No change poposed

Thank you for consulting Transport for London (TfL). I can confirm that TfL has no comments to make on the focussed changes to the pre submission Local Plan

Best wishes
Richard Carr

No change proposed

Dear Sir/Madam,

Please be aware that any works within the Marine area require a licence from the Marine Management Organisation. It is down to the applicant themselves to take the necessary steps to ascertain whether their works will fall below the Mean High Water Springs mark.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England's marine area on behalf of the UK government. The MMO's delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.

Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.

Environmental Impact Assessment

With respect to projects that require a marine licence the EIA Directive (codified in Directive 2011/92/EU) is transposed into UK law by the Marine Works (Environmental Impact Assessment) Regulations 2007 (the MWR), as amended. Before a marine licence can be granted for projects that require EIA, MMO must ensure that applications for a marine licence are compliant with these regulations.

In cases where a project requires both a marine licence and terrestrial planning permission, both the MWR and The Town and Country Planning (Environmental Impact Assessment) Regulations http://www.legislation.gov.uk/uksi/2017/571/contents/made may be applicable.

If this consultation request relates to a project capable of falling within either set of EIA regulations then it is advised that the applicant submit a request directly to the MMO to ensure any requirements under the MWR are considered adequately.

Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.

Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.

Minerals and waste plans and local aggregate assessments

If you are consulting on a mineral/waste plan or local aggregate assessment, the MMO recommend reference to marine aggregates is included and reference to be made to the documents below:
* The Marine Policy Statement (MPS), section 3.5 which highlights the importance of marine aggregates and its supply to England's (and the UK) construction industry.
* The National Planning Policy Framework (NPPF) which sets out policies for national (England) construction minerals supply.
* The Managed Aggregate Supply System (MASS) which includes specific references to the role of marine aggregates in the wider portfolio of supply.
* The National and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period including marine supply.
The NPPF informed MASS guidance requires local mineral planning authorities to prepare Local Aggregate Assessments, these assessments have to consider the opportunities and constraints of all mineral supplies into their planning regions - including marine. This means that even land-locked counties, may have to consider the role that marine sourced supplies (delivered by rail or river) play - particularly where land based resources are becoming increasingly constrained.

If you require further guidance on the Marine Licencing process please follow the link
https://www.gov.uk/topic/planning-development/marine-licences

Dear Sir/Madam,
I would like to make the following comments on the Addendum of Focused changes the pre-submission local plan.
The initial statement that it is proposed to build an additional 70 homes at Dunton Hills Garden Village does not match up with the itemised changes. There are 70 homes being relocated from the Shenfield area and a further 20 homes from Blackmore Village area. That is a total of 90 homes. Where are the other 20 homes going to be located?
My specific comments on each proposal are detailed below;
1) Policy ROI
It appears that the Local Plan is to put all the homes it possibly can into Dunton Hills Garden Village at the expense of our local environment and habitat and flood risk rather than impose such a huge number of 70 homes in Shenfield. Obviously the environment and habitat in an urban area is far more important than green belt! Dunton Hills Garden Village is growing like Topsy and will be Dunton Hills Garden Town!
2) Policy R18
The reduction in the number of homes from 55 to 35 (almost 40%) in the Crescent Drive area is purportedly due to i) inconsistency of character, ii) implications on traffic and safety, iii) Development on an urban open space, iv) environment, habitat and flood impact.
1) I understand that Shenfield is an affluent area so any extra homes are unwelcome and out of character unless they are large and expensive. The need for homes must outweigh this and the council must find a way to build homes where needed, not where residents object on this basis. This is NIMBYISM of the highest order and should NOT be allowed. Come on Brentwood do the right thing by ALL borough residents not just the rich few!!
2) I find Crescent Drive to be a quiet almost traffic free area when I go to the Community Hospital so where is the traffic coming from? It is within 1 mile of the A12 so where is the issue with highway access? This sounds like a made up excuse to give padding to this reduction of home build in the area. It is nonsense.
3) How can a suburban area have an environment and habitat and flood risk which is of more importance than Green Belt? Our area of green belt is under severe risk as it is with the Thames tunnel plan and Brentwood council are making matters worse by adding to this pressure. In a Green Belt borough emphasis should be on urban/suburban new build not on using green belt as an easy option. Why are Shenfield opinions more important than that of West Horndon opinions?
All these justifications appear fatuous to me and this proposed change should be rescinded as the council and planning department appear to be making fools of themselves. These are not serious justifications for a re-think, more like a plan to try and shift as much new build as possible as far away from Brentwood Town as possible. When all recent road improvements are on the A12 corridor and the high speed link on rail is coming to Shenfield surely it makes sense to put as many new homes as possible in that area which is also rich in the settlement hierarchy with good transport links, shops and open areas. So again there in an obvious disconnect with no joined up thinking!
3) Policy R19
There is a proposal reduction in scheduled new build homes from 75 to 45 (40%), curiously exactly the same percentage reduction. The same items are stated as the justification for its reduction. My previous comment on POlicy R18 are also very relevant on this proposal too. I find it discriminatory, disgraceful and highly offensive that Shenfield residents have a greater voice than I appear to. They will now have only 80 homes scheduled for build where as our small village will have hundreds more and a new town on our doorstep. The A128 and A127 are already at capacity and entry and exit from our village is already time consuming and risky. Adding more homes and risk. Still Shenfield will be safer I suppose.
4) Policy R25 & R26
Reductions in Blackmore Village from 70 to 50 (30%). The statements for justification are i) inconsistency with character, ii) impact on local services, iii) disagreement with settlement hierarchy, iv) Green Belt development and flood risk.
1) In a large village it is difficult to understand how a total of 70 new homes can make too much difference. There are already a large variety in the types of homes in Blackmore so again how can new build be out of character? What can a reduction of 20 homes do to improve the village character that much? It does not make sense and again appears to be NIMBYISM! Does the council think a token gesture will do in this case? That is how it appears.
2) The impact on local services of 50 homes is not much different to that from 70 homes. Blackmore has good local services with a rail link to Brentwood and this was part of the reasons given for locating hundreds of homes in West Horndon. Road access is good with easy access to the A414, A12,M25 and M11. It has 3 public houses, 2 village halls, sports and social club, football and cricket pitches and a village shop with a farmers market at weekends. Hardly hard done by and surely it could easily take 70 homes without any impact at all. So this part of the justification does not ring true!
3) What is the basis of the settlement hierarchy? Small population areas tend to provide only low order services such as Post Office and Newsagents, not 3 public houses, 2 village halls etc. This is a ridiculous statement as a justification.
West Horndon Village has 1 public house, 1 village hall, no sports and social clubs or cricket pitches etc but is going to have almost 500 extra homes with no improvement in service or facilities. What about our settlement hierarchy? We do not appear to matter to the council and are not as important a village as Blackmore obviously. Again discriminatory, disgusting and very insulting to residents of West Horndon. Where is our value? We pay the same tax to support the council but are obviously second class citizens.
As a separate issue, why has the number of homes on brownfields sites reduced from 1152 to 1132?. There is no mention of where, when or why! Still, I expect they will be relocated to Dunton Hills Garden Town obviously.
All these proposals appear to token gestures pandering to the affluent areas of Brentwood. They show no joined up thinking, there are no explanations of traffic resolution unless you are in the Shenfield area of course.
In my opinion they are poorly thought out and are simply not justifications but excuses for a bad plan which will be pushed through despite protests from residents and tax payers. It is in a mess still!

