The Regulation 18 Plan evidence base requires some further clarification in respect of its assessment of specialist elderly persons accommodation referred to paragraphs 46 - 50. The SHMA Part 2 at paragraphs 6.3 - 6.14 attempts to assess the level of need for specialist elderly persons accommodation within the plan period by using the Strategic Housing for Older People tool developed by the Housing Learning and Improvement Network. In our view, this is a reasonable tool for assessing the likely level of specialist housing requirements for elderly persons in general but because it is, as confirmed in paragraph 6.8 of the SHMA, driven by demographic changes and does not take into account peoples' aspirations it is likely to be less accurate in assessing the level of need for Care Homes in Use Class C2. Paragraph 6.14 of the SHMA Part 2 suggests a need for an additional 424 spaces over the next 20 years. The problem with this demographic only assessment approach is that it is likely to over-estimate the actual need because it fails to take into account the traditional desire of elderly people to avoid taking accommodation in an institutional care home and also fails to recognize the greater variety of specialist housing options now available which are designed to allow elderly people to maintain their independence for longer. The HAPPI Spectrum published by the Housing our Ageing Population: Panel for Innovation (HAPPI) identifies a range of options which are available as specialized housing where personal care and support can be arranged or provided within the development together with shared facilities and activities. These include sheltered retirement homes, very sheltered homes, extra care housing, retirement villages and close care facilities.
Paragraph 72 of the Regulation 18 Plan suggests the provision at DHGV of "two large [care] homes -204 beds in total". While the Promoters do not object to the principle of providing elderly persons accommodation on site - indeed it is welcomed as part of creating an inclusive community - before committing to policy a precise provision requirement for two large care homes it will be important to be clear about the level and type of need. Alternatively, our recommendation would be to maintain flexibility and include in policy a requirement to provide specialist accommodation for the ageing population. Such flexibility would allow the Promoters and the Council to assess properly the level and type of requirements at the time of application submission and appropriately integrate that housing with the community. If, on the other hand, further detailed assessment or clarification of need and accommodation type is gathered then inclusion into the allocation policy would be entirely acceptable.
The Promoters are currently assessing the ability of DHGV to accommodate specialist pitches for Gypsy and Traveller households. It is noted that in Fig 13 of the Regulation 18 Plan DHGV has been identified in Step 6 of a sequential testing exercise for consideration of a possible 30 (approx) pitches. We are not yet convinced by the available evidence that sufficient need has been identified to justify the accommodation of this number of pitches, or in the DHGV location. Firstly, the Gypsy and Traveller Accommodation Assessment (October 2017) identifies a need within the borough for only 12 additional pitches for Gypsy and Traveller households which meet the planning definition contained in the Planning Policy for Traveller Sites. There is no explanation of why the Plan seeks to identify accommodation of additional pitches for households which do not meet the planning definition. Secondly, the Promoters are not persuaded that DHGV is a suitable location for such a large concentration of pitches, particularly in view of the fact that the sequential test has identified other more suitable sites to meet the need.

Specialist Accommodation Needs and Supply - Registered Care

ECC acknowledges BBC is seeking to meet its identified needs for registered care provision, (424 spaces between 2013 and 2033) as identified in the SHMA. However ECC seeks clarification on the suitability of the proposed sites for the provision of specific registered care accommodation (424 spaces across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

ECC seeks careful consideration of locations of developments with specific allocations of homes for older people. Easy access to primary care services including GP, local facilities including pharmacists and shops and also public transport links are vital. This would also be applicable for permission given for conversions of buildings of previous use to residential care homes for older and vulnerable people.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required Gypsy and Traveller pitches, which are proposed on 3 of the 4 same large housing sites (see comments below).

In order to meet its statutory obligations as the provider of adult social care, control the costs of adult social care and improve the lives of residents, ECC is committed to influencing the provision of a range of housing options for the older population. Consequently, ECC is keen to support and enable older people to live independently.

