Para 14: In arriving at a list of preferred site allocations, we have developed a site assessment process. This is robust, balanced and wide-ranging in terms of technical evidence material for each allocated and discounted site. Comment/Objection: There is no evidence as to why sites 044/178 are preferred sites other than, presumably, they are available. The site assessment (Page 72) is shallow and weak. There is no evidence of robustness or balance. Page 6 Para 15: A key part of the evidence base is the Sustainability Appraisal (SA)...Its role is to promote sustainable development...The SA allows us to consider opportunities to improve environmental, social and economic conditions in the local area and identify how to mitigate the impact of development. Comment/Objection: To what extent is there a specific Sustainabilty Appraisal of sites 044/178? How will environmental, social and economic conditions be improved in Priests Lane and how will the impact of development be mitigated? There is no evidence provided as answers to these questions. Page 6 Para 17: Refers to a Habitats Regulations Assessment screening that has been undertaken for Local Plan sites. Comment/Objection: What does it say regarding sites 044/178? It is not mentioned in the preferred site statement. Page 7 Para 18a: delivering the right infrastructure at the right time: ensuring that infrastructure to support new housing and employment opportunities, such as schools, health and transport are delivered at an appropriate scale and in a timely manner. Comment/Objection: Mere verbiage with no detail, although statistics on schools and local surgeries do appear later. Page 7 Para 18c: supporting high quality design...helping to minimise the impact of new infrastructure on local character and enhancing areas through innovative design which positively responds to local heritage and environments. Comment/Objection: No evidence presented as to how this might be achieved. What is meant by 'innovative design' that would be in keeping with the Priests Lane environment? What design strategies are profit-making developers likely to adopt? Page 7 Para 18d: enhancing green infrastructure networks: improving the quality, range and connectiveness of the Borough's natural green assets. Comment/Objection: How will this will be helped by removing a protected greenfield site? Page 7 Para 19: refers to the Draft Infrastructure Plan that is being continually updated. Comment/Objection: What is this? Page 11 Inset: The Borough will continue to thrive with a high-quality network of green infrastructure, parks and new connected green corridors, providing cycling and walking opportunities for all.....Brentwood will grow sustainably with new development directed to urban brownfield opportunity sites, well planned urban extensions. Comment/Objection: Except for Priests Lane, presumably, since we are targeted to lose a green space and have a highway that is conducive neither to cycling nor walking, but a connecting 'rat-run between Shenfield and Brentwood traversed by high speed traffic. Page 12 Para 28 SO1: maximise sustainable growth opportunities within our built-up areas and on brownfield sites. Page 12 Para 28 SO2: direct development growth in locations well served by existing and proposed local services and facilities. Page 12 Para 28 SO5: manage development growth to that capable of being accommodated by existing or proposed infrastructure, services and facilities. Comment/Objection: What represents 'sustainable' growth? Why are sites 044/178 the only identified greenfield sites? What evidence is identified for sites 044/178 being well served by existing infrastructure, local services and facilities - a set of statistics about schools and surgeries does not equal appropriate services? What proposals are there to enhance services? Page 12 Para 28 SO6: Plan for housing...creating inclusive, balanced, sustainable communities. Comment/Objection: What precisely does this mean for Priests Lane, one of the highest value housing areas in the borough? Page 13 Para 28 SO16: Protect and enhance valuable landscapes and the natural and historic environments. Page 13 Para 28 SO17: Establish a rich connected network of Green infrastructure across the Borough and reaching beyond. Comment/Objection: Developing sites 044/178 is clearly contrary to both the above objectives. Page 13 Para 28 SO19: Secure the delivery of essential infrastructure, including education, health, recreation and community facilities to support new development growth throughout its delivery. Comment/Objection: There is no evidence to confirm that education and health facilities will be delivered, given that the expansion of Hogarth School is to meet current need, whilst there is no evidence to support any view that surgeries can and will meet any substantial increase in demand - statistics do not often equate to reality. Page 13 Para 28 SO20: support self-build housing in sustainable locations across the Borough. Comment/Objection: What precisely does this mean? Which locations? Safeguards against blight? Page 13 Para 28 SO21: Improve public transport infrastructure and ensure development sites are well connected to bus and/or rail connections Page 13 Para 28 SO22: Improve cycling and walking facilities across the Borough and establish a grid or network of green transport corridors. Comment/Objection: Priests Lane is too narrow for public transport; the distance to buses and stations is not likely to reduce reliance on cars. Priests Lane is poorly served by pavements, which are too narrow and situated on alternate sides of the road. Any improvements are likely to narrow the width of the road below national guidelines that the Lane hardly meets now and actually transgresses in some places. Cycling in Priests Lane is almost suicidal and is rarely in evidence!! Page 14 Para 31The spatial strategy continues to focus upon the sequential use of land which prioritises using brownfield first and then considers growth in settlements in terms of their relative sustainability linked to services and facilities. This approach is in line with government