Failure comply with Duty to Cooperate as local residents and elected representative concerns are disregarded.
Proposed changes are superficial/more more radical reform required. Housing demand should be addressed with high density in and around Brentwood Town - blocks of flats and above shops. Executed effectively in Dagenham Heathway.

Object to all document particularly R25 and R26
Not legally compliant as still contravenes Green Belt legislation and national policy; unsound as R25 andR26 changes grossly inadequate as fail to rectify destruction of Green Belt, loss of agricultural land, access issues on Redrose Lane, impact on school and medical facilities, minimal public transport, flood risk.
Failure comply with Duty to Cooperate as local residents and elected representative concerns are disregarded.
Proposed changes are superficial/more more radical reform required. Housing demand should be addressed with high density in and around Brentwood Town - blocks of flats and above shops. Executed effectively in Dagenham Heathway.

Dear Sir/Madam

BRENTWOOD LOCAL PLAN - PRE-SUBMISSION (REGULATION 19)

Thank you for the consultation on the Brentwood pre-submission local plan. Having reviewed the document, we find the plan sound. We have provided comments in regards to Responding to Climate Change, Water Efficiency, Water Quality, Ecology, Flood Risk, Sustainable Drainage and Contaminated Land where we feel the plan can be enhanced.

Responding to Climate Change

Policy BE01 - Future proofing - the local plan recognises the Borough is located within an area of Serious Water Stress with susceptibility to multi-season droughts, which coupled with climate change and continued growth places further importance on water resources. We would like to see consideration for proactive strategies for increasing water efficiency and conservation of water within new developments promoted in the plan.

Water Efficiency

Policy BE03: Carbon Reduction, Renewable energy and Water Efficiency - due to water pressures in the region and specifically the Borough of Brentwood, we consider it is particularly important that water efficiency measures are incorporated into development schemes and welcome their inclusion within the local plan.

Increased water efficiency for all new developments potentially enables more growth with the same water resources. Developers can highlight positive corporate social responsibility messages and the use of technology to help sell their homes. For the homeowner, lower water usage also reduces water and energy bills.

We endorse the use of water efficiency measures especially in new developments. Use of technology that ensures efficient use of natural resources could support the environmental benefits of future proposals and could help attract investment to the area. Therefore, water efficient technology, fixture and fittings should be considered as part of all new developments.

Policies should consider the use of water efficient systems and fittings such as dualflush toilets; water butts; water-saving taps and showers; and appliances with the highest water efficiency rating as a minimum.
Greywater recycling and rainwater harvesting should also be considered. We welcome the use of SUDS on the site, however, the ultimate destination of surface water drainage and its possible effects on the Water Framework Directive status of receiving waters should be considered.
Any submitted scheme should include detailed information (capacities, consumption rates, etc) on proposed water saving measures. Applicants should be encourage to follow guidance: http://www.water-efficient-buildings.org.uk/ ;
And http://www.savewatersavemoney.co.uk/ which provides further guidance.

Residential developments

All new residential developments are required to achieve a water consumption limit of a maximum of 125 litres per person per day as set out within the Building

Regulations (Amendment) 2015. However, we recommend that in areas of serious water stress as identified by the ourselves, a higher standard of a maximum of 110litres per person per day is applied and we are pleased to see this reflected within this local plan.

Commercial/Industrial developments
We note that for new non-residential development -the BREEAM standard of 'Very Good' has been set as a minimum for Water efficiency.
Given Brentwood is in a serious water stressed area, we would like to see a more ambitious target in line with future proofing developments against climate change and increasing demand for an seriously stressed resource, such as water.
Therefore, for new non-residential developments of 1000 square metres gross floor area or more we feel the BREEAM 'excellent' standards for water consumption should be applied.

Water Quality

SP01 has an extensive list of requirements and mentions avoiding pollution 'such as light, noise pollution, vibration, odour, smoke, ash, dust and grit' but does not mention wastewater and risk to the environment from this.

Point D (Development will be supported .....) could be strengthened by adding an additional bullet point to
say:
can be shown there is availability of sufficient wastewater treatment capacity in order to protect the water environment

Policy DE03: Water efficiency mentions the need for a 'water sustainability assessment'. This section also mentions wastewater and additionally a drainage strategy should be provided to demonstrate there is capacity in the sewage treatment infrastructure or how capacity will be provided in line with development.

We support policies BE18 (Green and Blue Infrastructure) and NE06 (Flood risk). Which include statements about protecting watercourses, and on capacity and phasing of wastewater treatment facilities.

Ecology

Policy BE18 - Following our previous comments on the wording around 'Poor or Moderate [WFD] Status' under section 5.152, we are happy with the wording in this revised document, stating that it is the current grade of the watercourses that are either Poor or Moderate and not that they are the only grade that will be considered.

Policy NE01 - We support the inclusion of multifunctional green and blue infrastucture. In particular we welcome the reference to the numerous benefits derived from natural spaces.

