Dear Sir/Madam,
Thank you for consulting Thames Water on the above document. Thames Water is the statutory sewerage undertaker for part of the Borough and is hence a "specific consultation body" in accordance with the Town & Country Planning (Local Development) Regulations 2012.
Planning Policies
Thames Water support the proposed policies within the Pre-submission Local Plan. Notwithstanding this it is suggested that minor modifications are made to the text within Policies SP01 and SP04 in order to ensure that the policies are effective in relation to ensuring development is delivered alongside any necessary sewerage infrastructure reinforcement works required to support it. The proposed modifications are set out in the attached response forms. In relation to Policy NE02 the requirement for engagement with sewerage providers is welcomed. To assist with promoting early engagement it would be beneficial if a link to Thames Waters pre-application service could be provided on the Councils website. Details regarding Thames Waters pre-application service can be found at: www.thameswater.co.uk/preplanning

Site Specific Comments
We have undertaken a high level review of the proposed site allocations within the Thames Water catchment and have appended comments in relation to wastewater infrastructure issues for these sites in table below.
R04 & R05 - Ford Headquarters and Council Depot, Warley: The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and
how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application. R06 - Land off Nags Head Lane, Brentwood The wastewater network capacity in this area may be unable to support the demand
anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application.
R07 - Sow & Grow Nursery, Ongar Road, Pilgrims Hatch
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ
R08 - Land adjacent to Camel, Mascalls Lane, Warley
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ. We do not envisage network infrastructure concerns regarding wastewater infrastructure capability in relation to this site on a basis that it won't be any surface water connection into a public foul sewer system. Connection of surface water into a public foul sewer system reduces sewer capacity and has the potential to cause flooding to existing customers. Drainage hierarchy to be followed in addressing surface water.
R09 - Land west of Warley Hill, Pastoral Way, Warley
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ
Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R10 - Brentwood railway station car park St James Road, Brentwood
The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application. A significant assets run beneath the site. We would seek protection of these assets and may require several wayleaves /easements. Drainage hierarchy to be followed in addressing surface water. As this is brown field site, we expect significant reduction in surface water runoff.
R11 - Westbury Road Car Park, Westbury Road, Brentwood
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Drainage hierarchy to be followed in addressing surface water. As this is a
brown field site, we expect significant reduction in surface water runoff.
R12 - Land at Hunter House, Western Road, Brentwood (Reviewed Jan18)
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Surface water to be addressed according to the Drainage hierarchy. This being a brownfield site we expect a significant reduction in surface water runoff.
R13 Chatham Way/Crown Street Car Park, Brentwood (Reviewed Jan18)
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing.Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R14 - WILLIAM HUNTER WAY, CAR
PARK SITE, BRENTWOOD
The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead
of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be
submitted with the planning application. Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R15 - Wates Way Industrial Estate,
Ongar Road, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding water supply network or water
treatment infrastructure capacity in relation
to this site/s. It is recommended that the
Developer and the Local Planning Authority
liaise with Thames Water at the earliest
opportunity to advise of the developments
phasing. Please contact Thames Water
Development Planning, either by email
Devcon.team@thameswater.co.uk tel:
02035779998 or in writing Thames Water
Utilities Ltd, Maple Lodge STW, Denham
Way, Rickmansworth, Hertfordshire, WD3
9SQ
Drainage hierarchy to be followed in
addressing surface water. As this is a
brown field site, we expect significant
reduction in surface water runoff.
R16 & R17- Land off Doddinghurst Road, either side of A12, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater network or
wastewater treatment infrastructure
capability in relation to this site/s. It is
recommended that the Developer and the
Local Planning Authority liaise with Thames
Water at the earliest opportunity to advise of
the developments phasing. Please contact
Thames Water Development Planning,
either by email
Devcon.team@thameswater.co.uk tel:
02035779998 or in writing Thames Water
Utilities Ltd, Maple Lodge STW, Denham
Way, Rickmansworth, Hertfordshire, WD3
9SQ
R19- Land At Priests Lane, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Please note that the above comments
relate to the sewerage network within the
Thames Water supply area only. It is
recommended that Anglian Water are also
consulted for their comments in relation to
this development proposal. Drainage
hierarchy to be followed in addressing
surface water.
R23 - Brizes Corner Field, Blackmore
Road, Kelvedon Hatch
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Drainage hierarchy to be followed in
addressing surface water. Please note that
the above comments relate to the sewerage
network within the Thames Water supply
area only. It is recommended that Anglian
Water are also consulted for their
comments in relation to this development
proposal.
R24 - Land off Stocks Lane, Kelvedon Hatch
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Drainage hierarchy to be followed in
addressing surface water. Please note that
the above comments relate to the sewerage
network within the Thames Water supply
area only. It is recommended that Anglian
Water are also consulted for their
comments in relation to this development
proposal.

POLICY SP04
In relation to wastewater infrastructure it will be essential that new development is aligned with any
necessary upgrades required to ensure that the development would not overload the existing
sewerage network. Thames Water therefore support the content of Policy NE2 parts D and E and
encourage developers proposing developments to engage with them at an early stage to discuss the
wastewater infrastructure requirements for development.
The proposed policy ensures that the Local Plan is consistent with Paragraphs 20 and 41 of the NPPF.
Alongside the proposed amended text for Policy SP04, the policy will help ensure the effective
delivery of any sewerage network reinforcement works necessary to support development.

POLICY SP04
In relation to wastewater infrastructure it will be essential that new development is aligned with any
necessary upgrades required to ensure that the development would not overload the existing
sewerage network.