guidance and best practice. The release of Green Belt land should only be considered after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. Comment/Objection: Again we have to ask - why sites 044/178, given their denotation? There is no evidence presented about their sustainability and likely required links to services and facilities. Which sites have been discounted as alternatives to these 2 sites? Pages 18/19 Paras 41/42: However, importantly due to the worsening of the affordability ratio in Brentwood and the increased costs of rental levels, conclusions identify the need for a reasonable upwards market signal adjustment. Compared to most of Essex, the borough is much less affordable, homes are more expensive, and now less affordable than the last housing boom. The degree of market signal uplift is a matter of professional judgment and evidence indicates a 30% uplift above the new 280 dwellings per annum baseline, plus a small contingency of 6% should new official projections indicate a slightly different position to that forecasted. 42. In summary, using the minimum revised net dwelling baseline figure (280) plus combined market signal adjustment and contingency adjustment of 36%, this leaves an objectively assessed housing need of circa 380 dwellings per annum or 7,600 dwellings across the plan period (2013-33). The revised housing need from 362 per annum to 380 per annum across the plan period (20 years) equates to a total dwelling increase of 360 additional units.'. The updated SHMA is published as part of this consultation. Comment/Objection: I am not qualified to analyse the Housing Need statistics and hence assume them to be accurate. However, what are concerning are the admissions that housing and rental costs in Brentwood are high and less affordable, that projections suggest that perhaps only 280 dwellings are required per annum and that, therefore, a market signal uplift of 30% plus a contingency of 6% should be accepted, raising the annual build to 380. The statisticians amongst us will correct me, but am I to assume that the increased build per annum (which is substantial) is to do with increasing supply in the hope of reducing house/rental prices? This would actually be insane if the projected demand does not, and was never meant to, meet supply. Page 22 Para 55: The Council received a number of representations on the Draft Local Plan (2016) suggesting that there was a lack of information about the site assessment methodology and overall process. A summary of the site assessment process undertaken is detailed in Figure 7, with a detailed site assessment methodology technical note available alongside this consultation. This work is based upon best practice and is considered to provide a robust framework for site assessment and selection. NPPF Footnote: To be considered deliverable, sites should be available now, offer suitable location for development now,..be achievable... delivered within five years and in particular that development of the site is viable; to be considered developable, sites should be in a suitable location for housing development. Site options will be assessed in terms of their impact on a number of primary factors, including flood risk, Green Belt, landscape and highways....impact on historic assets, ecological designations, utilities, education and health facilities. All sites that have passed stages1 and 2 (site selection) will be appraised using objective (WHERE POSSIBLE) site selection criteria. This stage will identify any significant negative effects THAT MAY REQUIRE MITIGATION (my capitals) if a site is subsequently put forward for allocation. This study will identify whether proposed areas/sites/types of sites are viable and deliverable in the plan period. If evidence cannot give this confidence then it may be necessary to revise draft local plan policies and/or go back a stage and find alternative sites. This approach attempts to maximise brownfield redevelopment opportunities and support growth within sustainable locations. Comment/Objection: We need to review the technical note, given that the assessment of sites 044/178 is so weak. Note there is no comment in this revised plan Site Assessment of 044/178 referring to flood risk, landscape, highways, ecology, utilities, whilst the statistical references to Hogarth School and surgeries are questionable. Furthermore, if the process is so robust, why should site selection criteria not be objective? Why should a site that does not meet suitable selection criteria receive mitigation? With regard to Page 22 Para 55 we could conclude that there is a change of attitude here compared to that we have encountered in meetings with Louise McKinley and other councillors/representatives. Previously we have been told the entire Plan would be rejected by inspectors/government if sites 044/178 were not included as available sites. Para 55 implies this may no longer be the case and that sites that fail to meet development criteria could be discounted. Alternatively, we could interpret Para 55 as meaning that if sites 044/178 failed to meet the criteria, alternative reasons will be found to force development of the sites!! Page 25 Para 59: Brownfield Land within Brentwood Urban Area/Settlement Boundary 1,152 net homes / 13.94% of total build. Greenfield Land within Brentwood Urban Area/Settlement Boundary 95 net homes / 1.15% of total build Overall total build 8263 (100%) - Allocation total 6154 (74.48% of overall total). Comment/Objection: Whilst the net homes allocation at Priests Lane appears small taken as a total of planned building across Brentwood, the actual percentage of net build (Brentwood Urban Area Greenfield) at sites 044/178 compared to Brentwood Urban Area (Brownfield) net build is 8.25% which is a much higher percentage of net build in the Urban Area net build category, bearing in mind that the Priests Lane sites are the only identified greenfield sites in the entire plan/Borough. Furthermore, whilst comment on the planned 36% uplift on required housing has been made earlier, it is now clear this represents an net uplift of 2109 dwellings over the