Reduce the density

This policy proposes such a high density in an established residential area it is not taking account of its neighbours

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.

I am writing to you to object to the density of housing Brentwood Council is proposing on the office site in Western Road which equates to something like 229 dwellings per Hectare, which is far the biggest of any of the proposed sites and can only possibly be achieved with high rise blocks of flats, which is inappropriate in a residential street of houses with a maximum height of two and a half stories. I understand that there other sites which also fall short of policy in the Local Development Plan to which I object. I quote from the Local Development Plan: "Efficient land use is essential in a borough like Brentwood where land is scarce and enables new homes to be provided without encroaching on the countryside. Good design makes it appropriate to develop in a way that is sympathetic to local character, uses land efficiently and creates or maintains a high-quality living and working environment The right density will depend on the scheme, dwelling mix, site characteristics and location. 6.19 Proposals for housing developments should promote an effective use of land in line with the NPPF. Policy HP03 Residential Density sets out the Council's expectations on the net density of sites in the borough, supporting development proposals that make efficient use of land and discouraging low density development to ensure optimal use of each site.
6.20 The Council considers it reasonable to expect proposals to achieve densities
of at least 35 dwellings per hectare except where this would harm the special
character of an area, have an adverse transport impact or cause harm to residential amenities. Densities of 65 dwellings to the hectare or more will generally be expected in locations well served by retail, commercial and community facilities and services, and/or locations with good public transport accessibility."

I should like to raise the following issues regarding the LDP. GREEN BELT - While it concerns me that it has proved necessary to utilize Green Belt, I admire the council for sticking to its guns regarding defensible boundaries in order to prevent urban sprawl. I am aware that it is a government diktat that Green Belt should be used to
accommodate the unprecedented housing need but wonder why the enormous
brownfield Clapgate scrapyard site, off Chivers Road in Stondon Massey, is not part of the equation. TRAFFIC CONCERNS - I believe that problems besetting the Clapgate scrapyard site include difficulties involving access. Yet to invest in providing this could help to solve the problems below. 1. Traffic from the large amount of houses destined for Pilgrims Hatch, with access to the Doddinghurst Road, will make the road even more congested at peak times and will result in "rat runs" along minor roads. 2 Traffic from those houses on the William Hunter Way site will put an ENORMOUS amount of pressure on Brentwood's congested unofficial ring road, comprising Western Avenue and Western Road. The junction with the latter and Weald Road is totally inadequate with traffic lights so close to the mini roundabout there. Already, the back up of traffic caused by having to give way to vehicles from the right, and the proximity of the traffic lights, can cause tailbacks stretching down to Western Road, past North Road. I can only imagine the impact of more traffic on the Ongar Road. 3. To build these houses will deprive the town of valuable car parking space and dissaude outsiders from visiting Brentwood. As if the shops didn't have enough problems this could well and truly put a nail in the coffin.
4. As a resident of Pilgrims Hatch, I can testify that the area has a good bus service but, as a widowed pensioner, I would not be able to shop in Brentwood without a car - I would not be able to carry heavy shopping bags to and from bus stops and on and off buses. I rely heavily on collect-by-car services. Yes, I could resort to on-line ordering but this would further adversely affect the life blood of the High Street
ETHICAL CONCERNS - There is a development of 48 units on Western Road, close to its junction with Weald Road, listed as part of the LDP. This development was earlier presented to me, by the council, as a planning application and I was invited to submit any objections I might have. They were: More traffic debouching on to an already congested Western Road (part of Brentwood's unofficial ring road) close to its inadequate junction with Weald Road (as described in No.2 above). The design of the building did not blend with the appearance of the Edwardian /Victorian buildings in what was originally a quiet, residential road but is now a busy thoroughfare. The plans showed that this block of appartments more resembled the
high-rise ugly 1960 structures which Brentwood has been working hard to eliminate
from its townscape. I heard no more officially but understand that, owing to the huge amount of objections, the planners were trying to resolve some problems with the developers who refused to give the council the necessary time in which to do this. They appear to have got round the problem by resorting to the site's listing in the LOP (it had been listed for the development of 22 dwellings in the first draft).
Although this might be a legal loophole, it appears unethical to me because I understand it will be subject to a different policy to that which affects a normal planning application. It suggests that the developer wants to avoid the more stringent measures involved in the latter such as the design of the building and the fact that, in such a restricted area, the only alternative would be to build upwards which would totally conflict with the entire tenor of other homes in the road. CONCLUSION - All these problems appear to have arisen because the Government is demanding too much from such a small town. There is neither the capacity nor infra-structure for further building in the centre and to build outside its confines threatens the Green Belt Despite the need for housing, it is my suspicion that the Government's main aim is to test the water for future expansion of Greater London into Essex. The Campaign for the Protection of Rural England has informed me that the Government has ordered local councils to use Green Belt for building whether there are brownfield sites available or not I wonder whether this could this be the reason why the Stondon Massey scrapyard has not been considered for development.

