We need the thousands of local high quality jobs that Ford Head office supports. Giving planning permission for this site increases the probability that Ford will relocate away from Brentwood. this site should be kept for employment purposes.

Concerns over wildlife protection are my main concerns with this site.

In the light of Brexit, giving planning permission for houses will make it even easier for Ford to relocate to Germany. The financila knock on in Brentwood, with many jobs, will be significant. The Council should be keep to encourage good local employment.

The existing Ford building must be retained

As this site was used as a military barracks from 1742 until laterly the Essex Regiment left in 1959 and the land was developed by Fords is there not an opportunity for an archealogical examination of this land which is of significant military importance to this area and Essex as a whole especially as this year is 100 years after the end of the Great War.

Is this not from where the name "Eagle Way" comes

Housing density of 43.2 per HA
These are all large houses and will severrly impact schools and doctors in the a\ea

Whilst not objecting to possible redevelopment on the plot south of Eagle way, I consider the projected number of dwellings too high.
The plot north of Eagle Way, should continue to be used as a carpark but for business commuters working at the Warley Hill Business Park. This could potentially generate revenue for BBC

Sites of this nature are required for business and employment opportunities rather than housing.

Highways & Transportation Comment -
Development on these sites will need to be viewed from a holistic perspective to ensure that they contribute to a pool of funding to provide an enhanced level of bus service to serve the 473 homes planned. It will also be important to ensure that the design layout of the sites facilitates sustainable access, ideally with bus gates or other interventions designed to maximise such access whilst giving these modes a journey time advantage.

Economic Comment -
Significant concern about the potential loss of a key local employer (Ford) if site is lost to residential.
Brentwood has already lost BNY Mellon, EMoov in the last year.

I have just viewed the above Local plan and wish to raise some grave concerns and objections to some of the proposals.
These are:
1) The plan proposes in excess of 500 hundred homes in the Warley area, (Fords, Council Depot, Pastoral Way) As a resident of this area I can say with some authority that the roads a facilities in this area are under strain now, they would be overwhelmed and unable to cope with such an increase.
500 homes would have at least 1 car each, the expectation that people will use public transport is just rubbish, it doesn't happen in the real world.
As a result the traffic, pollution and noise pollution in the area will rise. Its gridlock currently in The Drive and Warley Hill in the morning and evenings, as it is in Chindits lane when the kids get driven to school.
The doctors surgery in Pastoral Way (Beechwood) never has any free appointments when you need one now and patients have to wait for days.
This is the situation currently, imagine what it will be like with 500 additional patients (that is presuming only 1 person lives in each dwelling which is unlikely to say the least).
2) There is a proposal to build on Brentwood Station car park!! Ludicrous!! !where do you think anyone commuting will park? In the surrounding streets? only to be joined by all the additional traffic from the 500 houses!! This proposal also needs a serious re think as well.
3) I notice you have proposal to build on nearly all the town centre car parks, bar Sainsbury's and the Multi-storey in Coptfield road. Where do you expect people to park when they go shopping? I think this will result in the death of the shopping centre. The shop keepers suffered when the High Street was re paved some years ago because people couldn't cross the road to get to them and wouldn't walk the 50 yards or so to where they could cross.
I believe you will see a demise and shoppers will go elsewhere to places like Lakeside and Bluewater where they can park with ease.
I would therefore like to register my very strong objections to these proposals.

