Policy wording should be amended as follows:

b. provision for "multifunctional" public open space to deliver a measurable net gain in biodiversity;

Policy wording lacks a commitment to deliver biodiversity net gain.

Reduce number of homes planned for the site.

The plan appears unsound. It will still bring heavy traffic to the Doddinghurst Road on a network that is already under enormous pressure.

There is also the consideration of schools in the area which are already oversubscribed and needs to be taken into account.

There is also concern that developing homes near the A12 boundary is unlikely to be an attractive proposition and careful consideration needs to be done if this development will be successful.

Reduce number of homes planned for the site to ensure enough boundary is in place between greenery and A12. Retain some of the countryside features so that the character of Brentwood and surrounding area is retained.

Provide clear evidence around how educational impact and infrastructure will not be significantly impacted.

Reduce number of homes planned for the site. Provide clear evidence around how education infrastructure will not be significantly impacted.

The plan appears unsound. It will still bring heavy traffic to the Doddinghurst Road on a network that is already under enormous pressure.

There is also the consideration of schools in the area which are already oversubscribed and needs to be taken into account.

There is also concern that developing homes near the A12 boundary is unlikely to be an attractive proposition and careful consideration needs to be done if this development will be successful.

Reduce number of homes planned for the site to ensure enough boundary is in place between greenery and A12. Retain some of the countryside features so that the character of Brentwood and surrounding area is retained.

Provide clear evidence around how educational impact and infrastructure will not be significantly impacted.

Reduce number of homes planned for the site to ensure enough boundary is in place between greenery and A12. Retain some of the countryside features so that the character of Brentwood and surrounding area is retained.

The plan appears unsound. It will still bring heavy traffic to the Doddinghurst Road on a network that is already under enormous pressure.

There is also the consideration of schools in the area which are already oversubscribed and needs to be taken into account.

There is also concern that developing homes near the A12 boundary is unlikely to be an attractive proposition and careful consideration needs to be done if this development will be successful.

Reduce number of homes planned for the site to ensure enough boundary is in place between greenery and A12. Retain some of the countryside features so that the character of Brentwood and surrounding area is retained.

Provide clear evidence around how educational impact and infrastructure will not be significantly impacted.

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'm. Sending you my objectives about planing on 200 houses being built on bishops Hall back viking way. This is green belt has badgers and fox's on also rare birds sky larks which are protected since 1981 they nest on there they will have no where to nest please send my object in to the right department as I will be sending this email to County file and the protection of birds thank you Williams

Amend wording in Policy R16&17 with regards to(1) unit number (2) access, so that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways.
Amend wordings in relation to the timing of the delivery in Appendix 1 and paragraph 9.160.

1. Introduction

1.1 These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients land at Doddinghurst Road (North & South of the A12), which has been allocated under Policy R16 & 17 of the PSLP. A plan showing the site is provided as Appendix A to this representation.

1.2 Countryside was founded in Essex 60 years ago by Alan Cherry and has since established a reputation for delivering high quality developments. With the ethos 'creating places people love', Countryside's achievements are exemplified through having won more Housing Design Awards than any other house builder.

1.3 Countryside is a major development and place-maker, having secured planning permission and building out developments in varying scales: from smaller 30 dwelling schemes on the edge of village's through to large urban extensions of 3,500 new homes plus associated community facilities. Countryside has a proven track record of delivery. The company is headquartered in Brentwood and has a proud legacy of local sites such as Clements Park and the Square on Hart Street.

1.4 The representations set out Countryside's position in relation to the residential site allocation of R16 and R17, both parcels of which fall within their control. The proposed allocation provides for around 200 dwellings and is an important contribution towards BBC's land supply for Brentwood Borough's Draft Plan. The representations provide comments on the relevant policies relating to those interests in the Draft Plan.

1.5 As the Council will be aware, representations have previously been made on behalf of Countryside Properties and in respect of the two parcels of land, towards the Preferred Options Consultation in October 2013 and the Strategic Growth Options Consultation February 2015, and the Regulation 18 Local Plan in March 2018. As a result of these representations, and the discussions that have been held with officers at Brentwood Borough Council alongside the Local Plan process, the two parcels either side of the A12 at Doddinghurst Road have been proposed as a housing allocation within PSLP. From here, the two parcels of land are referred to as "the site", in respect of their joint allocation and policy.