At present a gap exists in the provision of Independent Living housing across Essex. There are not sufficient numbers of Independent Living units to relieve pressure for residential care placements. A target of 2,825 Independent Living units (available as rental or ownership units) has been set by ECC to be delivered by 2020 in the County. Not including units either in development or completed to date, there are 2,178 units remaining to be delivered across Essex. Within Brentwood, by 2020, 153 units are required; 26 units are already provided, which leaves 127 still to be provided by 2020.

A programme has been developed by ECC to increase the supply of Independent Living units across Essex. It is therefore recommended that reference to the ECC Independent Living programme and its role in housing delivery should be made in progressing the Plan.

Specialist Accommodation Needs and Supply - Gypsy & Traveller

ECC notes that BBC has been working in partnership with Essex local authorities, through jointly commissioning the Gypsy and Traveller Accommodation Assessment (GTAA) (2017) to provide a robust assessment of current and future need for Gypsy and Traveller and Travelling Showpeople families and has used this data to inform how it addresses this in its Draft Local Plan.

ECC acknowledges BBC is seeking to meet its identified needs (78 pitches between 2016 and 2033), as identified in the Brentwood GTAA Need Summary Report October 2017, and is seeking to follow a sequential approach to site identification. ECC recommends that reference should be made to the most up to date position which is from the Greater Essex GTAA for 2016-2033 which was endorsed by EPOA on 25th January 2018 and published in February 2018.

ECC also seeks clarification on the suitability of the proposed sites for the provision of specific Gypsy and Traveller accommodation (58 pitches across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required registered care facilities, which are proposed on three of the four same large housing sites (see ECC comments above).

ECC notes and welcomes reference to the GTAA recommendations for BBC to engage with other Essex authorities to establish whether there is a need for investment in more formal transit sites or emergency stopping places.

ECC recommends that BBC should reference the transit recommendations as set out in the published Greater Essex GTAA (2018), which recognises and seeks to address the strategic cross boundary matters at a larger 'Greater Essex' level, incorporating data from local authorities; the Essex Countywide Traveller Unit (ECTU) and other sources. There are a range of site options available to address enforcement and unauthorised encampment issues (ie not just Transit sites), but also emergency stopping places, temporary stop and stopping places and negotiated stopping places. There is a need for further investigation and analysis to provide a more robust appraisal of current and future transit needs, to be undertaken.

ECC recommends that as part of the Plan preparation process any policy provision and supporting text should be flexible enough to allow the outcomes of the further work to be incorporated.

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

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

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



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

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

I note that the objections raised in the original application for Change of Use of Land in the Metropolitan Green Belt remain unchanged (application ref 11/00683/FUL). I also draw attention to the fact that although the Planning Inspector's report (as referred to in APP/H1515/A/12/2173169) made a recommendation for the granting of temporary planning permission for a period of 3 years (subject to conditions), it also clearly states that "very special circumstances do not exist and a permanent permission is not justified" and would be "unacceptable" - a view upheld by the Secretary of State. These objections centred on inappropriate development in the Green Belt, impacting on the openness and purposes of the Green Belt and the character and appearance of the markedly rural area; not constituting a sustainable form of development; and the effect on Curtis Mill Green SSSI. It is understood that subsequent revised Planning Policy (based on the consultation response of August 2015) was designed to strengthen Green Belt protection. Also, the intentional and apparent existing breach of planning control on the site should be a material consideration in granting permanent planning permission or 'regularisation'. Furthermore it is noted that several conditions of the temporary planning permission have been violated, including: 1. Frequent and improper burning of waste materials on the site - leading to potentially prejudicial health effects on the immediate neighbours; 2. Erection of additional structures within the site boundary; 3. Commercial activities (vehicle repair) - leading to substantial deleterious effects on the condition of the track providing access to the site; 4. Unauthorised clearing of land, adjacent to the SSSI and outside of the agreed boundary of the site. In summary, I object to the proposed regularisation of the site in question as it appears to be in contradiction of stated government policy, as well as the impact on the character and appearance of the locality (adjacent to, and with access via, the SSSI) and adverse effect on the residential amenity of the neighbours (improper disposal of waste by open fire, prejudicial health effects, deteriorating track condition, permanent visual impact of the development). However, in the event that the site is approved for regularisation, I would expect the original conditions as stated in the Planning Inspector's report to be met (e.g. with regard to formal drainage facilities) and that there is adequate enforcement of permitted activities on the site, in the interests of maintaining good community relations.