I have just viewed the above Local plan and wish to raise some grave concerns and objections to some of the proposals.
These are:
1) The plan proposes in excess of 500 hundred homes in the Warley area, (Fords, Council Depot, Pastoral Way) As a resident of this area I can say with some authority that the roads a facilities in this area are under strain now, they would be overwhelmed and unable to cope with such an increase.
500 homes would have at least 1 car each, the expectation that people will use public transport is just rubbish, it doesn't happen in the real world.
As a result the traffic, pollution and noise pollution in the area will rise. Its gridlock currently in The Drive and Warley Hill in the morning and evenings, as it is in Chindits lane when the kids get driven to school.
The doctors surgery in Pastoral Way (Beechwood) never has any free appointments when you need one now and patients have to wait for days.
This is the situation currently, imagine what it will be like with 500 additional patients (that is presuming only 1 person lives in each dwelling which is unlikely to say the least).
2) There is a proposal to build on Brentwood Station car park!! Ludicrous!! !where do you think anyone commuting will park? In the surrounding streets? only to be joined by all the additional traffic from the 500 houses!! This proposal also needs a serious re think as well.
3) I notice you have proposal to build on nearly all the town centre car parks, bar Sainsbury's and the Multi-storey in Coptfield road. Where do you expect people to park when they go shopping? I think this will result in the death of the shopping centre. The shop keepers suffered when the High Street was re paved some years ago because people couldn't cross the road to get to them and wouldn't walk the 50 yards or so to where they could cross.
I believe you will see a demise and shoppers will go elsewhere to places like Lakeside and Bluewater where they can park with ease.
I would therefore like to register my very strong objections to these proposals.

The Woodland Trust appreciates the opportunity to comment on the Brentwood Draft Local Plan Preferred Site Allocations consultation.
As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved. We own over 1,250 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.
Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost. As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.
The Trust is concerned about a number of site allocations included in the Brentwood Draft Local Plan as they could lead to the damage and loss of ancient woodland.
Planning policy
National Planning Policy Framework (NPPF) paragraph 118 states that "planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss."
The draft revised National Planning Policy Framework, published on 5th March 2018, further outlines the Government's commitment to improving protection for ancient woodland through the planning system. It states that "development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons and a suitable mitigation strategy exists." This wording is a clear recognition from the Government of ancient woodland's importance and better need for protection.
Natural England's standing advice for Ancient Woodland and Veteran Trees1 states:
"Trees and woodland classed as 'ancient' or 'veteran' are irreplaceable. Ancient woodland takes hundreds of years to establish and is considered important for its wildlife, soils, recreation, cultural value, history and contribution to landscapes."
Impacts on ancient woodland
Approximately one quarter of priority UK BAP species are associated with woodland habitats. Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.
Development in ancient woodland can lead to long-term changes in species composition, particularly ground flora and sensitive fauna, i.e. nesting birds, mammals and reptiles. Majorly adverse impacts would occur as a result of the removal of large areas of woodland, much of which contains high quality, valuable trees, to make way for the construction of this proposal.
When land use is changed to a more intensive use such as in this situation plant and animal populations are exposed to environmental impacts from outside of the woodland. In particular, the habitats will become more vulnerable to the outside influences, or edge effects, that result from the adjacent land's change of use. These detrimental edge effects can result in changes to the environmental conditions within the woodland and consequently affecting the wood's stable conditions. Detrimental edge effects have been shown to penetrate woodland causing changes in ancient woodland characteristics that extend up to three times the canopy height in from the forest edges.
Creation of new areas of woodland or buffer zones around semi-natural habitats, and more particularly ancient woodland, will help to reduce and ameliorate the impact of damaging edge effects, serving to improve their sustainability. The size of the buffer is dependent on the intensity of land use in the intervening matrix between ancient woods.
Natural England's standing advice for Ancient Woodland and Veteran Trees states:

