yes more employment to the borough sensible use of extending existing site

No access to public transport and as such runs counter to NPPF

I object to this site being expanded any further to the west or the south of the current boundaries.
Residents of Little Warley Hall Lane have suffered in the past from the noise and dust of heavy industrial operations on site at the end of their gardens. Also potential light-pollution.
The site lies in agricultural green belt. Currently it's fairly unobtrusive in the landscape viewed from A127 and Little Warley Hall Lane but this may not remain the case if given outline permission to expand.

To increase employment and growth of businesses, this site is ideal to expand an existing industrial estate. Good road access.

Highways & Transportation Comment -
Impact of development on the A127 needs to be fully assessed with significant improvement to the junction with the A127 / Childerditch Lane.
Within the expansion and improvements, connectivity should be developed for accessing the sites via sustainable transport measures.
The A127 does act as a deterrent for people using sustainable modes of transport.

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.

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.