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.

Section 12 - Dunton Hills Garden Village (DHGV) "evidence base is increasing including masterplan work" and
Section 64 e - "Developing a comprehensive masterplan for the new garden village at Dunton Hills, to engrain the core garden village design principles"
* how can an objective view be made on site selection before this masterplan detail is presented and made available to the public?

Section 26 - "Commited to growth . . . but in a way that maintains and enhances unique local character"
* wheras DHGV will completely destroy the unique local character of Dunton Village which is right on its border.

Section 28 - Strategic Objectives - S04 "A new well connected community at Dunton Hills"
* Please see fuller comments below - but how can it be well connected when it isolated from the rest of Brentwood, isolated from the railway and bound by already heavily congested roads

Figure 9 - page 26/27 - Proposed Housing Led Allocations
* DHGV is not included in the Green Belt total, effectively masking the extent of Green Belt land being developed
* Out of 381.25 Hectares of land allocated, 342.65 (257 + 85.65) is green belt. That's a staggering 89.8% Green belt land, which does not deliver a sustainable, ecological allocation plan.

Section 67 - Total dwellings
* Figure 9 shows a total allocated dwelling number of 6,154 houses. DHGV makes up 40% of this total. However, section 67 states this figure could increase to 9080 with accelerated growth within DHGV to deliver 3500 dwellings.
* This will add a huge burden to the surrounding infrastructure. With an estimated 9000 residents (section 105), a large level of investment will need to be made regarding roads, health, schools, shopping and work provisions. A sticking plaster approach will just not work given that many of these areas are already stretched to within breaking point.
* It just seems that not enough effort has been put into dispersing these houses across the borough. It is just lazy of the council to allocate it 1) on green belt land and 2) land from a single land owner - just to make the allocation process easier

Figure 13 - page 33 - Provision of traveller sites
* Travellers do not contribute funding in the same way that the general public do through council tax, national insurance etc. and therefore it does not seem appropriate to creating infrastructure specifically for one minority group
* That said, if traveller provisions do need to be created, surely it is better for all concerned to allocate them away from large communities and therefore the 30 allocations at DHGV would seem wholly inappropriate in that regard

Figure 22 - page 57 - New Employment Site Allocations
* The largest proportion of new employment areas are extensions onto green belt land - again along the A127 corridor, further burdening the already gridlocked roadways. The A127 is already experiencing pollution levels above EU allowable levels.
* The erosion of Greenbelt along the A127 means that there is almost no division from the urban sprawl of London and Brentwood / Basildon meaning that there will no longer be any green belt

Our client, Martin Grant Homes, supports Brentwood Council's approach in planning to meet the full OAN within the Borough. However, there are the following concerns: Over-reliance on Dunton Hills Garden Village to provide 40% of the allocated housing growth; The lack of flexibility in the strategy to accommodate un-met need from neighbouring authorities; Limiting the housing requirement to just 380 dwellings per year prevents sustainable sites that are available now coming forward within the plan period and does not acknowledge the changes to calculating housing need using a standardised methodology. The current approach is limiting to sustainable development opportunities and may not deliver the full extent of the housing provision in the plan period. It is considered that by identifying more sites for modest development in sustainable locations such as our client's site would be an appropriate solution to meeting the identified housing needs across the Borough and would not lead to the loss of large areas of the Green Belt in concentrated locations. The inclusion of sites such as land at Heron Court in Herongate will provide Brentwood Borough with a range of sites that enable a flexible approach to housing delivery and ensure that land comes forward within the plan period. Brentwood's current strategy to largely rely on the Dunton Hills Garden Suburb and windfall sites could result in issues with delivery which prevent the Borough meeting its identified housing need and result in the Borough continuing to be unable to demonstrate a five-year supply of deliverable housing sites. Please see attached representations for more detailed information.