1.6 Countryside's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to the elements of the Housing and Development Management Policies and the housing trajectory relating to the delivery of Policy R16 and R17 during the Plan period.

1.7 Where such concerns are raised, specific changes to the relevant polices are sought and these are indicated in the following representations in order to assist the Council to make the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy.


1.8 Site 023A measures at approximately 5.99ha and Site 023B measures at approximately 2.2ha. The Council have defined the total net developable area of the two sites as 6.14ha. The site is currently designated as Green Belt in the adopted development plan.

1.9 The PSLP has recognised the sustainability of the site and enclosed character, and have therefore proposed it for removal from the Green Belt and for its allocation to provide housing. We support this allocation but do however have some concerns over other policies in the PSLP that may have implications for the efficient and timely delivery of this site.








 

2. Brentwood Local Plan Regulation 19 Consultation
Housing Need
2.1. Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 dwellings per annum. Paragraph 4.12 confirms that this figure is calculated using the Standard Method (as per the NPPF and respective Planning Practice Guidance(PPG)). We note that the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220).

2.2. On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum.

2.3. The NPPF requires Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change.

2.4. At paragraph 4.16 the PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'.

2.5. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility or Green Belt protection. Moreover, the figure does not allow provision for unmet need from neighbouring authorities in addition to the minimum requirement.

2.6. At 4.18 the PSLP confirms the Council have not been able to identify a five-year housing land supply to deliver the annualised requirement. Further to this, at 4.19 the PSLP confirms that there is a high proportion of designated Green Belt within the Borough, making it extremely difficult to achieve a five-year supply due to the fact that sites on the edge of settlements, currently within the Green Belt are not available for development purposes until the adoption of the Plan.

2.7. The Borough has a limited amount of previously developed land within its authority to provide for short term delivery, as such Green Belt release is required in order to meet the Authorities housing need and deliver within the short, medium and long term, as stated at paragraph 2.54 of the PSLP. The approach to amend the Green Belt boundaries is therefore supported.

2.8. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement.

2.9. In respect of the above, whilst the current PSLP and associated housing allocations seek to go some way in delivering housing that will support the recognised needs of the Borough over the next 15 years, there is clearly a need to increase this provision. Whilst this could be helped through the identification of additional sites, ensuring the delivery and efficient use of the sites that are allocated for housing will also provide a degree of buffer. Further commentary and recommendations in this regard are provided later within this representation.
Five-year Housing Land Supply and Housing Trajectory
2.10. The Council is required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913).

2.11. The NPPF (Paragraph 73) confirms that a 20% buffer should be applied to the initial calculation for a five-year housing land supply requirement, in the event that the results of the Housing Delivery Test show that there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. From November 2018, significant under delivery indicates that delivery was below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037-20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan.

2.12. The results of the 2018 Housing Delivery Test confirmed that Brentwood have delivered just 50% of the housing requirement over the last three years and this is therefore well below the threshold for the 20% buffer requirement.

2.13. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is noticeably less.

2.14. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings.

2.15. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply.

2.16. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can delivery early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver.

2.17. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24.

2.18. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing.

2.19. Furthermore, and in respect of the projected supply, we are concerned to note that Dunton Hills Garden Village is anticipated to deliver housing completions from 2022/23, falling within the first five years of the plan.

2.20. Dunton Hills Garden Village is a proposed major strategic development, intended to provide a new settlement supported by a range of facilities and infrastructure. Delivery will require the coordination and input of multiple landowners, developers, infrastructure providers and other stakeholders. Once allocated, the PSLP proposes a masterplan and design guidance will be required to be prepared to ensure that a cohesive approach is taken to the development of the Garden Village.

2.21. As such, it is a concern that 100 homes will be completed at Dunton Hills Garden Village as early as 2022/23. This does not in itself mean that Dunton Hills Garden Village proposals cannot form part of a sound Local Plan, but it does again demonstrate an inability to rely on large strategic sites for short term housing delivery, and emphasises the need for smaller sites to be supported by policies which will allow their short term delivery to ensure the Local Plan is sound.