Thames Water support the policy in principle. However, it should be noted that new sewerage
infrastructure is delivered by the sewerage undertaker and funded through the infrastructure charge
for new developments connecting to the sewerage network. It is not therefore possible for any
necessary upgrades to be secured through CIL or S106 contributions. In order to ensure that any
necessary sewerage infrastructure reinforcement works required to support a development are
delivered ahead of the occupation of development it may be necessary for planning conditions to be
used to ensure that a development or phase of development is not occupied until the required
upgrade has been delivered. To help ensure this Policy SP04 should make reference to the use of
planning conditions as a mechanism to ensure the delivery of infrastructure alongside S106
agreements and CIL.

To address the above concern Part B of Policy SP04 could be amended to incorporate the following
wording:
"c. off-site capacity improvement works (secured through appropriate planning conditions or
agreements)"
The proposed change would ensure that planning conditions can be used to secure infrastructure
improvements necessary to support development alongside S106 agreements and CIL thereby
ensuring that the policy is effective and the Local Plan is sound.

POLICY SP01:
Thames Water support the aim of Policy SP01 (D) in relation to ensuring development does not result
in unacceptable impacts on amenity. However, as worded the policy would only be effective in
ensuring that development itself has no unacceptable impact on amenity. Consideration is also
required to be given to whether the location of proposed development is appropriate taking into
account existing sources of noise, odour and vibration to ensure that the amenity of future occupiers
of development will not be adversely affected by such issues. Where development would be affected
by an existing source of noise, odour or vibration development should only be allowed where it is
demonstrated that suitable mitigation measures can be put in place and it has been demonstrated
how these will be delivered. This would be required in order to ensure that the policy is consistent
with Paragraph 182 of the NPPF 2019.
To address the above concern it is considered that Part D(e) of Policy SP01 could be revised to read as
follows:
"e. has no unacceptable effect on health, the environment or amenity due to the release of pollutants
(such as light, noise pollution, vibration, odour, smoke, ash, dust and grit) to land, water or air, and
where the amenity of future occupiers would not be adversely impacted by existing sources of such
pollutants unless suitable mitigation measures are proposed and secured;"
The additional wording would ensure that development is not located where the amenity of future
residents would be affected by existing sources of polluntants unless suitable mitigation is provided.
This would ensure that the policy is effective and consistent with the NPPF and therefore sound.

1.0 Introduction
1.0.1 Thank you for consulting the Basildon & Brentwood Clinical Commissioning Group (CCG) and the Mid and South Essex Sustainability and Transformation Partnership (STP) on the above emerging Local Development Plan (LP) Document.
1.1 In reviewing the context, content and recommendations of the LP Document and its current phase of progression, the following comments are with regard to the Healthcare provision on behalf of the STP
2.0 Existing Healthcare Position in the Emerging Plan Area
2.1 The LP Document covers the administrative area of Brentwood.
2.2 Currently, within the administrative area, healthcare provision incorporates a total of 9 GP Practices, 13 pharmacists, 9 dental surgeries, 10 Opticians, 2 community clinics and 2 community hospitals.
2.3 These are the healthcare services available that this Local Plan must take into account in formulating future strategies.

1. Introduction
1.1 This representation is made towards the Brentwood Local Plan Pre-Submission Regulation 19 consultation document and is focussed on support of Policy R08: Land at Mascalls Lane, which proposes an allocation on the land at Mascalls Lane, Warley, for housing development of "around 9 new homes of mixed size and type."
1.2 This representation is made on behalf Stonebond Properties Ltd (SP) a locally based regional house builder who has secured an option to promote and develop the land at Mascalls Lane, Warley (Policy R08) for housing. SP are currently working towards submission of a planning application and submits these representations supporting the delivery of this site for residential development. The land at Mascalls Lane, Warley is available for development, in a suitable for housing, being free of constraint, and achievable within 0-2 years.
1.3 This representation follows previous submissions promoting this land as suitable for allocation during previous stages of the Local Plan process and more recent submissions to the Regulation 18 consultation document supporting the allocation of the site for housing. SP fully support the identification of the site for residential development and are committed to delivery once the Council accepts the principle of development or adoption of the emerging Local Plan, whichever is sooner.
1.4 Previous representations have been made in support of the sites release from the Green Belt at the Call for Sites in March 2017, and during the Regulation 18 consultation in March 2018 (Rep ID: 19563). We do not wish to repeat our previous representation but suffice it to say that we continue to support the Pre-Submission Local Plan and the decision to release the site from the Green Belt for residential development, and that SP is committed to developing the site within the next two years.
1.5 SP has not identified any constraint to development of this site that would withhold development. The site has previously been the subject of an application for 11 dwellings under reference 13/01351/OUT, which was refused by the LPA and subsequently dismissed at appeal on 28th January 2015, simply on matter of principle being located within the Green Belt. There were no other matters of harm or local objection that counted against the development, nor any sound planning reasons why this site should be considered anything other than deliverable in the context of the National Planning Policy Framework (NPPF); it is available for development immediately, it is suitable for residential development, and development of 9 dwellings is achievable.
1.6 These representations have adopted the format of the Local Plan comments form and are based around answering the following questions:
* Question 5: Please provide details of either: Why you consider the Plan to be sound, legally compliant, or adheres to the Duty to Cooperate; or
Why you consider that the Local Plan is unsound, is not legally compliant, or fails to comply with the Duty to Cooperate;
* Question 6: Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above; and
* Question 8: If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
1.7 This representation also summarises the Planning History of the site (section 3), as well as providing a summary of relevant Evidence Base documents that have been published since previous representations were made in respect of the site (section 4) before providing our submissions (section 5).