Removal of Allocation R20. This is a small site and should be categorised as a potential windfall site. At present, there appears to be no certainty about its availability.

R10 - We also think that, without any direct evidence of intent on behalf of the landowner, Allocation R10 should also be removed.

Policy R11 - the third sentence of related paragraph 9.137 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 45 homes, anticipated to be delivered between 2023/24 and 2024/25"

Policy R13 - the third sentence of related paragraph 9.146 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 31 homes, anticipated to be delivered between 2023/24 and 2024/25"

All these policies relate to relatively small redevelopment sites within the urban areas of Brentwood and Shenfield. They have all been under consideration since consultations on the Local Plan began with the original Call for Sites in 2009. If indeed these sites are suitable, available and achievable it must be surprising that at least some of them are not yet developed, or in the process of being developed.
Policy R20 concerns the Eagle and Child PH in Shenfield, with an estimated delivery of 20 new dwellings between 2021/22 and 2022/23. This site is surely best regarded as a windfall site, contributing to this stream of new housing supply as and when it is finally redeveloped. The fact that it first appeared in 2009's Call for Sites suggests that there is no urgency on behalf of the current site owners to take things forward. No application has been submitted over the past five years.
Policies R10 to R15 all relate to sites in or close to Brentwood Town Centre. Four of the six are currently used as car parks, three for the town centre and the fourth is the station car park.
Allocation R10 is the Station Car Park. Many such car parks cannot cope with demand as railway passenger numbers continue to increase. Further parking provision will surely be required during the Plan period and, as with other station car parks, multi-storey provision must be one option for increased capacity. This would affect both redevelopment options and the potential number of new houses, if any, the site could provide. Unless the Borough Council can confirm a clear commitment to redevelopment on behalf of the owners that would provide the 100 homes being asked for, then it should be removed as an allocation. We note that delivery is timed for the very end of the Plan period, with a start in around ten years' time. Given what could happen in the intervening decade, we suggest that there is a strong degree of wishful thinking in proposing this land as a residential allocation.
Policies R11, R13 and R14 all relate to existing town centre car parks controlled by the Borough Council. Together they provide nearly 600 or 45% of the publicly available car parking in Brentwood Town Centre. We note that each policy does contain the following caveat:
"development proposals should consider wider Town Centre parking needs in collaboration with other development sites where there is existing parking on site, in order to ensure that current level of Town Centre public parking spaces is maintained".
This would suggest a high degree of cooperation is needed to achieve these sites' redevelopment and maintain the existing level of town centre car parking provision. All three sites have been under consideration since 2009. Anticipated delivery is as follows:
R11 Westbury Road car park - estimated 45 dwellings between 2020/21 and 2021/22, one to two years from now
R13 Chatham Way car park - estimated 31 dwellings between 2020/21 and 2021/22, one to two years from now

R14 William Hunter Way car park - estimated delivery of 300 dwellings between 2022/23 and 2028/29, three to nine years from now.
No planning applications have been submitted on either allocation R11 and R13 in the past five years. It is most unlikely that either site will be able to deliver in one to two years' time. The lead in time for R14 is longer, but again, no proposals for redevelopment here have been submitted in the past five years.
R12 is land at Hunter House, with anticipated delivery of 48 dwellings between 2024/25 and 2026/27. We assume the number of dwellings is based on the application submitted in 2017, and regarded by the Council as finally disposed by notice dated 10 January this year. Paragraph 9.142 referring to Allocation R12 states that the site will provide "... a mix of size and type of homes including affordable in accordance with the Council's policy requirements." It would appear that the applicants' decision not to provide affordable housing in their proposed scheme was one of the main issues of contention.
The latest Five Year Housing Land Supply Statement is for 31 March 2018, published in November 2018. It demonstrates a 4.1 year supply. Around half of the supply required (820 dwellings) during the period 2018 to 2023 is to come from allocations set out in the Pre-Submission Document. We believe there is considerable doubt over R11, R13 and R20's ability to deliver during this period.
The general point we are making here is that a number of the Pre-Submission Document's brownfield allocations have been under consideration for ten years or more. Some of them, like the town centre car parks, will be complicated to redevelop. We have emphasised throughout the Local Plan process that many of these sites were unlikely to make early contributions to meeting housing supply requirements, unlike our client's site at Pilgrims Hatch that is straightforward to develop and in a single, willing ownership. The problem remains, and supports our contention that the Plan needs more easier to develop sites, with an ownership ready to start.