life of the plan, much of which would be expected to be built within 5 years of granted planning permission. These 2109 dwellings would then be built in the hope of driving down house/rental prices. Consequently, Priests Lane would be paying a rather high environmental price for the sake of an economic demand/supply house price lottery. Page 29 Para 64d: Work is progressing on....providing further design, layout and land use direction for the sites at Priests Lane and Honeypot Lane Comment/Objection: There is no detail provided about this and hence its meaning is unknown. Page 37 Para 77: For the year 2016/17, the net capacity of non-independent primary schools in the Borough was 6,032 pupils across 24 schools[11]. In the immediate future (2017/18) the net capacity of non-independent primary schools will increase to 6,222 pupils mainly driven by expanding Hogarth Primary School to a two-form entry (2FE) with 420 pupil capacity. Comment/Objection: The plan admits that the expansion of Hogarth Primary School will deal with predicted increased enrolments in 2017-18. It will then have a surplus capacity of 61 places by 2021-22. However, the Development Plan predicts a shortfall of places at Long Ridings Primary School of 217 places and Larchwood Primary School of 55 places - a total shortfall of 272 places. Since there is no mention of any further expansion at these 2 schools and given their relative proximity to Hogarth Primary School, it could be suggested that some of the need for places will be met by Hogarth. In this scenario further vehicle movements can be predicted in Priests Lane, increasing the danger to children that already exists. We should also recognize the notorious difficulty in predicting school place demand year-on-year (especially in areas of new housing - 95 homes could generate 30 children or 150, the number is unpredictable), the sudden inability of schools to meet demand and the unexpected frailty of schools where demand falls away. Page 45 Para 96: The Council will be looking to support the further development of the Endeavour School to provide facilities for sixth form students. This education requirement will need to be built into the detailed layout and masterplanning for the proposed housing site at land at Priests Lane (044/178). Comment/Objection: No detail is provided. What is clear is that expansion of Endeavour School, which is to be welcomed, is at odds with a sizeable housing development that will aggravate the health and safety obligations to already vulnerable children. Page 48 Paras 103 (stats) and 104: Current infrastructure services improvements alone are unlikely to address the significant patient pressures that may occur through housing growth in the Borough during the lifetime of the plan. Comment/Objection: If we only count forecast new patients at the nearest surgeries to Sites 044/178 - Rockleigh Court, Mount Avenue, The New Surgery and Tile House, they number 1023+1025+779+782 = 3609 respectively ( or a 34.46% increase). The average UK occupancy of each dwelling is 3.7; 95 houses could generate an additional population of 352 residents requiring medical services, i.e. 9.75% of the additional forecast new patients. It is well known that obtaining appointments at these surgeries is currently difficult or involves lengthy wait times, so the problems experienced by Priests Lane residents will only be exacerbated, a fact further aggravated by the local age profile. Page 50 Para 107: Brentwood is an attractive business location with a high quality environment .... and good transport links. Comment/Objection: Many local businesses have struggled to survive in a high rent and rates environment. Vacant sites at the Baytree Centre bear this out, along with the proliferation of food outlets in Brentwood and Shenfield High Streets. Brentwood High Street is mainly beset by fast food chains, hairdressers and charity shops - the recipe for High Street decline. As for travel to London, the current cost of a train season ticket from Shenfield is £3000. If the commuter wishes to go on from Liverpool Street to central London, the cost rises to £4000 and car parking is an extra £1000. Who exactly will be able to afford to live in Brentwood, commute to London and pay a mortgage for an affordable house in the borough, which is currently calculated at £440,000? Page 52 Para 110: The updated economic evidence...considers a number of evaluation factors including travel to work areas, commuting flows...and strategic transport routes. Comment/Objection: Priests Lane is a major traffic flow capillary connecting Shenfield to Brentwood and vice versa. As such it serves as a busy conduit to the A12, A127/A128 and the M25. It is historically and actually a lane that is poorly served by alternating narrow pavements and does not meet many national highway criteria nor acceptable health and safety standards. This highly unsatisfactory situation will only be worsened by the likely increased traffic coming from the central Brentwood developments and Officers Meadow (the need for which is understood). Priests Lane is not suited to serve increased traffic levels. (Included site plan for sites 178 and 044). Comment/Objection: The problems with access onto Priests Lane are not mentioned. The reference to secondary access via Bishop Walk is not supportable, given the nature/width of the road is only sufficient for the few houses it serves. The references to contextual analysis, informing typologies, scale, materiality and landscaping are not explained and are, hence, meaningless. There is a brief reference to traffic problems (but these are viewed cursorily as 'localised' - surely all traffic could be defined as localised!!) . All other myriad objections to sites 044/178, often highly technical and evidenced, relating to the LDP issued in January 2016 have been ignored, as they have been for the whole of the intervening period to date. The only mantra we have received is that the land 'must' be developed for the sake of the Plan - which has now been disproved. The current designation of the sites as Protected Urban Open Space is acknowledged.