Identifying the requirement for ecological connections between sites and the restoration of ecosystems, ties in with the biodiversity net gain (BNG) principle. BNG is mentioned in this policy already as is working with Essex Wildlife Trust in 8.21

We are encouraged to see that habitat and species conservation and enhancement of non-statutory sites / species as well as statutory is included. It is also good to see that sites are being considered of local importance, not just national importance. Locally important sites should include Local Wildlife Sites.

Section D accounts for cumulative impacts as well as individual impacts when appraising development. Analysis of impacts on designated sites will be particularly relevant to this approach.

Policy BE01- We note that it mentions natural flood management (NFM) under 'Future Proofing'. As NFM is linked to blue and green infrastructure, it should be included under Policy NE01 as well.

As per our previous comments 'The supporting text in Policy NE01 could be enhanced by acknowledging the role played by natural flood management. Reducing flooding by working with natural process, reconnecting watercourses with floodplains to enhance flood storage in times of need, and taking opportunities to restore watercourses to a naturalised state. This should be considered and incorporated into developments wherever opportunities arise. As well as contributing to reducing flood risk, such schemes can enhance the blue infrastructure and contribute to enhancing biodiversity.'

Flood Risk

Policy NE06 - Point C

d. We feel clarify should be proivided in regards to 'strategic water storage' - Does this relate to compensatory storage.

f. Clarification is required in relation to 'safe areas' - does this mean, safe in regards

to appropriate refuge above the extreme flood level with climate change. If so this should be made explicit.

8.61 We feel the line where a site-specific Flood Risk Assessment (FRA) is required, this should be considered by and approved by the Environment Agency should be amended. The Environment Agency are a statutory consultee, we do not 'approve' the Flood Risk Assessment, we provide expert advice on its content.


Sustainable Drainage

Policy BE08 - We feel the Sustainable Drainage section could be enhanced by the inclusion of the following text in Section B point b (Quality) The design must follow the Environment Agency requirements:

1. Infiltration sustainable drainage systems (SuDS) such as soakaways, unsealed porous pavement systems or infiltration basins shall only be used where it can be demonstrated that they will not pose a risk to the water environment.

2. Infiltration SuDS have the potential to provide mobilise pollutants and must not be constructed in contaminated ground. They would only be acceptable if a site investigation showed the presence of no significant contamination.

3. Only clean water from roofs can be directly discharged to any soakaway or watercourse. Systems for the discharge of surface water from associated hardstanding, roads and impermeable Vehicle parking areas shall incorporate appropriate pollution prevention measures and a suitable number of SuDS treatment train components appropriate to the environmental sensitivity of the receiving waters.

4. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.

5. Deep bore and other deep soakaway systems are not appropriate in areas where groundwater constitutes a significant resource (that is where aquifer yield may support or already supports abstraction).

6. SuDS should be constructed in line with good practice and guidance documents which include the SuDS Manual (CIRIA C753, 2015), Guidance on the Construction of SuDS C768 and the Susdrain website.

7. Further information on the EA requirements with regard to SuDS can be found on the Groundwater protection position statements (2018), in particular Position Statements G1 and G9 - G13 available at:

https://www.gov.uk/government/publications/groundwater-protection-positionstatements
.
Section B point c (Amenity and Biodiversity)

We feel point iii. (Preferred hierarchy) could be amended as follows:

"and if these cannot be met, thirdly, to a surface water sewer, highway drain, or another drainage system and if these cannot be met, to a combined sewer."

The footnote at page 86 refers to the CIRIA manual, the year 2017 should be 2015.

Contaminated Land

Policy NE07 - In section A, point b, the word "local" applied to groundwater might be misleading: it is clear that it's intended for the groundwater underneath the site, but 'local' groundwater does not exist, i.e. contaminated groundwater migrates from a contaminated site and gets transported elsewhere for long distances before getting degraded (if this applies).

We feel you should consider rewording this policy in the following way 'there will be no adverse impact on the wider environment and quantity and quality of controlled waters (surface water and groundwater)'.

We trust this information is useful.

Yours faithfully

Mr. Pat Abbott
Planning Advisor

Planning Department 19th November 2019
Brentwood Borough Council
Dear Sirs,
Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)
Thank you for giving the Ingatestone & Fryerning Parish Council the opportunity to comment on the
Addendum to the LDP. We recognise that the amendments do not alter the Plan's spatial strategy
but seek to respond to concerns in specific areas of the Borough by redistributing housing growth,
and it is in that context that we write.
The last time we commented comprehensively on the LDP, on 3rd March 2016 (copy attached), we
had not begun the evidence gathering for our Neighbourhood Plan, as our Neighbourhood Plan
Advisory Committee was not convened until November 2017. The research on our own housing
needs, relating to our existing 2,000 households and the requirements of our residents for the
planning period the LDP covers, was only started in 2018. We sought to work closely with the
Borough Council recognising that we are one of nine Parishes in the Borough that do not cover the
entire geographical area - the balance being directly managed by the Brentwood Borough Council
itself.
We had attempted to establish what the demand for housing is via Brentwood's own records but
have not succeeded in obtaining a figure. Recently we have learnt that that your planning
department policy team has been discussing local demand but they believe that the figure can only
be based on the proposed development sites within the Regulation 19 Brentwood Local Plan Pre-
Submission draft. Additionally this would include a figure for windfall sites expected in the area
which would account for an additional 5%.
In summary - the proposed housing for our Parish is not based on local demand, but rather on what
a proposed development site could accommodate. Therefore the figure for our Parish would be R22
as the site and 57 dwellings for the yield, plus 5% for the Parish as a whole.
Mountnessing Parish is adjacent to Ingatestone and Fryerning, and has been the subject of
considerable new build housing in the last few years. In the current LDP a further development site
is identified for 161 dwellings, amounting therefore to some 229 units that will be looking towards
our Parish to meet much of its infrastructure needs, namely, pre-schools, schools, health services,
parking, rail services etc. These figures are confirmed in Appendix 1 to your Addendum document.
The LDP does also identify a site for Employment close to both the sites identified above (R21 and
R22). The Parish would wish to work with Brentwood Borough Council and Mountnessing Parish
Council to enable this site to provide some of the infrastructure needs essential to both local
communities.
We look forward to working with you on the implementation of the LDP and being directly involved
in all pertinent discussions.
Yours faithfully
Rosemary Spouge
Assistant Clerk
Ingatestone & Fryerning Parish Council

Remove Sites R25 & R26 from the LDP. Reasons and detailed alternatives are specified in my actual multiple representations.
The questions below refer to DPD, I assume this is a typo and you are referring to the LDP and have answered on that basis.