Policy R16 & R17: Land off Doddinghurst Road
2.22. Policy R16 & R17 proposes the release of the site from the Green Belt and allocation for around 200 new homes. This approach is supported as an achievable and deliverable solution to contributing towards the Borough's housing land supply to meet the housing need requirement.

2.23. Having regard to the PSLP's housing trajectory, paragraph 9.160 the PSLP states the dwellings are anticipated to be delivered between 2023/24 and 2026/27. We do not support this assumption and object to the timing of the delivery of this site, as set out in the above mentioned paragraph and Appendix 1 of the PSLP. As the Council will be aware, representations have been made to earlier iterations of the emerging Local Plan to confirm the site is available, deliverable and achievable within the first five years of the plan period.

2.24. As currently proposed the trajectory is unsound in relation to this site, and as such is not justified. This is because the site can be delivered earlier than the stated timescales in Appendix 1 of the PSLP. In order to make the housing trajectory sound, amendments to the trajectory must be made to reflect the earlier delivery of the site in the plan period. The proposed amendments would result in a justified approach and a sound policy.

2.25. In addition to amending the housing trajectory to reflect the realistic and earlier delivery of the site, as proposed by a developer with an option on the land, the inclusion of the site within the first five years on the plan period will assist BBC with their five-year housing land supply position, not only assisting in housing delivery of the PSLP is effective and can be found sound at Examination.

Unit Numbers
2.26. Whilst we are supportive of the allocation, we raise concerns in relation to the wording of allocation policies such as Policy R16 & R17 should take this requirement for flexibility into account and worded as such to provide "at least 200 homes", as opposed to "around 200 homes". We consider that this would provide greater certainty on the number of homes to be delivered as part of each allocation for Brentwood Borough Council, and also allows for the delivery of additional units where appropriate opportunities may arise.

2.27. For sites R16 and R17, a significant amount of feasibility work has been undertaken to establish any site constraints, and as a result of this, Countryside are confident in the ability for the site to provide at least 250 homes. We have concerns that the respective policy's current format may be interpreted to confirm the optimum use of the site, rather than a lower limit. In fact, the 200-unit figure has been produced by Brentwood Borough Council with far less rationale and technical justification than has been undertaken by Countryside Properties and may lessen the ability of this site and other policies with similar wording to support Brentwood's need for a buffer and flexibility in their housing land supply.

Access

2.28. It is noted that there has been a change in wording of Part B (b) of Policy R16 & R17 from the November 2018 Proposed Submission Local Plan presented to Committee, and that now being consulted on (February 2019), with no explanation. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.

2.29. Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways.

Policy SP03 Health Impact Assessments
2.30. The Policy requires planning applications for developments of 50 or more to be dwellings, non-residential development of 1,000sqm or more or schemes for C2 class developments to be supported by HIAs. The HBF response to this policy is unsupportive and they consider the policy to be unsound as it is not consistent with national policy and is ineffective.

2.31. We are in agreement with the HBF's response, dated 17th March 2019, in relation to the requirement for HIAs to be provided for 50 or more dwellings and consider the requirement to be unnecessary and an additional burden on applicants. Referring to the PPG we note that HIAs may be useful tools, however the PPG also expresses the importance of the local plan needing to consider the wider health issues in an area and ensuring the policies respond to these concerns. The guidance is provided below for completeness.

2.32. Paragraph: 002 Reference ID: 53-002-20140306 confirms that provision of the required health infrastructure should be supported and taken into account at local and neighbourhood plan making, and when determining planning applications.

2.33. Referring to National policy, paragraph 20 states that Strategic Policies should set out an overall strategy for the pattern, scale and quality of development, this includes infrastructure and community facilities.

2.34. In order for the local plan to be consistent with national policy, the Local Plan should already consider the impact of development on the health and wellbeing of the communities and any identified infrastructure should be addressed in policy. Therefore, whilst Countryside support the important consideration of health and wellbeing of communities where development is in line with the policies contained within the development plan a HIA should not be necessary. The requirement for a HIA should only be triggered where there is a departure from the plan, enabling the Council to assess any impacts on the health and well-being of the community as a result of said proposals.


Policy SP05 Construction Management

2.35. The Policy expects all major development schemes/developers to sign up to the Considerate Constructors Scheme, or equivalent. The scheme is a non-profit making, independent organisation which monitors construction sites signed up to the scheme, with the aim of managing and mitigating impacts arising from construction. This requirement is considered unjustified and inconsistent with national policy.