2. Sustainable Location
2.1 The site measures 0.34 ha (0.84 acres) and lies in a highly sustainable location, close to Brentwood Town Centre and the associated benefits that the town centre would offer to residents of the site, including the train station (with its regular services (Including the new Crossrail service) to London and surrounding parts of Essex), retail, and public open space. These are located within walking/cycling distance of the site, and include:
* The Fat Turk Restaurant - opposite the site;
* Headley Spice Restaurant - Approx.400m to the south;
* Warley Country Park - Approx. 500m to the north;
* Ursaline Preparatory School - Approx. 550m to the south;
* Tesco Express - Approx. 800m to the north;
* DW Sports Fitness - Approx. 900m to the north;
* Warley Playing Fields - Approx. 1000m to the east; and
* Beechwood Doctors Surgery - Approx. 1000m to the north.
2.2 The site also lies within walking distance from bus stops located on Warley Hill and Eagle Way, which provide the following bus services:
* 9 Brentwood - Billericay - Laindon - Basildon (Monday - Saturday);
* 21 Ongar - Kelvedon Hatch - Pilgrims Hatch - Brentwood (Monday - Saturday);
* 81 Brentwood Station - Shenfield Station - Hutton (Circular) (Monday - Saturday);
* 251 Warley - Shenfield - Billericay - Gt Burstead - Wickford (Sunday only);
* 269 Grays - Stifford Clays - South Ockendon - Gt Warley - Brentwood (Monday -
Saturday);
* 351 Brentwood - Ingatestone - Chelmsford (7 days a week);
* 808 Community Hospital - Hutton Village - Brentwood Rail Station (Monday - Friday);
and
* 826 Upminster - Gt Warley - Brentwood - Billericay (Monday - Friday).
2.3 The site is located in a highly sustainable location for residential development.
3. Planning History
3.1 The Local Authority refused planning permission for 11 dwellings on the site, under reference 13/01351/OUT, on 24th March 2014. The reasons for refusal did not refer to the number of dwellings proposed; indeed, the only reasons advanced by the Local Authority related to impact upon the Green Belt and the lack of very special circumstances put forward to harm to the Green Belt i.e. the principle only.
3.2 The application was subsequently appealed, which was dismissed by Planning Inspector on 28th January 2015. Again, the Inspector found no issue with the numbers of dwellings proposed; with the main issue being the lack of very special circumstances required to justify the development. This application was made in advance of the emergence of the draft Local Plan which now recognises the suitability of the site for housing and proposes its release from the Green Belt.
3.3 The Council records for the application confirm that the application was accompanied only by a Phase 1 Habitat Survey. This report confirms that, "with respect to ecology, there are no overriding constraints to development and that the scheme is wholly deliverable."
3.4 A copy of the refused site layout, and the Inspector's Report, is supplied with this
4. Local Plan Evidence Base
Green Belt Study (January 2019)
4.1 Brentwood Borough Council has acknowledged that "exceptional circumstances" exist to justify the release of land from the Green Belt in order to meet its OAN. The next step is to select the most suitable and sustainable sites in the most suitable locations.
4.2 Brentwood Borough Council published its initial Green Belt study in January 2018, which comprised the following documents:
* Part 1: Brentwood Green Belt in Context - A high-level historic and functional review of the London Metropolitan Green Belt, and the context against which the Brentwood Local Plan 2013-2033 is being developed; and
* Part 2: Green Belt Parcels Assessment - A borough-wide definition and relative assessment of Green Belt parcels against the five purposes of the Green Belt.
4.3 Our representation dated March 2018 provided SP's comments on that document, which in summary supported the Council's conclusion that the site is appropriate for release from the Green Belt, and that the Parcel of Green Belt that the site lies within (Parcel 29A West of Warley) made a 'moderate' contribution to the Green Belt purposes.
4.4 The Green Belt Study Part 3 - "Assessment of Potential Housing, Employment and Mixed-Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation" - was published in November 2018, and subsequently amended in January 2019. This part of the Green Belt Study assesses the potential Site Allocations against the purposes of the Green Belt.
4.5 The report continues to find that Land at Mascalls Lane, Warley makes a 'Low-Moderate' contribution to the Green Belt.
4.6 We fully endorse the assessments conclusions which confirms that:
* Purpose 1 - the site is well contained by housing to the north and east; Warley Hospital to the west; and Mascalls Lane to the south. The assessment confirms that development on this site would not encroach beyond the existing settlement into the countryside;
* Purpose 2 - development on the site would not cause coalescence with other towns and will not significantly reduce the gape to Great Warley or towards Romford;
* Purpose 3 - The site is a 'typical' countryside use with no current public access; and
* Purpose 4 - The site has a 'limited' relationship with the historic town, and that that site does not lie within or adjacent to a Conservation Area, with adjacent dwellings being predominantly post-war.
4.7 The assessment concludes that the site makes a 'low-moderate' contribution to the Green Belt Purposes and concludes that development would form a natural small-scale extension to Warley.
4.8 Our own assessment of the site against the purposes of the Green Belt was provided within our March 2018 representation, and which came to consistent conclusions as the Green Belt Study 2019, as follows:
* Purpose 1: to check the unrestricted sprawl of large built-up areas The site has strong physical features that would act as boundaries to restrict future development. The site is constrained by residential development to the north, east and west; and by Mascalls Lane to the south. The site is therefore clearly well contained, and development would not encroach beyond existing pattern of development on Mascalls Lane into the countryside.