"Development can affect ancient woodland and veteran trees, and the wildlife they support, when it takes place on the site, or nearby. You can assess the potential impacts using this assessment guide and use this to help you with planning decisions.
(https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences).
Direct impacts of development on ancient woodland or veteran trees include:
* damaging or destroying all or part of them (including their soils, ground flora, or fungi)
* damaging roots and understorey (all the vegetation under the taller trees)
* damaging or compacting soil around the tree roots
* polluting the ground around them
* changing the water table or drainage of woodland or individual trees
* damaging archaeological features or heritage assets
Nearby development can also have an indirect impact on ancient woodland or veteran trees and the species they support. These can include:
* breaking up or destroying connections between woodlands and veteran trees
* reducing the amount of seminatural habitats next to ancient woodland
* increasing the amount of pollution, including dust
* increasing disturbance to wildlife from additional traffic and visitors
* increasing light pollution
* increasing damaging activities like flytipping and the impact of domestic pets
* changing the landscape character of the area"
Development must be kept as far as possible from ancient woodland, with a buffer area maintained between the ancient woodland and any development boundary. An appropriate buffer area will depend on the local circumstances and Natural England recommend "leaving an appropriate buffer zone of semi-natural habitat between the development and the ancient woodland (depending on the size of development, a minimum buffer should be at least 15 metres)."
The size of a number of the site allocations suggests that large scale development could potentially take place. The minimum 15m buffer recommendation to all development is not effective in ensuring that ancient woodland within and/or adjacent to site allocations is not affected by potential future development. Buffers should be constructed on a case-by-case basis rather than a 'one size fits all' approach.
Conclusion
The Trust is concerned about the potentially adverse impacts that the proposed site allocations will have in relation to areas of ancient woodland within and/or adjacent to site allocations. Ancient woodland should not be included in areas that are allocated for development, whether for residential, leisure or community purposes as this leaves them open to the impacts of development.
The Woodland Trust objects to the inclusion of the below site allocations in the Brentford Draft Local Plan as they are likely to cause damage and/or loss to areas of ancient woodland within or adjacent to their boundaries. For this reason we believe the sites in the table below are unsound and should not be taken forward. We will maintain our objection until there is a commitment to either avoiding ancient woodland or providing suitable buffers to development. Secondary woodland should also be retained to ensure that ecological networks are maintained and enhanced.
We hope you find our comments to be of use to you. The Woodland Trust is happy to provide any additional information or support regarding the protection of ancient woodland. If you require any further information regarding points raised within this document, then please do not hesitate to contact us.

081 Council Depot,
The Drive,
Warley
Brentwood
CM13 3BH Brentwood Housing - 2.98 ha
Masterplan opportunities (potential for mixed use) when considered along with adjoining sites 117A and 117B. Adjacent to AW on eastern boundary Type - ARW
Name - Barrack Wood aka Harts/Kents Woods
Size - 37.711702 ha
Grid ref - TQ596917

117A & 117B Ford Offices,
Eagle Way,
Warley
Brentwood
CM13 3BW Brentwood Housing and employment - 8.09 ha
Masterplan opportunities (potential for mixed use) when considered along with adjoining sites 117A and 117B.
AW on eastern boundary. Approx. 12m buffer of woodland (non-AW). Type - ARW
Name - Harts/Kents Woods
Size - 37.711702 ha
Grid ref - TQ596917

083 Land west of Warley Hill,
Pastoral Way
Warley
CM14 5HJ Brentwood Housing - 2.21 ha AW 37m to West of site Type - ASNW
Name - Clements Wood
Size - 1.490825 ha
Grid ref - TQ588921

263 Land east of Chelmsford Road,
Shenfield Brentwood Housing - 9.85 ha
Opportunity to create a masterplan along with adjoining proposed allocations (site refs: 158, 034, 087, 235 and 276). Adjacent to AW on south eastern boundary (length approx. 292m) Type - ASNW
Name - Arnold's Wood
Size - 1.56641 ha
Grid ref - TQ621961

034, 087, 235 and 276 Officer's Meadow,
Land off Alexander Lane,
Shenfield Brentwood Housing - 24.44 ha
Opportunity to create a masterplan along with adjoining proposed allocations (site refs: 158 and 263) Contains AW on eastern side of the site. Whole of this part of Arnold's Wood included to provide contiguous site with Site ref. 263 Type - ASNW
Name - Arnold's Wood
Size - 1.56641 ha
Grid ref - TQ621961

200 Dunton Hills Garden Village Brentwood Mixed Use - New Garden Village community including housing, employment, specialist accommodation, local shops and supporting infrastructure. 257 ha Contains AW Type - ASNW
Name - None
Size - 3.084541 ha
Grid ref - TQ645894


101A Brentwood Enterprise Park (Former Brentwood Employment - 35.47 ha Adjacent to AW on Type - ASNW
Name - Hobbs Hole

As a Brook Road homeowner for over 20 years, I strongly object to a number of the planning "options" submitted and have itemised above those that are most unacceptable to me.

Brentwood is regularly grid-locked, particularly during rush hour, and always at weekends because of our growing population, the town's popularity as a celebrity haunt and the close proximity to the M25, which is regularly closed with traffic being diverted through the High Street.