2.36. Whilst we recognise the importance of managing the potential impacts on construction sites, we consider this policy to be unsound because it is unjustified and not consistent with national policy. We would suggest that consideration for the scheme is best dealt with through planning applications and development management without it being written into formal planning policy.

2.37. We are not aware of any other adopted or emerging Local Plan which requires applicants and developers of major sites to enter into a specified construction management scheme and therefore question the reasonableness of this policy. The matter of construction management should be assessed on a case by case basis and should not be a matter for a strategic policy to prescribe. How a construction scheme is managed and mitigated should be an item for consideration by the decision taker and assessed on a case by case basis.

2.38. The imposition of Policy SP05 requires all major developments to be signed up to the Considerate Constructors Scheme regardless of the site or proposal details. It is recommended that this policy is removed.


Policy BE02 Sustainable Construction and Resource Efficiency

2.39. We consider the policy to be unsound as it is inconsistent with national policy. Part (f) of Policy BE02 requires the inclusion of renewable and decentralised energy as part of a new development, this is not consistent with national policy. Whilst Countryside recognise the importance of sustainable construction, a policy approach to such requirements does not allow for the appropriate flexibility in this regard, as recognised in the NPPF.

2.40. Paragraph 153 of the NPPF states that local plans can expect development to meet such provisions, however the NPPF also states that they are only required to comply with such policies where it is either feasible or viable. To ensure consistency with national policy part (f) of Policy BE02 should be amended to reflect this position.


Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency

2.41. It is Government policy to seek to deliver improvements to emissions from buildings through the building regulations regime. As such we do not consider it necessary to include the table at part (a) of this policy. Should a national zero carbon policy be introduced it will be achieved and applied through building regulations, as noted at paragraph 5.33.

2.42. We therefore echo those comments of the HBF's consultation response, dated 17th March 2019, and suggest that if the building regulations are updated then the Council should revisit the policy through a local plan review at that stage, but that such matters are dealt with through building regulations in the meantime to prevent unnecessary duplicate consideration of such matters through both planning and construction stages.


Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network

2.43. It is acknowledged that the Government support the transition to a low carbon future in a changing climate, including support towards renewable and low carbon energy and associated infrastructure. Countryside support these intentions.

2.44. Part (b) of Policy BE04 expects sites of over 500 dwellings, including where there are clusters of neighbouring sites that total over 500 units, shall incorporate decentralised energy infrastructure in line with a hierarchy however.

2.45. We raise concerns in relation to the deliverability of part (b) of the policy in relation to sites within a cluster of 500 or more dwellings given that neighbouring sites will not necessary come forward by multiple landowners and developers at similar times. The coordinating and implementation of a heat network to serve smaller scale sites as separate applications but adjacent to other similar sized sites in the locality, is unreasonable and unjustified and could result in a delay in delivery of new homes, resulting in an ineffective local plan.

2.46. It is recommended that the requirement for new development located where 'clusters' of neighbouring sites totals over 500 units should be removed from the policy in order to make the policy effective.


Policy BE10 Connecting New Developments to Digital Infrastructure

2.47. It is Government policy to support the expansion of electronic communications networks. However, we would draw the Council's attention to the Written Ministerial Statement, 25th March 2015, which announced that local planning authorities preparing Local Plans, "should not set any additional standards or requirements relating to the construction, internal layout or performance of new dwellings."

2.48. The Local Planning Authority are only allowed to adopt the three optional technical standards, in relation to construction, internal layout and performance, subject to evidenced need and viability. As such, the Council should not seek higher standards than Building Regulations, as already referred to in our response to Policy BE03. Therefore, Policy BE10 is considered unsound because it is unjustified and contrary to national policy.

2.49. We are also unaware of National Policy requiring benches and bins to be connected to mobile digital infrastructure. As such the policy is unjustified and contrary to national policy.

2.50. Countryside are committed to ensuring that all developments go as far as is practical to meet national intentions to ensure the quality, practicality and future-proofing of new housing developments. We have concerns however that by introducing a wealth of additional planning policies in these areas, there will be unnecessary duplication to building regulations, and potentially delays to planning applications which will in turn impact on the timely delivery of new homes.