* Purpose 2: to prevent neighbouring towns merging into one another The significant containment of the site will ensure that proposed development will not result in towns - Brentwood and Romford - merging into one another, nor will development reduce the gap to Great Warley.
* Purpose 3: to assist in safeguarding the countryside from encroachment The site currently comprises unused scrubland, with no public use of rights of way and no public use.
* Purpose 4: to preserve the setting and special character of historic towns The site does not lie within a Conservation Area. Adjacent buildings are typically post-war, modern development. The site has no relationship with the historic core of Brentwood.
* Overall: It is our assessment that the site performs a low-moderate contribution to the Green Belt purposes. The site is bound on all sides by existing development, which restricts opportunities for further development into the Green Belt, and as such development on this site would make a natural extension to the existing built up area without encroaching further into the Green Belt.
4.9 We therefore fully support the Council's conclusion that the site is appropriate for release from the Green Belt and is to be removed from the site from the Green Belt, which will allow SP to bring forward the site for residential development immediately.
4.10 The removal of the site from the Green Belt would not cause conflict with paragraphs 136-139 of the NPPF, in that the site has clearly defensible boundaries (Mascalls Lane, and adjacent residential development) which are permanent and will not lead to further development encroaching into the Green Belt.
Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options
4.11 This Study was published in October 2018 and assesses landscape and visual considerations only in relation to the sites allocated for potential development in the Pre-Submission Plan.
4.12 Land at Mascalls Lane, Warley, is included within the assessment as Site Reference 027, with the report confirming that the site has a 'low' landscape and settlement character sensitivity; a 'medium' visual sensitivity; and a resultant overall landscape sensitivity of 'medium'. The
report confirms that the site is of an 'unremarkable' character, is not an important piece of land between settlements, and would have no effect on the general pattern of development in the area.
4.13 We would agree with this assessment of the site and consider that a scheme could be delivered on this site, which would consider the landscape character of the area and deliver some landscape benefits to this part of Warley.
Housing and Economic Land Availability Assessment (HELAA) October 2018
4.14 The Borough Council's Housing and Economic Land Availability Assessment (HELAA) was published in October 2018 and updates and replaces all previous land availability studies, including the 2011 Strategic Housing Land Availability Assessment (SHLAA).
4.15 Land at Mascalls Lane, Warley, is within the HELAA as Site 027, with the HELAA confirming the site to be 'suitable', 'available' and 'achievable' for residential development, further confirming that the site is deliverable within 1-5 years.
4.16 We support the conclusions that the site is 'suitable', 'available' and 'achievable' for residential development and confirm that Stonebond Properties committed to delivering residential development on this site immediately but certainly within 1-2 years.
5. Policy R08: Land at Mascalls Lane, Warley
Question 5 - Comments
5.1 Land at Mascalls Lane, Warley is allocated at Policy R08 for 'around 9 new homes of mixed size and type'. Stonebond Properties supports the proposed allocation and are committed to delivering residential development on this site immediately but certainly within 1-2 years.
5.2 The NPPF makes clear at paragraph 59 that the Government is committed to significantly boosting the supply of homes, and that a sufficient amount of land should be brought forward where it is needed. Paragraph 60 goes onto provide that strategic policies should be informed by a local housing need assessment. It is considered that the Council's Housing Strategy and its proposed allocations, including land at Mascalls Lane, is an appropriate strategy in order to deliver the objectively assessed need calculated at Policy SP02 and detailed within the
Strategic Housing Market Assessment published in October 2018.
5.3 Paragraph 31 of the NPPF confirms that policies should be underpinned by relevant and up to date evidence. Having reviewed the evidence base relevant to this site, as summarised within Section 4 of this Representation, it is considered that the evidence supports the proposed allocation and demonstrates that the site is 'suitable', 'available' and 'achievable' for residential development. This consideration is further confirmed by the planning history of the site, which demonstrates that an earlier application for 11 dwellings was only refused on grounds relating to the impact upon the Green Belt and the lack of very special circumstances put forward to harm to the Green Belt i.e. the principle only. No other concerns were raised within either the Council or Planning Inspector's decision to suggest that development on this site is not achievable.
5.4 Residential development on this site would therefore help to deliver the objectively assessed need that the Local Authority has identified at Policy SP02. Furthermore, the Local Plan Evidence Base has confirmed, through the various stages of its Green Belt Review, that the release of the site from the Green Belt is appropriate given that the site makes only a 'lowmoderate' contribution towards the Green Belt purposes. Stonebond Properties agrees with the Council's assessment of the site in this regard.
5.5 We would like to draw reference to the Technical Report attached as Appendix 4 to this Representation, which provides further evidence with regards the suitability of the site for
residential development. This report confirms that:
* The site lies within a sustainable location, close to regular bus services and central Brentwood;
* A Visibility Plan and Refuse Swept Path accompanies the report, which confirms that the site access can be positioned safely in relation to the existing Mascalls Park access; that reuse vehicles will be able to access and egress in forward gear; and that visibility splays close to 2.4m x 90m can be achieved;
* A range of Sustainable Drainage Systems (SuDS) can be employed on this site which would ensure that development does not increase flood risk off site;
* The development would connect with the existing foul sewer within Mascalls Lane and it is likely that there will be existing capacity within the sewer to serve the development; and
* The site is well served by Essex and Suffolk Water, National Grid, UK Power Networks and BT Openreach, without the need for offsite works.