The small residential roads are often used as cut-throughs, and speed limits and general safety ignored by road users - Brook Road is a prime example being adjacent to London Road.

Regarding Honeypot Lane - the location is only accessible by existing residential areas with restricted arteries to the town (Weald Road including width restriction). Trying to turn right from Weald Road onto London Road is already a lengthy and dangerous turn.

To remove parking spaces when it is already difficult to park around the town is short-sighted.

To consider building most or all the required housing on one site (Honeypot Lane and Ford, Warley) will lead to even greater bottlenecks in one part of the town.

The charm of Brentwood is that, despite it being a busy town, within a few minutes (traffic permitting!), you can be driving past allotments, beehives (far end of Honeypot Lane) and the country park.

South Weald is a small hamlet, which does not have the infrastructure of roads or school places to cope with 200 homes being built a mile down the road.

Brentwood doesn't have the infrastructure either.

I am writing regarding this and am unable to copy your form to this email - perhaps I am too late for commenting.
My comments are one of alarm at the number of sites you have noted in the plan. Hopefully not all will come to pass. It seems to me that a lot of these proposed sites take no account of the extra traffic and therefore congestion which would be caused. The developments at Warley, Fords, Mascalls Lane would cause severe pressure on Mascalls Lane itself - it already suffers from greatly increased traffic from the Warley Hospital developments. Most of the town centre proposals would also cause congestion and if car parks are developed where is parking to be provided for those residents and visitors.
While I appreciate that there is a need for housing in this country due to increases in the population I feel it is necessary that it is done so as not to destroy the country and the quality of life most of us are lucky to have. London and the south east always seem to bear to brunt of mass building you only have to look at London on leaving Liverpool Street for that!!
Some the proposed sites seem to be taking greenfield or woods into the development area which is unnecessary. We have many brownfield sites which should be used first. I understand the Campaign to Protect Rural England has listed sites throughout the country which could provide about 1 million homes. Will there be more roads to accommodate extra traffic, more schools, healthcare services, buses and trains and, perhaps, more importantly - jobs? I note some of the sites take industrial areas into being developed for homes. I know a great deal is done on the internet but there will surely be a need for other types of work.
While not agreeing with a lot in the plan it is good that a plan is being prepared as I saw a programme which showed what happens if local councils do not have one or update one. We are lucky to live in Brentwood which still has country parks and green areas - at the moment - but I think most people would be unhappy to see it turned into a Romford and Ilford which I think looks like a mini-Manhattan!
I note that the Council Office and the former Police Station sites are not mentioned - are these already decided? The land in Ingrave Road which was formerly Warwick Wright has been standing empty for years.
I do not think this huge planned development of 300,000 homes a year is realistic bearing in mind the infrastructure that has to go with it. Also will it really end bearing in mind the figures suggesting 200,000+ (net) people are migrating to the UK every year!

I am making comments on the plan and note the suggestion that Fords Warley and the Eagle and Child pub will both close as part of this plan. Clearly the closure of Fords is a massive blow to the area and I do hope they are relocating.
I note the plan for business premises. The problem in this area are that the requirements for business premises are not met by the current stock of properties available. As a small office style business which needs to be near to transport links the absence of suitable accommodation has caused us to relocate to South Quays. There appears to be a view that our of area business sites are the most useful. They are not for the current type of micro and SME that is being created.
My other concerns are about the road links and car parking as a consequence of these plans. I would urge the development first of a major multi story car parkin Brentwood before the other projects run. At present it is difficult to park and any change to the level of car parking to residents is likely to have a negative impact on the High Street and surrounding areas.
The Priests Lane development has real problems in terms of road usage. The minor roads that would be the linkage are already overused and are likely to be clogged. The impact on the limited car parking in Shenfield will also need to be considered. To maximise the value of Crossrail there is a need for a multi story car parking Shenfield which should probably be on one of the Railway existing car parks. This will allow Shenfield to be the successful transport hub it needs to be. However you will also be aware of the problems with the roads around the station and main street area and this must be addressed as part of the plan. I would suggest that the multi story be built and then the main street parking bays be removed altogether.
To get buy in from the local population to this I would suggest that in the first stage the car park should be free to local residents and that a residents voucher can be obtained. However out of town users will need to pay which will subsidise the project.