3. Site Deliverability

3.1. The site represents a deliverable, sustainable and achievable site for residential development. A number of technical reports and associated documents have been completed which demonstrate this. The below section provides a summary of these documents.

Density Study
3.2. A Density Study (January 2018) has been undertaken by JTP Architects.

3.3. As per Paragraph 2.23 of this representation, the Preferred Site Allocations Document (January 2018) states that the indicative dwelling yield of the site is 200 dwellings.

3.4. The Density Study confirms that the total site area is 8.02ha and the total developable area is 6.17ha. Furthermore, it confirms that the site can accommodate up to 250 dwellings with 180 dwellings on Site 023A and 40 dwellings on parcel 023B, which results in 40 dwellings per hectare and 25 dwellings per hectare, respectively.

3.5. The Density Study also provides a Developable Area Plan which illustrates the developable area, the existing trees and root protections areas (RPA), the easements and attenuation and drainage. The plan proposed that the most significant existing trees and foliage are retained.

3.6. Furthermore, the Study characterises the existing landscape features of Site 023A as three naturally formed developable areas. This natural formation will enable an orthogonal street pattern and regular frontage and a more efficient layout of a potentially higher density.

3.7. The study characterises Site 023B as a more irregular shape due to the present underground services. Furthermore, the Density Study identifies that the site has more constrained access opportunities. This has led to a more organic layout of a potentially lower density.

3.8. Given the evidence in the Density Study, the site could accommodate up to 250 dwellings. Further detail on how the site could present a sustainable development opportunity can be found in the summaries below.
Air Quality
3.9. An Air Quality Assessment was undertaken by Ardent Consulting Engineers in February 2017. The assessment reviews air quality constraints affecting the site.

3.10. The assessment concludes that it is unlikely that the proposed development will be considered high risk in terms of construction impacts. It also suggests that there has been a general improvement in local air quality over recent years which is evidenced by the monitored concentrations which are detailed within the report. Nevertheless, the assessment recommends that mitigation measures may need to be adopted as part of the development and be further considered in due course.

3.11. The assessment recommends that the impact of any potential increase in traffic flow on the local road network should be determined by way of a detailed air quality assessment.

3.12. Given the proximity of the A12, there is the potential for the introduction of a new exposure adjacent to the A12. This is dependent on the distance between individual units and the A12 which is to be addressed through careful design by the Architects.


Archaeology
3.13. An Archaeological Desk Based Assessment was undertaken by CGMS Consulting in November 2014.

3.14. The assessment confirms that the site does not lie within an area of archaeological priority, as previously designated by Brentwood Borough Council. It confirms that the site can be considered to have a modest potential for the late prehistoric.

3.15. The assessment also confirms that the site has remained undeveloped land through its documented history.

3.16. The assessment anticipates that Essex County Council archaeological advisors may request additional archaeological mitigation measures, initially in the form of a geophysical survey.

Desktop Noise Report
3.17. A Desktop Noise Report was completed by Ardent Consulting Engineers in March 2016.

3.18. The Noise Report concludes that subject to appropriate mitigation measures, the proposed internal and external areas of the proposed development could be demonstrated to be within desirable noise levels, subject to a detailed assessment.

3.19. The report states that ambient vibration levels may be a concern due to the sites proximity to the A12. These will need to be further addressed during more detailed assessment works.

3.20. Furthermore, a Noise Feasibility Plan has also been produced by Ardent Consulting Engineers. The plan provides a number of layout recommendations for Glazing, Ventilation, Rear Gardens and Balconies and Standalone Barriers. The Noise Feasibility Plan also outlines the closest possible building line on site which has reasonable attenuation and the recommended approximate minimum effective extent of an acoustic barrier. The plan also provides dimensions between the site and the nearest channel of the A12.


Drainage Strategy
3.21. A Drainage Strategy Technical Note was produced by Ardent Consulting Engineers in 2016. The note confirms that existing foul and surface water sewers navigate the site, together with a number of watercourses which will continue to serve the site, post development.

3.22. The report also confirms that the site is within Flood Zone 1 and is therefore suitable for residential development. The note suggests that subject to further investigation and detailed design, a Flood Risk Assessment and Detailed Drainage Strategy can be prepared to support a successful planning application for the development.