* The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

Remove R25 and R26 from the plan

Text submitted online.
The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

Increase density of site Allocation R10 Brentwood Railway Station Car Park and reflect this in the Addendum and Regulation 19 Draft Local Plan.

Transport for London Commercial Development
Dear Sir / Madam,
RE: Addendum of Focussed Changes to the Pre Submission Local Plan Consultation
Thank you for providing the opportunity to comment on the Addendum of Focussed Changes to the Pre Submission Local Plan.
Please note that our representations below are the views of the Transport for London Commercial Development (TfL CD) planning team in its capacity as a landowner in the borough only and are separate from any representations that may be made by TfL in its statutory role as the strategic transport authority for London. Our colleagues in TfL Spatial Planning may provide a separate response to this consultation in respect of TfL-wide operational and land-use planning / transport policy matters as part of their statutory duties.
TfL CD works to identify development opportunities throughout our landholdings and unlock underutilised land by pursuing innovative solutions to enable development on our sites. We are committed to providing exemplary development that will show case the Mayors objectives of providing good growth.
Brentwood Railway Station Car Park
Within Brentwood, TfL CD has identified Brentwood Railway Station Car Park as having the potential for residential development which could make a significant contribution towards meeting Brentwood and TfL housing targets.
In written representations dated 14th March 2019 (see attachment 2), we supported the principle of the Strategic Housing Allocation R10: Brentwood Railway Station Car Park, however we did not agree with the approximate capacity of 100 homes for the following reasons:
* This capacity was not in line with the content of the Draft Brentwood Town Centre Design Guide which identified that up to "405 units per hectare is suitable around key transport nodes, such as Brentwood Station."
* Brentwood Railway Station Car Park is a brownfield site, located within a town centre and adjacent to a significant transport interchange. It is, therefore, a prime opportunity to optimise housing delivery in a highly accessible location in line with National Planning Policy Framework (NPPF) paragraphs 103 and 118 (D).
* Feasibility studies indicated that a decked design could allow a greater density to be achieved on the site whilst still providing a compatible and neighbourly form of development.
* The draft site allocation boundary did not include a section of car park towards the east. The whole parcel of land which TfL has an interest in and for which we are exploring development feasibility measures 1.39ha.

Given the above, we suggested that the indicative density was increased. A density of 405 units per hectare would better reflect the sites capacity; if this figure is applied to the site area of 1.39 hectares this would equate to around 560 homes. This is considered a more realistic housing figure for the site, to ensure that the site is fully optimised and the Addendum of Focussed Changes should be amended accordingly.
We would like to emphasise that, as currently drafted, Strategic Housing Allocation R10: Brentwood Railway Station Car Park does not accurately represent the sites housing capacity. It is therefore not encouraging effective land use or optimising the potential for housing delivery on this site and conflicts with Draft London Plan policy H1 (2, a & b) which states that:
'boroughs should optimise the potential for housing delivery on all suitable and available brownfield sites through their Development Plans and planning decisions, especially the following sources of capacity:
a. sites with existing or planned public transport access levels (PTALs) 3-6 or which are located within 800m of a Tube station, rail station or town centre boundary'
b. mixed-use redevelopment of car parks and low-density retail parks'
Furthermore, if development at Brentwood Railway Station Car Park will need to re-provide existing commuter car parking, it is highly likely that higher density residential development would be required to fund the additional infrastructure associated with re-providing the parking, such as decking over the car park level or a multi-storey car park . This would be in line with the draft Brentwood Town Centre Design Guide which sets out that development should aspire to increase the density of the existing Brentwood Station area.
We therefore strongly suggest that as per the above, an increased indicative site capacity is included within the Strategic Housing Allocation R10 to accurately represent the sites housing capacity and support the redevelopment of a highly accessible, optimal site.
Concluding Remarks
We trust that we have provided sufficient information for the Council to be able to consider our representations in respect of the Addendum of Focussed Changes to the Pre

Refer to attached document

None proposed

Re: Land at Blackmore Road (R23) & Land at Stocks Lane (R24)

We welcome the opportunity to submit representations to the above consultation on behalf of Stonebond
Properties Ltd. Stonebond are in control of two sites identified in the Pre-Submission Local Plan, which
includes the Land at Blackmore Road (ref: R23) Land at Stocks Lane (ref: R24). This submission to the
Consultation on the Addendum of Focussed Changes (AFC) is made having regard to representations
submitted at the Regulation stage consultation in March 2019 in respect of both of these sites in so far as the
Addendum has relevance and supports the comments made at that stage.

Previous representations

Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019,
and set out proposed amendments to the wording of the policies associated with the sites proposals to
increase the stated capacity of the sites, as well as amendments to the site boundary of the Blackmore Road
site.

Included with this submission is the further information that was supplied to the Council on 2
September
2019 for the consideration by Policy Resources and Economic Development Committee on 11
nd
September.
The purpose of this additional information was to suggest to the Council that R23 and R24 can accommodate
additional dwellings, over and above the stated yield within the Pre-Submission Local Plan. For ease of
reference, extracts are provided below which illustrate that the sites combined and with the changes sought
could deliver around 42 more homes in total than that currently set out in the Regulation 19 Local Plan:

The information submitted to the Council was intended to promote an opportunity for possible amendments
to the Local Plan before submission for Examination which could have been considered as part of this focused
consultation and it is regrettable that this was not considered acceptable.

The AFC does not respond to any of the recommendations made in the previous representations, nor any of
the proposals set out in the additional information provided to the Council and attached. This representation
reiterates the opportunity for the two sites at Kelvedon Hatch to make a meaningful contribution to
Brentwood's housing needs, particularly to assist in early delivery of homes in the Plan period.