I write on behalf of myself and my wife to register our serious concerns at the potential impact of the proposals embodied in the local plan. Before I begin, I should perhaps apologise if it turns out that I have based what follows on partial information, or on a misunderstanding of what is proposed. To some extent, I assume this must be the case, since in some areas (my first three bullet points below) the plan appears to be contradicting itself. I am assuming that the document of interest is the one headed 'Preferred Site Allocations 2018' - I have trawled through the website looking for other relevant information, and also in the hopes that there might actually be a shorter summary document, but have found neither. Regrettably I have struggled with this document because so much of it is given over to, what is for me, irrelevant minutiae relating to government policy; because different figures appear in different places; because it makes use of jargon and - my apologies - because the earlier portions are given over to meaningless platitudes. Anyway, assuming this is the correct document, I have a number of specific points : The introductory comments suggest state that 'People choose to live and work here because of the excellent transport links connecting us to London and the rest of the country, along with access to the surrounding countryside and green spaces' and also that 'A "borough of villages" will continue to be a defining characteristic of the area.' Green field and Green Belt development: I struggle to see how a plan which envisages significant building upon green-field sites can be reconciled with maintaining the bucolic charms which you see as an essential characteristic of the town; and nor do I see how the notion of a 'borough of villages' is enhanced by concreting over the gaps between them. There was a time - I believed - when the green belt was supposed to be sacrosanct, but I presume this is no longer the case. My concern is not simply the present intention to build within the Green Belt, but the inevitable precedent this sets. I presume the argument runs that we would be building only / mainly on Green Belt sites which are already compromised by existing development. But in so doing, yet more land will be compromised - paving the way for the same argument to be repeated forever, while the Green Belt steadily vanishes under tarmac. Rail links: If we really believe that fast transport links are a major attractor, I cannot understand how a plan to build on the station car park can do anything other than undermine this. You may be able to get to London in twenty minutes from the station, but if your journey time to the station now takes twenty minutes more than before because you can't park there (longer if you have to travel early and there are no buses), surely the fact that the train is fast is irrelevant - and certainly for businesses there must be a temptation to locate elsewhere where possibly property prices are lower? Transport infrastructure: Presumably you must have considered the impact of the plan upon the road and general transport infrastructure of the town, but the plan seems to have nothing to say about the transport infrastructure to support all this development (or if it does, I have failed to find it). As you will know only too well, Brentwood essentially has only one major road east-west, and one north-south, and even without blockages, travel across town can be extremely time-consuming and frustrating, particularly at rush hour - in addition reducing air quality in the town centre; and I know that in towns such as Cambridge, traffic congestion has caused a number of startups to abandon plans to locate in the city, and to move elsewhere. Proposals for significant further building in the town centre cannot but exacerbate the problem - and exacerbate it significantly. Developments on William Hunter Way and on the Wates Way Industrial Estate are particular cases in point, the latter in respect of the awkward junction between Burland Rd and Ongar Rd. I imagine you must have modelled likely capacity requirements and have proposals to address them? What were the outcomes of those investigations, and what specific plans are in place to relieve the congestion which will otherwise inevitably arise? Are you considering further road building (and if so, how much existing property will need to be demolished to make way for new or widened roads, and to what extent will this compromise what you are trying to achieve); and what provision is being made for public transport? Overall growth: I have had difficulty identifying the actual number of dwellings the plan envisages, since different numbers appear in different places in the document. So far as I can see, the plan calls for an additional 7600 houses over the period to 2033 - or possibly it calls for 9080. According to 2011 census information online, Brentwood had 30,600 households at that time. Assuming (generously) that this equates to 30,600 individual homes, this still appears to mean that the Brentwood district will grow over the next 15 years by approximately 25% - 30%, and it is impossible to imagine that this can do other than change the whole character of the area. Car parks: I am concerned at the number of Brentwood town-centre car parks which the plan envisages giving over to housing. What studies have you carried out to investigate the impact of this upon town-centre businesses, and what is the risk that this will simply drive shoppers away from Brentwood altogether? (And in the latter case, what is your estimate of the environmental impact of the additional travel?) Plans by Tesco: I realise that Tesco's plans to redevelop the Hopefield Animal Sanctuary site appear to be outside the scope of the plan. Nonetheless, they would certainly impact upon Brentwood town centre, and therefore upon the developments covered by the plan. Is planning permission likely to be given to Tesco? If so, how is it intended that the new development should be linked to existing roads, given that there are a number of schools along Sawyer's Hall Lane, and the area is already very congested at the start and end of the school day? And what impact would it have upon the council's own plan? Plans for the Ford Offices at Warley: I was unaware that this site might become available. Is Ford planning a closure off its own bat? And if the offices do close, has any assessment been made of the impact upon the local economy? Let us close by thanking you for your time in considering these issues. We look forward to any comments you can make to set our minds at rest.

