R17 should be removed from the list of Housing sites proposed. Both R16 and R17 should be reassessed from the ground up, especially as far as the NPPF goes.

Policy R16 & R17 - Land off Doddinghurst Road, Pilgrims Hatch and Brentwood

Essex County Council's official response to Brentwood's Draft LDP in 2018 explicitly (and very significantly) withheld support from Brentwood's plan under a number of specific headings.
One paragraph from the above which particularly relates to the R17 part of this "single" site
is paragraph 4.20:
"ECC notes that the evidence base for the Local Plan includes a Local Wildlife [Site](LoWS) Review (2012) which enables consideration to be given to minimising impacts of site allocations on these non-statutory designated sites for biodiversity. However ECC advises that BBC [Brentwood Borough Council] should carry out assessments in relation to the preferred site allocations, including DHGV [Dunton Hills Garden Village], to establish if they contain Priority habitats and species which could meet the criteria for new LoWS".
There is a very significant chance that the R17 site, as naturally regenerating scrub several decades old, in the Green Belt (a relatively rare habitat in the heavily developed South East), might meet the criteria for new LoWS.
The choice of this site also conflicts with the Plan's own NE01 (Protecting and Enhancing the Natural Environment), in its entirety, particularly because this applies to both "natural designated and non-designated heritage assets". In particular no possible development of the southern part of this site can adhere to NE01 D. b.) and c.).

Additionally there is a point about R16 & R17 in relation to the process which the Council has followed in assessing the borough's Green Belt. Had a decision not been made at the very beginning to lump the site on the town centre side of the A12 (R17), and the site on the Pilgrims Hatch side (R16) together, the work done by the Council's consultants in relation to the Green Belt would have reached different conclusions as to the justifiability of proposing these sites for development. The value of each of the Borough's green belt sites was assessed under the reasons for protecting the Green Belt given in the National Planning Policy Framework (NPPF), and the resulting scores added up - but the scores would have been different for these areas if they had been originally designated two different sites instead of one. Moreover the only reason given, by officers, for lumping these two sites together was that the council (effectively arbitrarily, and not on any planning grounds), did not want any of the Green Belt areas to be assessed to be "very small". However the site on the south of the A12 is inherently small (2.2 hectares, with a developable area of only 1.65 hectares), and this alone hardly justifies lumping it together with the Pilgrims Hatch area. This "single" site (R16/R17, which were 023B/023A on earlier lists) is wholly anomalous as the only Green Belt site in the borough that straddles a major road or a railway line - in all other cases major roads or railways separate sites that have been kept distinct from one another. It was one of only two sites in the whole January 2018 consultation version of the plan - both green belt and non green belt - where the council itself had to list different Site Access roads (the other was the two parts of the West Horndon industrial estate, which have nothing more than an existing fence, not an inaccessible A road, between them). The stated site access in the latest version of the plan is Doddinghurst Road for both, but in fact site access for R17 would have to be off Russell and Karen Closes (off St Kildas Road, off Doddinghurst Road). This is because R16/R17 are the only "single" site all parts of which are neither in a unified area, nor accessible from either side of a single, pre-existing road. R04 and R05 (once 117A and 117B), are directly opposite one another on either side of Eagle Way in Warley; and 034/087/235 and 276, which have become R03, off Alexander's Lane and the A1023 Chelmsford Road in Shenfield, have only been unified in plan terms retrospectively, not from the start.
In the Parcel Definition and Review above, some relevant paragraphs are 1.5.2; 2.2.3 and 2.2.4, and the relevant "parcel" reference is (here, confusingly), 44b.
A criticism of this "single" site on the above grounds, if upheld, therefore potentially undermines everything that has been predicated on it being a "single" site, including the Draft Plan's housing proposals.
This site also contradicts everything said elsewhere in the Plan about noise, pollution and air quality. Currently, as undeveloped and regenerating scrub, R17 does an excellent job of protecting Russell Close, Karen Close and St Kildas Road from excessive A12 noise and pollution. No development of it can improve the role it currently plays, and any development of it, on ground level with the A12, will almost inevitably create new dwellings whose air quality fails to meet Environment Agency guidelines - just as was happening for dwellings in the River Road, Wingrave Crescent, Leonard Way area of west Brentwood when they were assessed several years ago. No responsible Council should be proposing such sites in its Local Plan.