Site 191 has been rejected because it has been considered
a) to be an isolated site within the Green Belt. Yes it is in the green belt (not isolated) but the land comprises part of an existing building plot and in any case the Government has suggested lifting restrictions on building in the green belt. Brentwood Council has admitted it is challenged when trying to meet government house building targets because so much of its land is in the green belt. Clearly the government's policy to ease restrictions has been implemented to help boroughs such as Brentwood to meet the targets.
and
b) not to be connected to an existing urban area. Not sure what this means. The land is about a 5 minute walk to a bus stop at which the 21 and 71 routes run an hourly service to Brentwood, Ongar, Harlow, etc. The land is also about a 10/15 minute walk to Kelvedon Hatch which is a fairly densely populated village. Buses from Kelvedon Hatch connect to the city of Chelmsford. Frog Street is a pleasant semi-rural location within easy reach of towns and shops. Not everyone wants to live in a built up area and it is considered short sighted to only consider development in existing built up areas. Providing a well balanced housing stock offering city and country dwellings seems a desirable course of action. The suitability of site 191 should therefore be reassessed.

This representation is made on behalf of our client, Barwood Land and Estates Ltd.
Barwood Land and Estates (BLEL) support the proposed allocation of Land at Honeypot Lane, Brentwood (reference 022) as a Brentwood Urban Area, A12 Corridor Urban Extension as set out at page 77 of the Local Plan. The proposed allocation follows the settlement hierarchy and proposed spatial distribution of housing set out in other plan policies and objectives. BLEL support the proposed housing allocation of Land at Honeypot Lane but raise a number of more specific comments as follows: BLEL consider that Land at Honeypot Lane has an indicative development capacity for >200 dwellings based on masterplanning and detailed site analysis/testing undertaken to date by BLEL and shared with the Borough Council. The proposed allocation information should therefore be updated accordingly for up to 250 dwellings total. The next iteration of the Local Plan Sustainability Appraisal should also take this quantum into account. BLEL note that the Honeypot Lane site is also identified as a potential location for a C2 Use Class care home and query where this indicative land use proposal originates as it has not been proposed to the Borough Council or discussed with BLEL as the development promoter to date. The reference to C2 Care Home appears to refer to paragraph 9.2.5 of the Interim Sustainability Appraisal Report that notes that there is a potential for some 40 bed space C2 Use Class provision for the site and itself purports to draw this from the latest version of the Borough's Strategic Housing Market Assessment. Land at Honeypot Lane is described as a 'self-contained urban extension' but clearly the development would be integrated with Brentwood and particularly with surrounding areas including St Faiths Country Park. Indeed, the site's location supports the potential for a high degree of integration rather than self-containment. BLEL suggest that the wording of the Local Plan text be modified accordingly in this respect. With respect to housing delivery, BLEL consider that Land at Honeypot Lane is capable of delivery within the five year period rather than in the longer 5-10 year period. The site is suitable, available and achievable and has a willing landowner, developer and investor. The potential for early delivery in the plan period has been discussed with the Borough Council and BLEL suggest that the Local Plan text be updated to reflect the ability to bring this site forward early in the plan period. Barwood Land and Estates support the Spatial Strategy shown in Figure 5 (page 17). The Spatial Strategy shows a realistic overall distribution of growth. It focuses on sustainable urban locations and the best opportunities for Green Belt release in/adjacent to existing higher order settlements in order to meet identified housing and economic growth objectives of the Local Plan. Barwood Land and Estates (BLEL) support the proposed Housing-led Allocation set out in Figure 9 (pages 26 - 27). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. Land at Honeypot Lane is a sustainable location and a deliverable housing site within the urban area of Brentwood. The site can come forward early in the Plan period without the need for extensive new infrastructure. Release of the site from the Green Belt will ensure development can be achieved in a timely manner and that this site can contribute to supplying much needed new housing in Brentwood. BLEL has undertaken an extensive and detailed technical and design analysis of the Honeypot Lane site and has concluded that the site is capable of delivering more than 200 dwellings without causing adverse effects on highways, landscape, amenity or other matters. BLEL has previously shared this analysis with the Borough Council. On this basis BLEL consider that the site is capable of sustainably accommodating up to 250 dwellings and the Local Plan should be updated accordingly at Figure 9 (and elsewhere where the Plan identifies a proposed allocation quantum for the site) to reflect this. Barwood Land and Estates (BLEL) support the proposed Settlement Hierarchy set out in Figure 14 (page 35). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. The proposed settlement hierarchy represents the current pattern of activity and forms a realistic approach to guiding future sustainable development patterns of activity and land use in the Borough. The hierarchy clearly and appropriately identifies Brentwood, Shenfield, Hutton, Warley, Brook Street and Pilgrims Hatch as 'Category 1 - Main Towns'. Barwood Land and Estates (BLEL) has reviewed the Interim Sustainability Appraisal Report (SA)