Focused changes

It is acknowledged that the Council are seeking representations focussing on the AFC only with the most
notable change is the reduction in units to be provided by sites R18 and R19 in Shenfield and R25 and R26
in Blackmore, as set out below;

a) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least
2,700" to "at least 2,770 homes in the plan period";
b) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around
35 homes";
c) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45
homes";
d) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to
around "30 homes"; and
e) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to
"around 20".

The AFC explains that the modifications proposed result from a review of consultation responses on the PreSubmission
Local
Plan
on
the
proposed
allocations
R18,
R19,
R25
and
R26,
necessitating
a
reduction
in
the

number
of
homes
for
these
proposed
allocations
(Focussed
Changes
2-5).



The
AFC
proposes
that
the
total
loss
of
70
homes
across
the
four
sites
will
be
off-set
through
an
increase
in

the
number
of
new
homes
to
be
provided
at
Dunton
Hill
Garden
Village
(Focussed
Change
1).

The
AFC

confirms
that
the
overall
number
of
new
homes
will
not
be
increased,
but
that
there
will
be
a
faster
rate
of

delivery

at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than
previously projected (resulting in fewer post-2033).

Representations

Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield,
we do consider that the AFC is a missed opportunity to review the capability of other sites proposed for
allocation in the Local Plan to accommodate the units to be lost at those sites rather than simply adding to
the allocation at Dunton Hills Garden Village.

To support our representations, we draw attention to requirements of the National Planning Policy Framework
(NPPF) that Plans should;

 provide a strategy to meet housing needs with sufficient flexibility to be able to respond to rapid change
(para 11) and
 Housing requirements are to be considered as minimum (para 60).
 Acknowledge the role of small and medium sites to contributing to meeting the housing requirement
(para 68)
 Make efficient use of land (paras 11, 122, and123).

Our submitted representations supporting the allocations for R23 and R24 at pre-submission stage in March
made the case that the medium sized sites at Blackmore Road and Stocks Lane can accommodate a modest
increase in the number of additional dwellings on these sites in line with the Council's spatial strategy.

We note that Appendix 1 to the AFC provides an updated housing trajectory based on the proposed
allocations. For R23 and R24 it indicates that delivery will commence 2021/22. In our representations to the
Pre-Submission Local Plan we indicated that both sites can come forward in 2020 with the delivery of 20 units
to assist the Council's shortfall in 5-year housing supply.

Reviewing Appendix 1, we have reservations that Dunton Hills Garden Village will deliver the number of
homes as soon as 2022/23. Furthermore, reliance on the site for delivery would not provide for flexibility or
acknowledge the role of smaller or medium sites in contributing to early delivery.
There is an acute need for new homes within Brentwood Borough. The provision of new homes within the
early years of the plan period is critical. The AFC proposes that the reduction in supply from sites identified
as contributing to housing delivery from as early as 2020/21 be compensated for by an increase in the number
of new homes to be provided between 2030/31 and 2032/33. In short, it is identifying that fewer homes will
be delivered in the early years of the plan period and it is proposed to rectify this through increasing delivery
at the end of the plan period. Such an approach is, in our view inappropriate, and contrary to the NPPF's call
to significantly boost the supply of homes. This makes the early delivery of sites such as R23 and R24 entirely
credible and our proposals for the modest increase in homes that can be delivered is important to the identified
housing requirement.

Summary

This letter has set out our views on the focussed changes to the Draft Local Plan, with particular emphasis
on the role that the identified sites at Land of Stocks Lane and Land of Blackmore Road (R24 & R25
respectively) can assist the Council in meeting its requirements ahead of the Local Plan Examination.

As set out in this letter, we are responding to the contents of the AFC and specifically the housing trajectory
and redistribution of housing as identified. To support our comments, we are resubmitting the representations
previously made with regard to the two site's under Stonebond's control in Kelvedon Hatch. We reiterate
points made at Pre-submission stage that both of these sites can accommodate additional homes above the
number they are identified to assist the Council in meeting its requirement for new housing at early stages of
the Plan period, which is of critical importance given the position with the Council's 5 year housing land supply
shortfall.

Furthermore, the Pre-submission stage was prepared before publication of the revised NPPF in February
2019 which introduced important changes to the approach to identifying housing land supply and greater
emphasis on the efficient use of land. Both of these matters clearly indicate that our proposals for R23 and
R24 would be compatible with national planning policy objectives and provide justification for a review of
capacity of these sites and confirmation for early delivery against the issues we identify with the both the
timing of supply and redistribution of housing set out in the AFC.

We would welcome further liaison with the Council regarding the opportunities expressed in this and our
previous representations as the Local Plan proceeds to the examination stage. In particular, we would be
more than happy to present to the Examination a Statement of Common Ground (SoCG) with the Council to
reflect our proposals. The SoCG would confirm that sites R23 and R24 are available, suitable, and sustainable
to aid the Council to confirm certainty of early delivery. We believe that our proposals also provide for flexibility
in sources of supply to assist in the housing land requirement for the Borough.

I would be grateful to receive acknowledgment of this representation. If you require any further information,
please do not hesitate to get in touch.

Yours sincerely,
Andy Butcher

update your trajectory at Appendix 1 to reflect the fact RHL could deliver homes from year 2020/21 rather than 2021/22 as currently listed. This would tie in with another garden centre that you have proposed for allocation (R07), which is also in the Green Belt but that your records indicate as not being the subject of an application (current or otherwise). R07 is identified as delivering from 2020/21 and given the advanced stage that RHL is at, R21 should also be identified as starting delivery in the same year.

Dear Sir/Madam

Thank you for the opportunity to comment on the Addendum of Focussed Changes to the Pre Submission Local Plan (Regulation 19, February 2019).

I represent Redrow Homes Ltd (RHL), who has an interest in emerging site allocation R21 (Ingatestone Garden Centre). I have previously submitted comments to earlier versions of the plan on behalf of RHL and these comments remain valid.

My comment to the addendum document relates to Appendix 1 of that document and the absence of any change to the proposed trajectory in relation to this site.

As you know, RHL has a current application submitted for the redevelopment of Ingatestone Garden Centre (part of R21). That application is well-advanced and is currently held up by the plan-making process. RHL repeats its desire to commence development of this site at the earliest opportunity and reminds you that it is the legal owner of the land. It is an established house-builder, willing and able to deliver homes at this site as soon as the Council can grant it permission to do so.