Phase 1 Habitat Survey
3.23. A Phase 1 Habitat Survey was produced by SES in 2014. The survey concluded that the habitats on site have the potential to be of value to protected species, as well as being of general biodiversity value themselves. As a result, the Phase 1 Habitat Survey recommends that the following works are undertaken;

* Reptiles (presence/likely absence survey - northern site only);
* Badgers (monitoring of setts on site);
* Bats (tree inspection surveys, activity surveys);
* Breeding Bird (walkover survey during breeding bird season, generally March to August); and
* Invertebrates (walkover survey to establish value for rate and vulnerable beetles).


3.24. It is considered within the survey that any potential adverse impacts from the proposed development upon specific protected species will be able to be wholly mitigated for with careful design.

Social Infrastructure Review
3.25. A Social Infrastructure Review was produced by Quod in February 2017. The review looked to provide an assessment of the likely impact of the development of the site on the demand for school places and healthcare provision.

3.26. The review confirms that based on average household sizes for the area, it is anticipated that the site could accommodate a resident population of approximately 600 people and generate demand for 68 primary school places and 45 secondary school places.

3.27. In line with this estimated growth, the review provides a summary of the education and healthcare provision within Brentwood.

3.28. The review states that although a number of existing primary schools in the Brentwood urban area are being expanded or are due to be expanded, Essex County Council is still expecting to be facing a deficit of places by 2020/21, with the Preferred Site Allocations Document stating that there is an estimated deficit of 541 places by 2021/2022 for Primary Schools. In terms of Secondary School Provision, the Preferred Site Allocations document states that there will be an estimated deficit of 9 places by 2021/22.

3.29. In terms of healthcare provision, the report confirms that the capacity to absorb additional demand arising from developments in the Brentwood Urban Area is limited. The Preferred Site Allocations document confirms this and states that there is likely to be significant pressures on GP Surgeries due to housing growth in the Borough throughout the lifetime of the plan.

Transport
3.30. A Transport Technical Note was prepared by Ardent Consulting Engineers in January 2018. The technical note provides an initial review of the anticipated highway and transportation impacts, based on a potential development of up to 250 dwellings at the site.

3.31. The note confirms that vehicular access to the site could be provided from Doddinghurst Road for the 23A of the site and provided via the extension of Karen Close and Russell Close at the 23B parcel.

3.32. In response to local concerns regarding the suitability of existing public transport provision, the note suggests that the site could generate an additional 7 peak hour bus trips and 35 peak hour rail trips. It is considered that there is sufficient capacity to accommodate these trips. The note confirms that there does not appear to be any specific issues relating to public transport.

3.33. The technical note confirms that the impacts on surrounding roads including Doddinghurst Road and Ongar Road would not be severe and should not be a reason for the site not to be allocated.

3.34. The note confirms that there are no highways issues that would prevent the site from being allocated for residential development in the emerging Local Development Plan.

3.35. The above studies demonstrate that the site is deliverable and sustainable.

We propose the following modifications for the reasons outlined in our response to the Local Plan consultation. Strengthen the wording of all policies to ensure that appropriate air and noise pollution measures form an integral part of any development proposals. Wherever there is reference to either the A12, or the mainline railway, the related criterion should read as follows:
"appropriate measures, including barriers, embankments and landscaping, to reduce air and noise must be provided along the site's boundary(ies) with the A12 and/or the mainline railway."
Removal of R17 from Policy R16 and R17.
Removal from proposed allocation R03 of the elliptical shaped piece of land between the A1023 Chelmsford Road and the A12 Marylands Interchange, and the area to the north of the site bounded by the Marylands Interchange to the north, the railway line to the south-east, a part of Arnold's Wood to the south-west and Chelmsford Road to the north-west.
Removal of Allocation R21 on grounds of poor physical environment, isolation from the main settlement of Ingatestone and coalescence with the village of Mountnessing.
Removal of Allocation R22 on grounds of poor physical environment.