that supports the Local Plan Site Allocations and has the following comments with respect to paragraphs 10.5.4 (page 44); 10.10.2 (page 52); and the Site Appraisal of BLEL's site and Honeypot Lane, Brentwood (022) on page 81. Paragraph 10.5.4 (page 44) BLEL note that the Honeypot Lane site is proposed for a reduced level of housing (200 dwellings compared to 250 dwellings) when comparing the current Site Allocations Plan with the previous 2016 draft Local Plan. BLEL are not aware of any site specific reason why there should be a reduction and have considers (based on extensive technical assessments and site masterplanning that the site should be allocated for up to 250 dwellings. The SA should therefore be updated and revised accordingly in this respect. BLEL agree with the SA at 10.5.4 that the Land at Honeypot Lane site is associated with an opportunity to support enhanced pedestrian links through St Faiths Country Park. The SA notes at 10.5.4 that the potential for noise and potentially air pollution on the Honeypot Lane site arising from the A12 road. BLEL considers that the site's design and specific technical measures respond to the context of the site, including proximity to the A12 road and that the emerging scheme design includes appropriate buffers and mitigations for noise and air pollution amenity accordingly. The SA text should therefore be updated accordingly in this respect. A small watercourse running through the Honeypot Lane site is noted in the SA at 10.5.4 and the text highlights this as an example of the factors that will need to be taken into account in developing the site. BLEL has undertaken extensive technical analysis including physical surveys and assessments of the site and can confirm that site and surrounding area physical characteristics have been taken fully into account in concluding that the site can deliver up to 250 dwellings. Paragraph 10.10.2 (page 52) Paragraph 10.10.2 of the SA Interim Report identifies a lower level of housing delivery at Land at Honeypot Lane (and other Green Belt sites in Brentwood) as potentially having a lower landscape effect than earlier proposals and also potential for more green space on the site. BLEL's conclusion, following extensive technical analysis including landscape and visual impact assessment work is that Land at Honeypot Lane can deliver more than the 200 dwellings set out in the Site Allocations Plan and it can do so without adverse landscape effects. The site can achieve this while supporting levels of new amenity and green infrastructure to high degree. Honeypot Lane can therefore deliver more housing than the current version of the Plan identifies and can do so without adverse landscape effects given sensitive site design and the effective use of the site's natural topography and natural boundary vegetation as appropriate. Honeypot Lane Site Appraisal (page 81) BLEL note that the SA Interim Report has provided a high level sustainability appraisal of the Honeypot Lane site (page 81). BLEL concur with the analysis and note that the Site performs well in relation the analytical criterion. BLEL notes that the SA site assessment criteria covering issues such as access to primary and secondary schools and GP's surgeries is based on existing local provision and does not consider the potential future provision arising from new development as the Local Plan is implemented. I.e. the SA site assessment does not consider the potential for an enhanced level of site sustainability where development has supported the provision of new or expanded facilities. It is also important, in BLEL's view that that the SA site assessments consider factors such as the quality or capacity of facilities and services as well as a site's distance from such facilities. Quality and capacity are equally important sustainability factors. The Red Amber Green (RAG) scoring system used for the SA's site sustainability appraisals has no green scores in relation to a number of criteria. For example, Air Quality Management Areas and proximity to SSSI designations. This means that all sites are either scored red or amber for such criteria. Similarly, the distance from a Local Nature Reserve criteria is scored as either Red or Green (there is no amber). The RAG scoring system is, in BLEL's view, helpful but rather confusing overall as it mixes two and three RAG scoring codes depending on the criterion in question. BLEL is of the view that the assessment criteria and RAG scoring should be used consistently in respect of each criteria in the next version of the Sustainability Appraisal of the Local Plan. Barwood Land and Estates (BLEL) support the Local Plan at paragraph 43 (page 19) concerning objectively assessed housing need. BLEL support the higher OAN figure (380 dpa) calculated in the latest version of the Strategic Housing Market Assessment, but consider it is realistic and appropriate to now plan on basis of the Government's standardised methodology as set out in the new consultation draft NPPF and in revisions to the NPPG. It is clear that Government intends to adopt the standardised methodology in future and the Local Plan should reflect this now. Therefore, the Plan should set out opportunities and sites to deliver the 454 dpa (+74 dpa over the OAN). This supports and emphasises the need for a choice and mix of sites to ensure delivery and focuses the Plan into ensuring release of sufficient brownfield land and Green Belt sites at sustainable locations in order to deliver. Barwood Land and Estates (BLEL) support paragraph 54 (page 22) of the Local Plan that is concerned with the supply of housing sites. BLEL agree that it is appropriate to review, test and evaluate (and discount where necessary) a wide range of housing sites through the HELAA process. The process undertaken has been thorough in identifying potential sites and in evidencing those selected for allocation in the Plan. The Vision (page 11) supports sustainable growth and makes best use of brownfield and greenfield
land. This represents a realistic approach to the need to release Green Belt land to fully support housing and economic delivery objectives of the Local Plan.