When the East of England New Homes policy was introduced to Brentwood residents we were asked to comment on it. We were informed how many new homes were being proposed for Brentwood and asked what number we thought would be appropriate. My pragmatic, and I believe fair, answer was as many as brown fill sites in our area would accommodate. Since then my preference for building on brown fill and other sites, situated in our town, has reversed for two reasons - the first, a negative one, the second, a positive. Four or five years ago, following the development of the Highwood and Little Highwood hospital sites, one of the two single handed G.P.s working on there retired leaving 1500 patients without a doctor. I was at this time, and continue to be, a member of the patient participation group at my doctors' practice in the town. I learnt that my practice had offered to take over the practice on the Highwood Hospital site provided it was not out of pocket, ie the PPG (as it was at the time) would pay for the rent and upkeep of the surgery and for staffing it, as another G.P. would have to be employed - the PPG refused to accept the costs insisting that the patients could be absorbed onto the lists of local G.P.s. Our practice manager contacted our P.P.G. members, as a matter of urgency, to ask us if we should close our list to new patients, as the other local practices had. With there being a two to three week wait for a non-urgent G.P. appointment, even then, the answer was a resounding yes. It was only then, when 1500 patients were bereft of a G.P., that the P.P.G. agreed to the terms offered by my practice. I find this attitude to the provision of an important local service alarming and I am fearful for the wellbeing of the residents of Brentwood if new homes are built within close proximity of the town, whether it be on brown fill sites or other areas, as currently proposed. It goes without saying that this could be the tip of the iceberg as other important services such as schools could suffer from local overdevelopment. This makes no mention of the obvious increase in traffic that we have seen and will have to endure further, if these developments go ahead and because of the stop/start nature of the vehicles in these traffic jams, the increase in pollution and resulting health problems. On a positive note, I was very impressed with the plans for the Dunton Garden Village. With its integrated infrastructure this will offer tremendous advantages, in so many ways, over developing the town and its nearby environs. One small example of this would be the provision of locality shops and I believe it is interesting to note that, despite being enlarged, the Sainsburys car park still gets very full and can be quite a dangerous place both for drivers and pedestrians. I strongly believe that a number of satellite developments, such as Dunton Garden Village, will offer the best solution to the need for new homes in our area despite these settlements having to be developed on green belt land which I understand some of the proposed sites are anyway. I am also confident that fewer people would be affected by this type of development as these sites will be in less populated areas and, because of their self reliance, there would be less traffic coming into Brentwood which would be a big benefit for so many residents living in and close to the town. There will no doubt be a great deal of "nimbyism" over any proposal, but for my part my wife and I have often discussed our indifference to the field between where we live in Viking Way and the A12 being built on as, on the one hand we would lose some open land, which I believe was at one time designated as green belt, but buildings on it would shelter us from some of the road noise from the A12 - this has been measured and found to be above an acceptable level but in these times of austerity nothing has been done about it. On the subject though, it does strike me as being a strange choice for development as nine or ten years ago, when Brentwood Council was charged with finding sites for travellers (I believe the scheme was dropped following a change of government), the field in question was under consideration for such a site but it was removed from the list because it was considered to be unsafe for travellers to live there as it represented a health hazard owing to the levels of pollution from the A12. To summarise, the planners could follow what seems to be happening at present and develop the area in and around Brentwood town even further, squeezing out a large number of green areas, creating an infrastructure pushed beyond its capacity and creating traffic chaos along with the accompanying health risks from pollution. The alternative would be radical and would represent "thinking outside the box". It would upset fewer residents, in total, and give rise to less of the problems highlighted above, giving rise to all residents finding Brentwood a more pleasant place to live compared with the alternative. I firmly believe developing more sites like the Dunton Garden Village would be the best choice for Brentwood and, more importantly, its residents. I guess it comes down to the quality of life that it is considered appropriate for Brentwood residents, old and new. This could be maintained for those currently living in Brentwood and a really good quality of life could be afforded to the newcomers. Alternatively, it could be diminished for all of us.