I therefore write to request that you update your trajectory at Appendix 1 to reflect the fact RHL could deliver homes from year 2020/21 rather than 2021/22 as currently listed. This would tie in with another garden centre that you have proposed for allocation (R07), which is also in the Green Belt but that your records indicate as not being the subject of an application (current or otherwise). R07 is identified as delivering from 2020/21 and given the advanced stage that RHL is at, R21 should also be identified as starting delivery in the same year.

The prompt delivery of sites such as Ingatestone Garden Centre will be crucial in ensuring that your Council can make significant in-roads in the current housing land supply deficit. RHL remains at your service to assist you in demonstrating to the Inspector how it can help you in this regard.

Yours faithfully

Nicky Parsons
Executive Director

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

Brentwood Local Plan - Regulation 19 Focussed Consultation
This letter has been prepared by Strutt & Parker on behalf of Countryside Properties, in respect of their land interests in Brentwood and in particular, the following three sites that have been promoted to date as part of the emerging Local Plan:
1. Land at Chelmsford Road, Shenfield (Ref: R03)
2. Land at Doddinghurst Road, Brentwood (Ref: Policy R16 & R17)
3. Land at Bayleys Mead, Hutton
Representations were made on the Pre-Submission Local Plan (Reg 19) in relation of all three of the above sites. Countryside Properties hereby provide consent that their personal contact details, and those of their planning agent, Strutt & Parker, can be shared with the Planning Inspectorate and Programme Officer for the purposes of administering the Examination of the Local Plan when it is submitted by the Council.
Allocation of Unit Numbers
Whilst Countryside Properties can confirm their support of the draft Local Plan in principle, and in particular the allocation of land at Chelmsford Road and Doddinghurst Road for residential development, it is noted that the Focussed Changes relate exclusively to the reduction of unit numbers on 4 sites that are proposed for allocation within the Pre-Submission Local Plan, and the respective increase of the number of homes proposed for delivery as part of Dunton Hills Garden Village to accommodate the reductions.
Countryside Properties remain concerned in relation to an over-reliance on large scale strategic development for the provision of housing over the Plan period (2033). Brentwood Borough Council should protect those sites that are immediately available for the short term delivery of housing within the early stages of the Local Plan period.
Should there be specific reasons why the 4 sites have a lower capacity than initially understood, alternative sites proposed for allocation, such as land at Chelmsford Road and Doddinghurst Road have sufficient capacity to accommodate an increase in unit numbers to protect overall housing delivery numbers for the Borough. This would help to balance the reliance on Dunton Hills Garden Village for housing delivery whilst ensuring the efficient use of small to medium scale sites which are available to deliver housing immediately.
Countryside are able to confirm an intention for the three developer parties with land interests at Shenfield to agree a Statement of Common Ground, which is expected to provide further reassurance of the short term delivery of this particular allocation in due course.
It should also be acknowledged that no growth of the sustainable settlement of Hutton has been proposed, despite its sustainability credentials and offering of small scale development sites such as land at Bayleys Mead. Such sites currently make a negligible contribution to the Green Belt and would not contribute to coalescence of settlements given the scale and enclosed nature of the site, as has been demonstrated in information submitted alongside previous representations at earlier stages of this Local Plan.
Policy R03
In addition to the comments above, we have also previously raised a recommendation for policy wording relating to an inflexible provision of employment land (2ha) to be amended or removed. This is in respect of an over-provision of employment land that has been allocated in comparison to the need identified within the Plan, and also in the interests of providing an employment use at Chelmsford Road that best meets the market demand and Borough Council objectives for this site.
Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location.
Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature, or be desirable in this edge of settlement location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area, and would also have implications on the A12 gyratory through the associated movements of HGVs and other vehicles.
We are aware of interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognised however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land.
The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. Countryside Properties are confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location. As such, the provision of 2ha of land for employment purposes should be removed from the policy.
Policy R16 & R17
Countryside maintain concerns over the amendment to the wording of Policy R16 & R17 that was made without justification during the previous iteration of the draft Local Plan. 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.
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. The use of these accesses may also better support the design of scheme that is fully integrated with existing development.
Countryside continue to support Brentwood in the progression of their Local Plan, but wish to emphasise the continuing importance of minor amendments to specific policies, alongside the need for consistent housing delivery across the entire Plan period. This is important to ensure that the Plan is deliverable and found sound at Examination.