5.6 The report concludes therefore that the site is deliverable for residential development.
5.7 With regards to the wording of the policy, our comments are as follows:
* Amount and Type of Development - it is considered that the proposed allocation of 'around 9 new homes' is appropriate for the site, and that the use of 'around' allows for a degree of flexibility for Stonebond Properties to progress a scheme for more than 9 dwellings if achievable on the site.
* Development Principles - Access via Mascalls Lane is appropriate for this site. The March 2018 representation was accompanied by the Technical Report (and is resubmitted), which confirmed that visibility splays could be achieved on the site of 2.4m x 90m; and that indicative schemes have demonstrated that refuse vehicles will be able to enter and exit the site in forward gear. This Report also confirms that the site lies within walking distance of a number of bus stops, providing services into Brentwood Town Centre, Shenfield, Grays and Ockendon, which would provide sustainable travel thus reducing car reliance. The additional requirement to provide landscaping along the north, east and western boundaries of the site is appropriate and accepted.
* Infrastructure Requirements - it is noted that the policy identifies the site is within a critical drainage area and this needs to be considered in respect of surface water flooding and may require an individually designed mitigation scheme. However, a report undertaken by our engineers (Appendix 5) illustrates that the site is not located within a Critical Drainage Area as confirmed by the Council's Strategic Flood Risk Assessment but that a Drainage Impact Assessment (DIA) would be required. Therefore, this aspect of the policy is incorrect but will nonetheless be satisfied by a
DIA.
5.8 The emerging policy framework therefore supports Stonebond Properties proposals for residential development on Land at Mascalls Lane, Warley. Policy R08 is, therefore, considered to be sound as it has been:
* Positively Prepared - the proposed allocated has been informed using an evidence base, as summarised within section 4, which demonstrates that the site is available, and that development is achievable and suitable. Development on the application site will contribute towards the Council's identified objectively assessed need and will be brought forward within 1-2 years, making a contribution towards the Council's 5-year housing supply and housing delivery test;
* Justified - The proposed allocation, given that the site is bounded on three boundaries by residential development, is the most appropriate strategy for the site and its allocation is based on a robust and proportionate evidence base;
* Effective - The wording of the policy is sufficient to allow the development to be brought forward within 1-2 years and does not raise any requirements that would delay development being brought forward; and
* Consistent with national policy - Residential development on this site would enable the delivery of a scheme which would be consistent with the Government's aims to sustainable development and which could comply in all other respects with policies within the National Planning Policy Framework.
Question 6 - Comments
5.9 Stonebond Properties only comments that would require amendments relates to the wording
of Part C of Policy R08.
5.10 Part C identifies the site is within a critical drainage area and this needs to be considered in respect of surface water flooding and may require an individually designed mitigation scheme. However, a report undertaken by our engineers (Appendix 4) illustrates that the site is not located within a Critical Drainage Area as confirmed by the Council's Strategic Flood Risk Assessment. However, a Drainage Impact Assessment (DIA) would be included with any future application to address this issue. Therefore, this aspect of the policy is incorrect but will nonetheless be satisfied by a DIA.
Question 8 - Comments
5.11 Stonebond Properties would welcome the opportunity to present oral evidence to the Inspector, if required, in order to provide further detail in respect of the proposed allocation and to provide further evidence in respect of application timescales and the deliverability of development on this site.
5.12 We would therefore like to participate in the examination process.
6. Summary
6.1 Stonebond Properties Ltd is committed to delivering residential development on this site immediately but certainly within the first five years of the Plan; indeed, the site is available for development now, in a suitable for housing, being free of constraint, and achievable within 0- 2 years. Stonebond Properties Ltd supports the Local Authority's intention to remove the site from the Green Belt and its proposed allocation for residential development.
6.2 The Council's Evidence Base, supplemented by representations prepared in respect of the site's allocation, demonstrates that the site is suitable to be released from the Green Belt, given that it performs only a 'low-moderate' function against the Green Belt. Furthermore, a previous application for development on this site was only refused on ground related to inappropriate development in the Green Belt at a time prior to the Council's signalled intention to allocate the land for residential development. No other issues were raised in respect of the suitability or deliverability of the site for residential development.
6.3 Please record this representation as a formal submission towards the Local Plan evidence base and drafting stages and we look forward to the opportunity to presenting evidence to the Local Plan Inspector and answering any questions that the Inspector may have with regards to residential development on this site.

The site is not located within a Critical Drainage Area as confirmed by the Council's Strategic Flood Risk Assessment.

1. Introduction
1.1 This representation is made towards the Brentwood Local Plan Pre-Submission Regulation 19 consultation document and is focussed on support of Policy R08: Land at Mascalls Lane, which proposes an allocation on the land at Mascalls Lane, Warley, for housing development of "around 9 new homes of mixed size and type."
1.2 This representation is made on behalf Stonebond Properties Ltd (SP) a locally based regional house builder who has secured an option to promote and develop the land at Mascalls Lane, Warley (Policy R08) for housing. SP are currently working towards submission of a planning application and submits these representations supporting the delivery of this site for residential development. The land at Mascalls Lane, Warley is available for development, in a suitable for housing, being free of constraint, and achievable within 0-2 years.
1.3 This representation follows previous submissions promoting this land as suitable for allocation during previous stages of the Local Plan process and more recent submissions to the Regulation 18 consultation document supporting the allocation of the site for housing. SP fully support the identification of the site for residential development and are committed to delivery once the Council accepts the principle of development or adoption of the emerging Local Plan, whichever is sooner.