I am a resident of the Village of Blackmore and object to the proposed Local Development Plan for the following reasons. The plan does little to resolve the boroughs long standing infrastructure problems especially in terms of addressing public transport links to the outlying rural communities. It also appears to have no consideration for the problems facing the outlying rural communities other than use them as sites for affordable housing, that cannot be guaranteed, other than to meet the quota for new housing. As a resident of Blackmore I am shocked that no mention of additional housing was made in the proposal from 2009 but find that in the new document the village has been earmarked as a proposed site for an additional 90 dwellings to be built in two fields on the periphery of the village. I would agree that some affordable housing is required in the village however this density of housing would be unsustainable, cannot be of benefit to the community, will add to the congestion already suffered by the village and will exasperate the chronic parking issues that already exist. I note from the consultation document that the Blackmore site Ref:076 which is earmarked for 40 additional dwellings notes that road access is poor and that the area suffers from surface water flooding. There is no mention of how these issues will be resolved. The flood and SuDs plans displayed at the community consultation event at Tipps Cross had no information for Blackmore which was left blank. Local Authority representatives at the event had little knowledge of the area and were vague when answering questions relating to Blackmore. Areas of hedging towards the top of Red Rose lane show a high mix of species indicating ancient hedgerow of high bio-diversity and a valuable wildlife corridor which will be lost if road widening and development takes place. The section of the proposed LDP, titled Managing Growth, lists in its strategies S03 - Support the sustainable growth of our existing larger villages to provide improved housing choice and protect services and facilities. S05 - Manage development growth to that capable of being accommodated by existing or proposed infrastructure, services and facilities. In the case of development proposal in Blackmore neither of these statements can be supported as exiting infrastructure is insufficient for current needs. The proposed development is not sustainable growth but is increasing the village housing stock by 28.6%, putting additional pressure on existing services and facilities which have been reduced over recent years and cannot be accommodated by existing infrastructure which is already failing. Under the heading Sustainable Communities SO6 - Plan for housing that meets the needs of the Borough's population and contributes creating inclusive, balanced, sustainable communities. Again an increase in housing as proposed for Blackmore is not helping to create a sustainable community but is doing the opposite under current circumstances. Under the heading Spatial Strategy the proposed LDP states 48 - 49 Brentwood has a reasonably modest Gypsy and Traveller need requirement for the period 2016-2033 I would point out that Blackmore has a large illegal travellers site near the proposed development site which has put pressure on existing infrastructure and facilities especially the village school. This site has not been dealt with by the local authority and has been in existence for over 10 years. This fact has been ignore in the LDP document. 66 : The proposed housing allocations for the more sustainable villages are limited in size and scale but will at a local level provide a valuable role in enhancing the housing mix, introducing new affordable housing and help support local shops and services. As smaller greenfield sites they are likely to be attractive to smaller builders and have the possibility of being built out relatively quickly to support housing delivery within the early stages of the Plan being adopted. As with all current Green Belt sites, the Council is keen to ensure that edges of the sites are defendable and the revised village envelopes will be retained for the lifespan of the local plan and beyond. There is no evidence that the statement above will be met by the proposed development. The loss of amenities, poor public transport links and bad planning development decisions within the village boundary have seen Blackmore develop the characteristics of a dormitory village. Adding an additional 90 houses in two fields on the village boundary is not small scale development especially when considering maximum housing density. I also do not believe that affordable housing can be guaranteed under the current NPPF and development regulations especially as the NPPF is under review and will most likely favour housing development. Under the current system developers can