Brentwood Local Plan - Regulation 19 Focussed Consultation
This letter has been prepared by Strutt & Parker on behalf of Countryside Properties, in respect of their land interests in Brentwood and in particular, the following three sites that have been promoted to date as part of the emerging Local Plan:
1. Land at Chelmsford Road, Shenfield (Ref: R03)
2. Land at Doddinghurst Road, Brentwood (Ref: Policy R16 & R17)
3. Land at Bayleys Mead, Hutton
Representations were made on the Pre-Submission Local Plan (Reg 19) in relation of all three of the above sites. Countryside Properties hereby provide consent that their personal contact details, and those of their planning agent, Strutt & Parker, can be shared with the Planning Inspectorate and Programme Officer for the purposes of administering the Examination of the Local Plan when it is submitted by the Council.
Allocation of Unit Numbers
Whilst Countryside Properties can confirm their support of the draft Local Plan in principle, and in particular the allocation of land at Chelmsford Road and Doddinghurst Road for residential development, it is noted that the Focussed Changes relate exclusively to the reduction of unit numbers on 4 sites that are proposed for allocation within the Pre-Submission Local Plan, and the respective increase of the number of homes proposed for delivery as part of Dunton Hills Garden Village to accommodate the reductions.
Countryside Properties remain concerned in relation to an over-reliance on large scale strategic development for the provision of housing over the Plan period (2033). Brentwood Borough Council should protect those sites that are immediately available for the short term delivery of housing within the early stages of the Local Plan period.
Should there be specific reasons why the 4 sites have a lower capacity than initially understood, alternative sites proposed for allocation, such as land at Chelmsford Road and Doddinghurst Road have sufficient capacity to accommodate an increase in unit numbers to protect overall housing delivery numbers for the Borough. This would help to balance the reliance on Dunton Hills Garden Village for housing delivery whilst ensuring the efficient use of small to medium scale sites which are available to deliver housing immediately.
Countryside are able to confirm an intention for the three developer parties with land interests at Shenfield to agree a Statement of Common Ground, which is expected to provide further reassurance of the short term delivery of this particular allocation in due course.
It should also be acknowledged that no growth of the sustainable settlement of Hutton has been proposed, despite its sustainability credentials and offering of small scale development sites such as land at Bayleys Mead. Such sites currently make a negligible contribution to the Green Belt and would not contribute to coalescence of settlements given the scale and enclosed nature of the site, as has been demonstrated in information submitted alongside previous representations at earlier stages of this Local Plan.
Policy R03
In addition to the comments above, we have also previously raised a recommendation for policy wording relating to an inflexible provision of employment land (2ha) to be amended or removed. This is in respect of an over-provision of employment land that has been allocated in comparison to the need identified within the Plan, and also in the interests of providing an employment use at Chelmsford Road that best meets the market demand and Borough Council objectives for this site.
Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location.
Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature, or be desirable in this edge of settlement location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area, and would also have implications on the A12 gyratory through the associated movements of HGVs and other vehicles.
We are aware of interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognised however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land.
The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. Countryside Properties are confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location. As such, the provision of 2ha of land for employment purposes should be removed from the policy.
Policy R16 & R17
Countryside maintain concerns over the amendment to the wording of Policy R16 & R17 that was made without justification during the previous iteration of the draft Local Plan. 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.
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. The use of these accesses may also better support the design of scheme that is fully integrated with existing development.
Countryside continue to support Brentwood in the progression of their Local Plan, but wish to emphasise the continuing importance of minor amendments to specific policies, alongside the need for consistent housing delivery across the entire Plan period. This is important to ensure that the Plan is deliverable and found sound at Examination.

Strategic Planning Team
Publication of Brentwood Borough Council's Addendum of Focussed Changes to the Pre-Submission Local Plan, its accompanying updated Sustainability Appraisal and Habitats Regulations Assessment.
Thank you for notifying us about the above consultation. Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Highways England will be concerned with proposals that have the potential to impact on the safe and efficient operation of the Strategic Road Network (SRN), in this case the A12 and M25 Junctions 28 and 29. We have examined the consultation documents and given the scope of the Focussed Changes we have no comments at the present time.
In terms of the sustainability appraisal, it is worth stating that a growing concern to us is air quality and the impact of development traffic contributing to emissions from traffic on the SRN. We note that Paragraph 9.2.7 of the Sustainability Appraisal Report lists a number of wide ranging policies in pursuit of air quality objectives. We shall be paying particular attention to air quality matters in future and stress the need for appropriate monitoring.
We will continue to cooperate separately with Brentwood Officers in relation to the transport assessment of your Local Plan concerning the M25 and A12.
We hope that you find these comments useful. Please do not hesitate to contact us at planningse@highwaysengland.co.uk should you need more information or clarification.
Heather
Heather Archer, Assistant Spatial Planning Manager
Highways England | 1st Floor, Bridge House | Walnut Tree Close | Guildford | GU1 4LZ

Smith Jenkins Ltd act for McColl's Retail Group plc.
On behalf of our client we are instructed to make representations to the focussed changes made to the pre-submission draft of the Brentwood Local Plan, which we understand have been published for comment until 26th November 2019.
This response should be read in conjunction with our client's representations on the original pre-submission Local Plan, dated 19th March 2019. Both representations concern our client's headquarters at McColls House, Ashwells Road, Pilgrims Hatch, and have been prepared in order to assist the Local Authority.
We note that the focussed changes are not exhaustive and concern only five policies regarding particular allocations or sites that were already included in the pre-submission draft of the Local Plan. We have no comments on the necessity of the adjustments in housing figures that are proposed, although note that these are very minor in scale. For example, the changes to the Dunton Hills Garden Village allocation is equivalent to just a 2.5% increase in housing whilst other adjustments concern only 10 homes being deducted from allocations.
This is in marked contrast to the circumstances affecting our client's site, which, as outlined in our 19th March representation was identified as an existing employment site in the Green Belt that is effectively reserved for B-class uses under emerging Policy PC03.

Our client previously advocated the removal of their site from this policy on the grounds that it is neither effective nor positively-prepared. To confirm, this is still our client's position although this is now augmented by new information that must be considered by the Council in proceeding with the Local Plan.
On 13th September 2019, Brentwood Borough Council gave its Prior Approval for the change-of-use of our client's offices to create 55 dwellings (application reference 19/01043/PNCOU; see Appendix 1 for Decision Notice). The Council will be aware that our client has subsequently engaged in pre-application discussions for an alternative purpose-built scheme of 39 dwellings. Our client will implement one or the other of these schemes in the near future, meaning their site will be lost to employment purposes. As outlined in previous representations, the site is poorly suited to modern business use but nevertheless the loss of employment land is more than offset by the significant windfall boost to the Council's housing land supply and the efficient re-use of previously-developed land in a sustainable location.
This context not only renders the site's inclusion in Policy PC03 further unsound, but also affects the housing requirement and extant permissions in the emerging Local Plan to a greater extent than any of the proposed focussed changes. We would therefore respectfully request that the Local Plan be further amended to reflect this, either through an additional focussed change, or by way of modification at Examination stage. It is understood that the Council may have previously declined to do so on the grounds that only limited information was available as to the site's likely future. However, given our client's clear intent to use the site for residential purposes, and the extant Prior Approval allowing them to do so in principle, this matter clearly needs to be revisited in order for both the employment and housing provision within the Local Plan to be up-to-date and sound.
Please retain or add Smith Jenkins Ltd to any consultation database that is being used to publicise future Local Plan updates.
Should you require any further information regarding any of the matters in this representation, please do not hesitate to contact me or Jennifer Smith at this office.

Remove McColl's site (ref 321) from existing employment site as set out in Policy PC03, either through an additional focussed change, or by way of modification at Examination stage.