We have grouped these polices together since our comments relate to their common characteristics. The most important is that these allocations are all bounded by the A12 to a greater or lesser extent. As noted in our representations on Policy NE05, the Pre-Submission Document's paragraph 8.50 states that transport generated emissions are the prime source of air pollution in the Borough. We have consistently questioned the wisdom of locating new housing next to the A12 on the grounds of public health.
Policy R16 and R17 refers to two parcels of land on either side of the A12, currently designated as Green Belt. The Policy says that new development on this land should consider, amongst other things, providing for:
"... appropriate landscaping and buffers along sensitive boundary adjoining the A12."
R17 is a relatively narrow strip of land on the southern side of the A12. It is currently a relatively wooded area at around the same level as the A12. Any landscaping here would be confined by the narrowness of the site and ineffective as a barrier against air and noise pollution. This should be removed from the allocation and designated instead as open space.
R16 is a larger and better configured space and we agree that a degree of development here could be achieved in an acceptable environment, provided there are strong and effective measures to reduce air and noise pollution from the A12. Again, the land is on much the same level as the A12. Clearly, the further any development is located away from the A12 then the less the risk of pollution measures to mitigate.
Policy R16 and R17 is weakly worded on the need for appropriate mitigating measures. It should state that any new development will provide effective measures along boundaries with the A12 and elsewhere. We note that the Policy also includes requirements for public open space and provision of pedestrian and cycling connections. Again, the Policy should insist on these provision and not simply ask potential developers to "consider" them.
Effective noise and pollution barriers do not look aesthetically pleasing. Adequate space will be needed for landscaping to mitigate their visual impact.
R03 is one of the Pre-Submission Document's strategic allocations. Much of this allocation seems sensible and logical. It is bounded to the north-west by the A12 and south-east by the main railway line. As with Policy R16 and R17, R03 says new development should consider providing for:
"... appropriate landscaping and buffers along sensitive boundary adjoining the A12."
As with Policy R16 and R17, Policy R03 should be more strongly worded to insist on appropriate mitigation measures. There are two parts of the allocation which should be removed and left in the Green Belt. The first is the elliptical shaped piece of land between the A1023 Chelmsford Road and the A12 Marylands Interchange, unless it is specifically reserved for the employment uses mentioned in Policy R03 at A.e.:
"... provision of 2ha of land for employment purposes."
The Marylands Interchange is elevated at this point and would result in a poor residential environment.
The second is an area to the north of the site bounded by the Marylands Interchange to the north, the railway line to the south-east, a part of Arnold's Wood to the south-west and Chelmsford Road to the north-west. This site would also provide a poor and unhealthy environment for new homes as a consequence of its proximity to both the interchange and the mainline railway. Regardless of any mitigation measures, residential development this close to Arnold's Wood, already bisected by the railway line, can only be detrimental to its wildlife value.
R21 and R22 are both proposed allocations for Ingatestone. R21 is a relatively narrow triangular site lying between the mainline railway and the A12. Previously described as land adjacent to the garden centre, we now note that the proposed allocation includes the garden centre. The site is at a level with the A12 and the railway, with consequent air and noise pollution issues. The allocation's extension northwards to the rear of homes in Burnthouse Lane means that it will form a long, southern extension to Ingatestone. It will consolidate coalescence with Mountnessing, which lies to the west of the site on the other side of the A12. In our representations on 2018' s Preferred Sites Consultation, we said:
"This narrowing site, wedged between the A12 and the main railway line is completely unrelated to any existing residential area. The area would suffer from social isolation as well as air and noise pollution. Although the Ingatestone Nursery site would help to form a bridge with the rest of the village, it is our opinion that this site would retain significant disadvantages, and is not a sustainable location in either social or environmental terms."
We think this assessment remains true, even though the nursery now forms part of the allocation.
R22 - we still think it extraordinary to propose this allocation as a satisfactory environment for new homes. There are houses immediately to the south-west along Roman Road, but their presence should not be seen as a justification. The site is at a level with the A12, with the B1002 on the site's northern boundary elevated to cross the A12. We said in our response to 2018's Preferred Sites Consultation that no further consideration should be given to this site and nothing in the Pre-Submission Document has changed our views on this.
Our main point here is that all these proposed allocations, in whole or part, have significant issues resulting from their proximity to principal sources of air and noise pollution. There is conflict with the Pre-Submission Document's own policies on these issues, including Policy NE05. Consequently we are suggesting a number of modifications to the relevant policies.