1.4 Previous representations have been made in support of the sites release from the Green Belt at the Call for Sites in March 2017, and during the Regulation 18 consultation in March 2018 (Rep ID: 19563). We do not wish to repeat our previous representation but suffice it to say that we continue to support the Pre-Submission Local Plan and the decision to release the site from the Green Belt for residential development, and that SP is committed to developing the site within the next two years.
1.5 SP has not identified any constraint to development of this site that would withhold development. The site has previously been the subject of an application for 11 dwellings under reference 13/01351/OUT, which was refused by the LPA and subsequently dismissed at appeal on 28th January 2015, simply on matter of principle being located within the Green Belt. There were no other matters of harm or local objection that counted against the development, nor any sound planning reasons why this site should be considered anything other than deliverable in the context of the National Planning Policy Framework (NPPF); it is available for development immediately, it is suitable for residential development, and development of 9 dwellings is achievable.
1.6 These representations have adopted the format of the Local Plan comments form and are based around answering the following questions:
* Question 5: Please provide details of either: Why you consider the Plan to be sound, legally compliant, or adheres to the Duty to Cooperate; or
Why you consider that the Local Plan is unsound, is not legally compliant, or fails to comply with the Duty to Cooperate;
* Question 6: Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above; and
* Question 8: If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
1.7 This representation also summarises the Planning History of the site (section 3), as well as providing a summary of relevant Evidence Base documents that have been published since previous representations were made in respect of the site (section 4) before providing our submissions (section 5).
2. Sustainable Location
2.1 The site measures 0.34 ha (0.84 acres) and lies in a highly sustainable location, close to Brentwood Town Centre and the associated benefits that the town centre would offer to residents of the site, including the train station (with its regular services (Including the new Crossrail service) to London and surrounding parts of Essex), retail, and public open space. These are located within walking/cycling distance of the site, and include:
* The Fat Turk Restaurant - opposite the site;
* Headley Spice Restaurant - Approx.400m to the south;
* Warley Country Park - Approx. 500m to the north;
* Ursaline Preparatory School - Approx. 550m to the south;
* Tesco Express - Approx. 800m to the north;
* DW Sports Fitness - Approx. 900m to the north;
* Warley Playing Fields - Approx. 1000m to the east; and
* Beechwood Doctors Surgery - Approx. 1000m to the north.
2.2 The site also lies within walking distance from bus stops located on Warley Hill and Eagle Way, which provide the following bus services:
* 9 Brentwood - Billericay - Laindon - Basildon (Monday - Saturday);
* 21 Ongar - Kelvedon Hatch - Pilgrims Hatch - Brentwood (Monday - Saturday);
* 81 Brentwood Station - Shenfield Station - Hutton (Circular) (Monday - Saturday);
* 251 Warley - Shenfield - Billericay - Gt Burstead - Wickford (Sunday only);
* 269 Grays - Stifford Clays - South Ockendon - Gt Warley - Brentwood (Monday -
Saturday);
* 351 Brentwood - Ingatestone - Chelmsford (7 days a week);
* 808 Community Hospital - Hutton Village - Brentwood Rail Station (Monday - Friday);
and
* 826 Upminster - Gt Warley - Brentwood - Billericay (Monday - Friday).
2.3 The site is located in a highly sustainable location for residential development.
3. Planning History
3.1 The Local Authority refused planning permission for 11 dwellings on the site, under reference 13/01351/OUT, on 24th March 2014. The reasons for refusal did not refer to the number of dwellings proposed; indeed, the only reasons advanced by the Local Authority related to impact upon the Green Belt and the lack of very special circumstances put forward to harm to the Green Belt i.e. the principle only.
3.2 The application was subsequently appealed, which was dismissed by Planning Inspector on 28th January 2015. Again, the Inspector found no issue with the numbers of dwellings proposed; with the main issue being the lack of very special circumstances required to justify the development. This application was made in advance of the emergence of the draft Local Plan which now recognises the suitability of the site for housing and proposes its release from the Green Belt.
3.3 The Council records for the application confirm that the application was accompanied only by a Phase 1 Habitat Survey. This report confirms that, "with respect to ecology, there are no overriding constraints to development and that the scheme is wholly deliverable."
3.4 A copy of the refused site layout, and the Inspector's Report, is supplied with this
4. Local Plan Evidence Base
Green Belt Study (January 2019)
4.1 Brentwood Borough Council has acknowledged that "exceptional circumstances" exist to justify the release of land from the Green Belt in order to meet its OAN. The next step is to select the most suitable and sustainable sites in the most suitable locations.
4.2 Brentwood Borough Council published its initial Green Belt study in January 2018, which comprised the following documents:
* Part 1: Brentwood Green Belt in Context - A high-level historic and functional review of the London Metropolitan Green Belt, and the context against which the Brentwood Local Plan 2013-2033 is being developed; and
* Part 2: Green Belt Parcels Assessment - A borough-wide definition and relative assessment of Green Belt parcels against the five purposes of the Green Belt.
4.3 Our representation dated March 2018 provided SP's comments on that document, which in summary supported the Council's conclusion that the site is appropriate for release from the Green Belt, and that the Parcel of Green Belt that the site lies within (Parcel 29A West of Warley) made a 'moderate' contribution to the Green Belt purposes.
4.4 The Green Belt Study Part 3 - "Assessment of Potential Housing, Employment and Mixed-Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation" - was published in November 2018, and subsequently amended in January 2019. This part of the Green Belt Study assesses the potential Site Allocations against the purposes of the Green Belt.
4.5 The report continues to find that Land at Mascalls Lane, Warley makes a 'Low-Moderate' contribution to the Green Belt.