See attached.

See attached.

See attached.

See attached.

Thank you for your consultation on the above which was received by Natural England on 06 March 2018. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. FURTHER INFORMATION REQUIRED Brentwood Draft Local Plan: Preferred Site Allocations As a general principle, allocations should be sited on land of least environmental and amenity value. In particular, they should avoid: designated sites/priority habitats; Best and Most Versatile (BMV) agricultural land; areas at risk of flooding; brownfield sites of high environmental value. There are 3 SSSIs within Brentwood District, namely Thorndon Park SSSI, The Coppice, Kelvedon Hatch SSSI and Curtismill Green SSSI. We have looked the allocations in relation to these SSSIs. Part 2 Preferred Site Allocations There are no allocations directly within or adjacent to SSSIs but the following allocations are within Natural England Impact Risk Zones (IRZs) for residential and/or rural residential development: 81, 117A, 117B, 112A, 112D, 112E, 194, 075B. This means that we would like to be consulted further to ensure that any impacts have been taken into account and mitigation provided if required. It does not mean that we have an outright objection to these allocations. We have a more detailed comment to make on Dunton Hills Garden Village (site ref: 200) as follows: We have no 'in principle' objection to this allocation but we advise that certain mitigation measures will be required to avoid significant adverse impacts to designated sites. Our SSSI risk zones have identified that water supply mechanisms and the method of foul drainage will need confirming before impacts can be ruled out. Potential impacts from surface water runoff on water quality-sensitive designated sites will need consideration; good quality SuDS within the development would help to address this and could also provide biodiversity net gain along with other enhancement mechanisms, such as the provision of ecological linkages to existing habitats of importance and habitat management for S41 biodiversity priority habitats and species. The location falls within a zone of influence for recreational disturbance to internationally designated sites, i.e. it will need to be considered in terms of the emerging Essex Coast Recreational disturbance Avoidance and Mitigation Strategy (RAMS), which Brentwood Borough Council are committed to delivering along with the other relevant Essex authorities. For large developments, such as this Garden Village, we consider that mitigation of increased recreational disturbance impacts usually requires more than one type of approach, typically involving a combination of 'onsite' informal open space provision and promotion (i.e. in and around the development site) and 'offsite' visitor access management measures (i.e. at the designated site(s) likely to be affected). In terms of nationally designated sites, the development will also need to consider increased recreational pressure to the nearby Thorndon Park SSSI and Basildon Meadows SSSI (and any potential changes to the boundary of the SSSI; in Basildon District) and any mitigation measures that might be required. Habitats Regulations Assessment of Brentwood District Council Draft Local Plan: Preferred Site Allocations Section 4.5 Table 5: Screening Assessment of Employment Site Allocations: Brentwood Enterprise Park is listed as 1.9 km from Epping Forest, this should be 19km. The other distances for this site and for other allocations mentioned are also incorrect and need amending. Epping Forest SAC Note that recent studies have identified a new housing zone of influence around Epping Forest SAC to be a distance of 6.2km from the SAC; this may be subject to revision. However, we agree provisionally that impacts arising from increased recreational pressure from Brentwood's allocations can be ruled out given that none is within 6.2km from the SAC. Para 5.10. We agree that 'At this early stage in the Plan development (i.e. Reg. 18) it is appropriate that both traffic modelling and air quality modelling are undertaken to confirm Brentwood's contribution to traffic flows (and thus atmospheric pollution contributions) within Epping Forest SAC to inform future iterations of the Plan. The effects on designated nature conservation sites (including increased traffic, construction of new roads, and upgrading of existing roads), and the impacts on vulnerable sites from air quality effects on the wider road network in the area can be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. We consider that the designated sites at risk from local impacts are those within 200m of a road with increased traffic, which