state a lack of viability for building affordable housing, providing SuDs and improving infrastructure. I would also suggest that other development in the future is a possibility extending the village edge if the current government develops its ideas on house building. The document states that Blackmore Village Primary School has capacity for more children but does not show how many children from the village cannot go to their local school as places are taken by children from outside the village. As an ex-governor of the school I'm astonished that this argument has even been made. Under the heading Transport and Movement SO21 : Improve public transport infrastructure and ensure development sites are well connected to bus and/or rail connections. SO22 : Improve cycling and walking facilities across the Borough and establish a grid or network of green transport corridors. SO23 : Secure the delivery of new infrastructure to support a lower carbon future including electric vehicles charging points and other measures. No solid evidence in the document is presented into how the existing village infrastructure can be improved. In terms of public transport links the bus service in recent years has been reduced and a previous service provider stopped running buses as it was considered unprofitable due to Blackmores subsidised elderly and school aged population. The village is reliant on the car hence the villages current parking and congestion issues. I would also state that the bridge leading from Chelmsford Road has been weakened by heavy vehicle traffic. You also only have to visit Blackmore at weekends to know it is a popular hub for the South Easts cyclist and the roads are congested with parked cars and clogged by the cyclists riding in large groups sometimes 5 to 6 abreast. Much is made in the planning system of enhancing existing character, ensuring tranquillity in rural areas and in the LDP document of the need to facilitate and support stronger and vibrant town and village centres. How will this be applicable to Blackmore where the village centre is in a conservation area. Surely development and additional works traffic can only be detrimental to the fragility of this space. The village infrastructure which has had little investment in my XX years living in Blackmore is already insufficient, we have poor public transport, continuous flooding on the Chelmsford Road and in Red Rose Lane next to the proposed development site. The village suffers from regular power cuts, roads and public walkways are often in a state of disrepair and there are regular questions about sewage capacity. To add another 90 homes with the possibility of 200 additional vehicles shows a distinct ignorance of the problems facing our rural communities. It is also fair to point out the degrading of amenities in the village such as the loss of library services, a dedicated post office and reduced transport services have reduced the character and community cohesion of the village having an especially detrimental effect on elderly residents. This is far from the vibrant and sustainable picture painted in the LDP document which does little to address the issue. It is also worth pointing out that a new development of semi-detached housing was recently built in Nine Ashes, there is also an ongoing development at the site of the Norton Heath Equestrian Centre both of which add to existing infrastructure issues. Bad planning decisions within the village itself have allowed large sites previously occupied by single bungalows to be developed as large individual houses rather than encouraging the building of smaller dwellings. This has not only reduced the housing stock in the village but has also reduced the number of dwellings available for elderly residents that the building of affordable housing is supposedly trying to resolve. Although the plan states it guarantees the building of affordable housing for the village of Blackmore due to government policy there is no guarantee that affordable housing will actually be built. Due to the way developers use viability assessments and the poor use of available land in terms of housing density and vehicular parking I do not believe that any guarantee can be made that affordable homes and a workable SuDs system will be provided on the proposed sites. Generally I feel the proposed LDP process started as being well intentioned and agree that there is an obvious need for affordable housing. Unfortunately the current proposals appear to attempt to burden the outlying rural villages with large increases in housing showing a lack of research into current community needs, existing infrastructure, flood risk and sustainable capacity. The number of proposed houses is, I believe unsustainable and without guarantee and appears to be a desperate attempt to meet housing quotas for political expediency.