4.6 We fully endorse the assessments conclusions which confirms that:
* Purpose 1 - the site is well contained by housing to the north and east; Warley Hospital to the west; and Mascalls Lane to the south. The assessment confirms that development on this site would not encroach beyond the existing settlement into the countryside;
* Purpose 2 - development on the site would not cause coalescence with other towns and will not significantly reduce the gape to Great Warley or towards Romford;
* Purpose 3 - The site is a 'typical' countryside use with no current public access; and
* Purpose 4 - The site has a 'limited' relationship with the historic town, and that that site does not lie within or adjacent to a Conservation Area, with adjacent dwellings being predominantly post-war.
4.7 The assessment concludes that the site makes a 'low-moderate' contribution to the Green Belt Purposes and concludes that development would form a natural small-scale extension to Warley.
4.8 Our own assessment of the site against the purposes of the Green Belt was provided within our March 2018 representation, and which came to consistent conclusions as the Green Belt Study 2019, as follows:
* Purpose 1: to check the unrestricted sprawl of large built-up areas The site has strong physical features that would act as boundaries to restrict future development. The site is constrained by residential development to the north, east and west; and by Mascalls Lane to the south. The site is therefore clearly well contained, and development would not encroach beyond existing pattern of development on Mascalls Lane into the countryside.
* Purpose 2: to prevent neighbouring towns merging into one another The significant containment of the site will ensure that proposed development will not result in towns - Brentwood and Romford - merging into one another, nor will development reduce the gap to Great Warley.
* Purpose 3: to assist in safeguarding the countryside from encroachment The site currently comprises unused scrubland, with no public use of rights of way and no public use.
* Purpose 4: to preserve the setting and special character of historic towns The site does not lie within a Conservation Area. Adjacent buildings are typically post-war, modern development. The site has no relationship with the historic core of Brentwood.
* Overall: It is our assessment that the site performs a low-moderate contribution to the Green Belt purposes. The site is bound on all sides by existing development, which restricts opportunities for further development into the Green Belt, and as such development on this site would make a natural extension to the existing built up area without encroaching further into the Green Belt.
4.9 We therefore fully support the Council's conclusion that the site is appropriate for release from the Green Belt and is to be removed from the site from the Green Belt, which will allow SP to bring forward the site for residential development immediately.
4.10 The removal of the site from the Green Belt would not cause conflict with paragraphs 136-139 of the NPPF, in that the site has clearly defensible boundaries (Mascalls Lane, and adjacent residential development) which are permanent and will not lead to further development encroaching into the Green Belt.
Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options
4.11 This Study was published in October 2018 and assesses landscape and visual considerations only in relation to the sites allocated for potential development in the Pre-Submission Plan.
4.12 Land at Mascalls Lane, Warley, is included within the assessment as Site Reference 027, with the report confirming that the site has a 'low' landscape and settlement character sensitivity; a 'medium' visual sensitivity; and a resultant overall landscape sensitivity of 'medium'. The
report confirms that the site is of an 'unremarkable' character, is not an important piece of land between settlements, and would have no effect on the general pattern of development in the area.
4.13 We would agree with this assessment of the site and consider that a scheme could be delivered on this site, which would consider the landscape character of the area and deliver some landscape benefits to this part of Warley.
Housing and Economic Land Availability Assessment (HELAA) October 2018
4.14 The Borough Council's Housing and Economic Land Availability Assessment (HELAA) was published in October 2018 and updates and replaces all previous land availability studies, including the 2011 Strategic Housing Land Availability Assessment (SHLAA).
4.15 Land at Mascalls Lane, Warley, is within the HELAA as Site 027, with the HELAA confirming the site to be 'suitable', 'available' and 'achievable' for residential development, further confirming that the site is deliverable within 1-5 years.
4.16 We support the conclusions that the site is 'suitable', 'available' and 'achievable' for residential development and confirm that Stonebond Properties committed to delivering residential development on this site immediately but certainly within 1-2 years.
5. Policy R08: Land at Mascalls Lane, Warley
Question 5 - Comments
5.1 Land at Mascalls Lane, Warley is allocated at Policy R08 for 'around 9 new homes of mixed size and type'. Stonebond Properties supports the proposed allocation and are committed to delivering residential development on this site immediately but certainly within 1-2 years.
5.2 The NPPF makes clear at paragraph 59 that the Government is committed to significantly boosting the supply of homes, and that a sufficient amount of land should be brought forward where it is needed. Paragraph 60 goes onto provide that strategic policies should be informed by a local housing need assessment. It is considered that the Council's Housing Strategy and its proposed allocations, including land at Mascalls Lane, is an appropriate strategy in order to deliver the objectively assessed need calculated at Policy SP02 and detailed within the
Strategic Housing Market Assessment published in October 2018.
5.3 Paragraph 31 of the NPPF confirms that policies should be underpinned by relevant and up to date evidence. Having reviewed the evidence base relevant to this site, as summarised within Section 4 of this Representation, it is considered that the evidence supports the proposed allocation and demonstrates that the site is 'suitable', 'available' and 'achievable' for residential development. This consideration is further confirmed by the planning history of the site, which demonstrates that an earlier application for 11 dwellings was only refused on grounds relating to the impact upon the Green Belt and the lack of very special circumstances put forward to harm to the Green Belt i.e. the principle only. No other concerns were raised within either the Council or Planning Inspector's decision to suggest that development on this site is not achievable.