feature habitats that are vulnerable to nitrogen deposition/acidification. Regarding effects on general air quality (regional or national), we advise that in addition to assessing local air quality effects, consideration should also be given to national air quality impacts resulting from diffuse pollution over a greater area. The UK Government has international commitments to reduce national emissions of pollutants and consideration should be given to impacts that occur on a regional, national and international scale and which also contribute to background concentrations. Essex Coastal European Sites Para 6.2: We agree that Essex Estuaries SAC and Thames Estuary and Marshes SPA/Ramsar are scoped in for recreational disturbance impacts. Para 6.4: We note that 4 allocations are located within 10km of Thames Estuary and Marshes SPA/Ramsar, including Dunton Hills Garden Village. Para 6.6: We note that All residential site allocations in Brentwood are located within 24km of the Essex Estuaries SAC. Para 6.8: We agree that Brentwood should adhere to the interim guidance that we have recommended in order to avoid adverse effects on these sites until the Essex RAMS is finalised with up-to-date evidence. Visitor survey have been undertaken for a number of European sites in the RAMS project and as such the zones of influence for recreational disturbance impacts are currently being considered by partners. The HRA may therefore need to reflect these zones of influence should they change from the current interim zones of influence. Para 6.14: We agree that the Council prepare their Plan in consultation with Thames Water and Anglian Water to ensure that development is delivered in locations that can accommodate increased sewage inputs. We agree with the findings of the Conclusions that further information and studies are required before the final assessment of impact on internationally designated sites can be made. Interim Sustainability Appraisal (SA) of Brentwood Local Plan Table 4.1: We support the objectives for biodiversity and suggest that an objective is included to ensure development delivers a net gain in biodiversity. Decisions about 'Areas that are home to declining species or habitats should be a particular target for protection and ecological restoration' should be made on up-to-date information and evidence. Chapter 7 Appraisal of reasonable alternatives: We have no further comments to make on the alternatives. Chapter 8 Developing the preferred approach: We note that Option 3 which involves Dunton Hills Garden Village in addition to other sites which are a 'constant' is the preferred approach. 10.3. Biodiversity: We note the review of allocations which includes reference to Thorndon Park SSSI and The Coppice, Kelvedon Hatch SSSI. If it is likely that there will be impacts on SSSIs, we advise that the SA should undertake more detailed assessments and recommend any site specific mitigation that is required to inform the site allocation policies. 10.10 Landscape: We note the review of allocations which includes reference to highly valued rural landscapes. 10.11 Soil and contamination: We note that the current soil data does not allow an assessment of BMV land. We advise that further agricultural land classification surveys are required to inform decision-making. Section 13 Monitoring: Whilst it is not Natural England's role to prescribe what indicators should be adopted, the following indicators may be appropriate. Biodiversity: Number of planning approvals that generated any adverse impacts on sites of acknowledged biodiversity importance; Percentage of major developments generating overall biodiversity enhancement; Hectares of biodiversity habitat delivered through strategic site allocations. Green infrastructure: Percentage of the city's population having access to a natural greenspace within 400 metres of their home; Length of greenways constructed; Hectares of accessible open space per 1000 population. APPENDIX III - SITE OPTIONS APPRAISAL Table B: Site appraisal criteria with performance categories: Natural England has defined SSSI Impact Risk Zones for the three SSSIs present in the Borough. Impact Risk Zones relating to residential developments of 100 residential units or more tend to extend to 2km from the SSSIs' boundaries. However a further criterion of 800m has been included to reflect the number of sites within this Impact Risk Zone. (Note it should be Site of Special Scientific Interest). Natural England is unclear as to how the 800m criterion has been derived and we would like further clarification of this. We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

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