Page 21 para 48: why is there a need to accommodate these people? Can you confirm how the Council tax payment is controlled. Indeed do they pay Council tax?

Page 49 para 105: this is too vague. GP facilities are massively over stretched. I have had experience of waiting over 3 weeks for an appointment.

General: I cannot see any reference to roads or trains. The A127 and surrounding roads are choked with traffic and must have a dramatic impact on pollution. C2C trains are packed during commuting hours. What engagement have you had with C2C?

See attached.

Thank you for inviting Rochford District Council to make comments on the Brentwood Borough Council Preferred Site Allocations consultation. Please find the Council's comments below. Could you please confirm receipt and acceptance of these comments in due course. Strategic Objectives The Council supports Brentwood's identified strategic objectives, in principle, however would like to highlight the need to ensure that the impacts of the planned growth and wider strategy on other authorities in South Essex, including Rochford District, are considered in detail. It is expected that the collaborative work currently being undertaken at the sub-regional level, which includes both Rochford District Council and Brentwood Borough Council, will help to facilitate these cross-boundary considerations. Approach to Housing and Objectively Assessed Need Rochford District Council supports, in principle, Brentwood's approach to meeting its housing needs, but would like to raise the need to consider the impact of its proposed housing allocations within the wider context of South Essex. This is particularly pertinent in relation to the Dunton Hills garden village which could potentially be sited close to other proposed housing locations in the neighbouring authorities of Basildon and Thurrock. Rochford District Council would advocate a joined up approach to fully consider the potential impacts of this growth, and in particular, would like to highlight the need for Brentwood Borough Council to consider the impacts of this growth on the authorities and communities beyond it boundaries, including Rochford District. Approach to Gypsy and Traveller Accommodation Rochford District Council supports Brentwood's approach to meeting its Gypsy and Traveller accommodation needs in full and continues to support the close working of the Essex Planning Officer's Association towards effective planning for Gypsy and Traveller provision into the future across Essex. Approach to Infrastructure Planning Rochford District Council raises no objection to Brentwood's approach to infrastructure planning at this time but would like to highlight the need to carefully consider the impact of planned growth on the A127, A130 and A13, which all form part of the strategic road network for South Essex. The Council highlights the need to consider the impact of developments on these roads, as well as the wider strategic network, and would support further exploration of the mitigation and improvement measures needed to make such growth sustainable. The impact of the Lower Thames Crossing proposals should also be considered. Approach to Economic Development and Jobs Rochford District Council raises no objection to Brentwood's approach to economic development and growth but would highlight the need to carefully consider the impact of the planned growth on neighbouring authorities and the strategic highway network. Again, the Council would support further exploration of the mitigation and improvement measures needed to make such growth sustainable. Approach to Duty to Co-operate Rochford District Council raises no objection to Brentwood's fulfilment of the Duty to Co-operate, but would highlight the need to continue to work collaboratively with all other South Essex authorities on cross-boundary strategic planning matters, further to the intentions of the South Essex 2050 Memorandum of Understanding.

See attached.

See attached.

See attached.

Chelmsford City Council (CCC) welcomes the opportunity to comment on Brentwood's Draft Local Plan Preferred Site Allocations to help influence the emerging document and monitor the key cross-boundary and strategic issues that affect CCC's administrative area. CCC welcomes Brentwood Borough Council's decision to adopt a higher OAHN of 380dpa in light of the latest evidence and in anticipation of MHCLG introducing a standardised approach to calculating OAHN using the 2016 household projections when published. It is noted that the provision of Gypsy and Traveller Accommodation has changed in line with the National Planning Policy for Traveller Sites (PPTS) and the Essex wide GTAA undertaken in 2017. On transit sites, CCC acknowledges the GTAA's recommendations to engage, through the Duty to Cooperate, with other Essex authorities in the future to review the need for transit sites. Further work on this is also being undertaken by Essex County Council to consider the need for these sites across Essex as a whole. CCC supports the increase in employment land allocations to meet Brentwood Borough Council's overall forecasted employments needs. Overall CCC supports Brentwood Borough Council's proposed approach to housing and employment allocations which are unlikely to have any obvious adverse cross-boundary impacts on Chelmsford. However, it is crucial that the allocations are supported by the appropriate infrastructure, in particular highway and transportation schemes due to Brentwood's location on the A12/Greater Anglia road and rail corridor. It is noted that the Draft Infrastructure Delivery Plan is a working document and transport requirements are yet to be specified. CCC expects that when the emerging Plan has progressed to Regulation 19 (expected late summer/early autumn 2018) the IDP will have been updated accordingly.