5.4 Residential development on this site would therefore help to deliver the objectively assessed need that the Local Authority has identified at Policy SP02. Furthermore, the Local Plan Evidence Base has confirmed, through the various stages of its Green Belt Review, that the release of the site from the Green Belt is appropriate given that the site makes only a 'lowmoderate' contribution towards the Green Belt purposes. Stonebond Properties agrees with the Council's assessment of the site in this regard.
5.5 We would like to draw reference to the Technical Report attached as Appendix 4 to this Representation, which provides further evidence with regards the suitability of the site for
residential development. This report confirms that:
* The site lies within a sustainable location, close to regular bus services and central Brentwood;
* A Visibility Plan and Refuse Swept Path accompanies the report, which confirms that the site access can be positioned safely in relation to the existing Mascalls Park access; that reuse vehicles will be able to access and egress in forward gear; and that visibility splays close to 2.4m x 90m can be achieved;
* A range of Sustainable Drainage Systems (SuDS) can be employed on this site which would ensure that development does not increase flood risk off site;
* The development would connect with the existing foul sewer within Mascalls Lane and it is likely that there will be existing capacity within the sewer to serve the development; and
* The site is well served by Essex and Suffolk Water, National Grid, UK Power Networks and BT Openreach, without the need for offsite works.
5.6 The report concludes therefore that the site is deliverable for residential development.
5.7 With regards to the wording of the policy, our comments are as follows:
* Amount and Type of Development - it is considered that the proposed allocation of 'around 9 new homes' is appropriate for the site, and that the use of 'around' allows for a degree of flexibility for Stonebond Properties to progress a scheme for more than 9 dwellings if achievable on the site.
* Development Principles - Access via Mascalls Lane is appropriate for this site. The March 2018 representation was accompanied by the Technical Report (and is resubmitted), which confirmed that visibility splays could be achieved on the site of 2.4m x 90m; and that indicative schemes have demonstrated that refuse vehicles will be able to enter and exit the site in forward gear. This Report also confirms that the site lies within walking distance of a number of bus stops, providing services into Brentwood Town Centre, Shenfield, Grays and Ockendon, which would provide sustainable travel thus reducing car reliance. The additional requirement to provide landscaping along the north, east and western boundaries of the site is appropriate and accepted.
* Infrastructure Requirements - it is noted that the policy identifies the site is within a critical drainage area and this needs to be considered in respect of surface water flooding and may require an individually designed mitigation scheme. However, a report undertaken by our engineers (Appendix 5) illustrates that the site is not located within a Critical Drainage Area as confirmed by the Council's Strategic Flood Risk Assessment but that a Drainage Impact Assessment (DIA) would be required. Therefore, this aspect of the policy is incorrect but will nonetheless be satisfied by a
DIA.
5.8 The emerging policy framework therefore supports Stonebond Properties proposals for residential development on Land at Mascalls Lane, Warley. Policy R08 is, therefore, considered to be sound as it has been:
* Positively Prepared - the proposed allocated has been informed using an evidence base, as summarised within section 4, which demonstrates that the site is available, and that development is achievable and suitable. Development on the application site will contribute towards the Council's identified objectively assessed need and will be brought forward within 1-2 years, making a contribution towards the Council's 5-year housing supply and housing delivery test;
* Justified - The proposed allocation, given that the site is bounded on three boundaries by residential development, is the most appropriate strategy for the site and its allocation is based on a robust and proportionate evidence base;
* Effective - The wording of the policy is sufficient to allow the development to be brought forward within 1-2 years and does not raise any requirements that would delay development being brought forward; and
* Consistent with national policy - Residential development on this site would enable the delivery of a scheme which would be consistent with the Government's aims to sustainable development and which could comply in all other respects with policies within the National Planning Policy Framework.
Question 6 - Comments
5.9 Stonebond Properties only comments that would require amendments relates to the wording
of Part C of Policy R08.
5.10 Part C identifies the site is within a critical drainage area and this needs to be considered in respect of surface water flooding and may require an individually designed mitigation scheme. However, a report undertaken by our engineers (Appendix 4) illustrates that the site is not located within a Critical Drainage Area as confirmed by the Council's Strategic Flood Risk Assessment. However, a Drainage Impact Assessment (DIA) would be included with any future application to address this issue. Therefore, this aspect of the policy is incorrect but will nonetheless be satisfied by a DIA.
Question 8 - Comments
5.11 Stonebond Properties would welcome the opportunity to present oral evidence to the Inspector, if required, in order to provide further detail in respect of the proposed allocation and to provide further evidence in respect of application timescales and the deliverability of development on this site.
5.12 We would therefore like to participate in the examination process.
6. Summary
6.1 Stonebond Properties Ltd is committed to delivering residential development on this site immediately but certainly within the first five years of the Plan; indeed, the site is available for development now, in a suitable for housing, being free of constraint, and achievable within 0- 2 years. Stonebond Properties Ltd supports the Local Authority's intention to remove the site from the Green Belt and its proposed allocation for residential development.
6.2 The Council's Evidence Base, supplemented by representations prepared in respect of the site's allocation, demonstrates that the site is suitable to be released from the Green Belt, given that it performs only a 'low-moderate' function against the Green Belt. Furthermore, a previous application for development on this site was only refused on ground related to inappropriate development in the Green Belt at a time prior to the Council's signalled intention to allocate the land for residential development. No other issues were raised in respect of the suitability or deliverability of the site for residential development.
6.3 Please record this representation as a formal submission towards the Local Plan evidence base and drafting stages and we look forward to the opportunity to presenting evidence to the Local Plan Inspector and answering any questions that the Inspector may have with regards to residential development on this site.