See attached.

See attached.

Within the documents there is no supporting detail for allocation 022. We are being asked to comment on a proposal with major impacts for local residents with an outline of what is proposed - limited detail. The site was originally rejected because it did not meet the spatial strategy. It, however, remains but no clarity is provided on how the proposal now meets the spatial strategy.
This development has obvious detrimental impacts on transport, amenities, schools. This proposed development is within the Green Belt. It would only be exceptional circumstances that development began in Green Belt land. It is totally unclear what these circumstances are. The site is also not the most obviously sustainable. Any scale of development will increase in care traffic as amenities are not close and there is limited pathways, no bus routes and over 25 minute walk to Brentwood station.

Object to
* Draft local plan preferred site allocations
* Sustainability appriasal
* Evidence base

see attached representations and appendices

Object to
* Draft local plan preferred site allocations
* Sustainability appriasal
* Evidence base

see attached representations and appendices

See attached.

See attached.

See attached.

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached representations made on behalf of S & J Padfield and Partners for Land at Codham Hall North. The representations consist of the following:
- Representation
- Consultation Form
- Green Belt Assessment
- Appendix A and Appendix B of the Green Belt Assessment

Please find attached representations made on behalf of S & J Padfield and Partners for Land at Codham Hall North. The representations consist of the following:
- Representation
- Consultation Form
- Green Belt Assessment
- Appendix A and Appendix B of the Green Belt Assessment

See attached.

See attached.

Please find attached a representation made on behalf of Countryside Properties for Land at Bayleys Mead, Hutton. The representations consist of the following:
- Representation
- Consultation Form
- Location Plan

Please find attached a representation made on behalf of Countryside Properties for Land at Bayleys Mead, Hutton. The representations consist of the following:
- Representation
- Consultation Form
- Location Plan

Please find attached a representation made on behalf of Countryside Properties for Land at Bayleys Mead, Hutton. The representations consist of the following:
- Representation
- Consultation Form
- Location Plan