Smith Jenkins Ltd act for McColl's Retail Group plc.
On behalf of our client we are instructed to make representations to the focussed changes made to the pre-submission draft of the Brentwood Local Plan, which we understand have been published for comment until 26th November 2019.
This response should be read in conjunction with our client's representations on the original pre-submission Local Plan, dated 19th March 2019. Both representations concern our client's headquarters at McColls House, Ashwells Road, Pilgrims Hatch, and have been prepared in order to assist the Local Authority.
We note that the focussed changes are not exhaustive and concern only five policies regarding particular allocations or sites that were already included in the pre-submission draft of the Local Plan. We have no comments on the necessity of the adjustments in housing figures that are proposed, although note that these are very minor in scale. For example, the changes to the Dunton Hills Garden Village allocation is equivalent to just a 2.5% increase in housing whilst other adjustments concern only 10 homes being deducted from allocations.
This is in marked contrast to the circumstances affecting our client's site, which, as outlined in our 19th March representation was identified as an existing employment site in the Green Belt that is effectively reserved for B-class uses under emerging Policy PC03.

Our client previously advocated the removal of their site from this policy on the grounds that it is neither effective nor positively-prepared. To confirm, this is still our client's position although this is now augmented by new information that must be considered by the Council in proceeding with the Local Plan.
On 13th September 2019, Brentwood Borough Council gave its Prior Approval for the change-of-use of our client's offices to create 55 dwellings (application reference 19/01043/PNCOU; see Appendix 1 for Decision Notice). The Council will be aware that our client has subsequently engaged in pre-application discussions for an alternative purpose-built scheme of 39 dwellings. Our client will implement one or the other of these schemes in the near future, meaning their site will be lost to employment purposes. As outlined in previous representations, the site is poorly suited to modern business use but nevertheless the loss of employment land is more than offset by the significant windfall boost to the Council's housing land supply and the efficient re-use of previously-developed land in a sustainable location.
This context not only renders the site's inclusion in Policy PC03 further unsound, but also affects the housing requirement and extant permissions in the emerging Local Plan to a greater extent than any of the proposed focussed changes. We would therefore respectfully request that the Local Plan be further amended to reflect this, either through an additional focussed change, or by way of modification at Examination stage. It is understood that the Council may have previously declined to do so on the grounds that only limited information was available as to the site's likely future. However, given our client's clear intent to use the site for residential purposes, and the extant Prior Approval allowing them to do so in principle, this matter clearly needs to be revisited in order for both the employment and housing provision within the Local Plan to be up-to-date and sound.
Please retain or add Smith Jenkins Ltd to any consultation database that is being used to publicise future Local Plan updates.
Should you require any further information regarding any of the matters in this representation, please do not hesitate to contact me or Jennifer Smith at this office.

Add Salmonds Grove to the local plan.

Land at Salmonds Grove, Ingrave
Strutt & Parker on behalf of BPM Investments Ltd
November 2019
Consultation Response - Brentwood Local Plan Addendum of Focussed Changes
1
1.0 Introduction and Background
1.1 This representation on the Brentwood Borough Council's Addendum of Focussed Changes (AFC) to the Pre Submission Local Plan (PSLP) is made by Strutt & Parker on behalf of BPM Investments ltd.
1.2 BPM Investments hold the promotion agreement for Salmonds Grove, Ingrave. The site has been promoted to the Council through the previous Local Plan consultations including objections to the Regulation 19 PSLP Consultation. The site is identified in those earlier Representations. The site has been considered by the Council through its Strategic Housing Land Availability Assessment (SHLAA) 2011, the Site Specific Sustainability Appraisal (SA), and the January 2018 Site Assessment Methodology, under Site Ref. 067a and 067b. Representations to the Regulation 18 consultation were also submitted highlighting many of the same concerns raised at Regulation 19.
1.3 The site is on land currently allocated as Green Belt in the Brentwood Replacement Local Plan (2005) and is immediately adjacent to the settlement boundary of Ingrave and Herongate. The site is in a sustainable position on the eastern boundary of Ingrave, in an area of residential character, and would make a logical extension to the settlement boundary for a modest number of dwellings. The suitability of the Site for delivery of dwellings in the early period of the Plan with negligible impact on the Green Belt and surrounding landscape is pertinent to the AFC consultation.
1.4 Concerns regarding the soundness of the PSLP as set out in our representations remain, and are not repeated here to avoid duplication. This representation focuses on the proposed focussed changes to the PSLP, set out in the AFC. These comprise the following:
1. Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,700" to "at least 2,770 homes in the plan period";
2. Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";
3. Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";
4. Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"; and
5. Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
2
1.5 The AFC explains that the modifications are proposed due to concerns raised through consultation on the PSLP relating to proposed allocations R18, R19, R25 and R26, necessitating a reduction in the number of additional homes these proposed allocations can suitably accommodate (Focussed Changes 2-5).
1.6 The AFC explains that the total loss of 70 homes across the four aforementioned sites will be off-set through proposed focussed change to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the AFC does confirm that the overall number of new homes will not be increased, merely that there will need to be a faster rate of delivery at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than previously projected (para.5 AFC).
1.7 A critical matter raised in our previous representations is the over reliance of large strategic allocations that inevitably take a considerable time to bring forward (para. 2.28-2.34 and appendix 3 and 4 of our PSLP representations). The AFC exacerbates this failing by increases the proportion of development to be delivered at the strategic allocation of DHGV, from 34.6% of the total housing (44.3% of allocations) to 35.6% (45.5% of allocations)(see: AFC p.7; amendments to Figure 4.2).
1.8 To emphasise the impact of this approach, and the validity of our previous representations on this matter, changes are required to the delivery rate for new homes and is set out in the changes to the Housing Trajectory (AFC pp.10-15). This confirms a reduction in delivery rates until 2026/27 which is only accounted for in the final three years of the Plan (2030/31-2032/33). This is considered to be a distict failure of the Plan especially when alternative sites exist that can better meet the shortfall in the short term.
1.9 We therefore have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply stating that Dunton Hills Garden Village will deliver at a greater rate than previously suggested, at just a fast enough rate to account for the shortfall created by the need to reduce the proposed capacities for site R18, R19, R25, and R26.
1.10 The PSLP as amended by the AFC remains unsound. However, in our view it is capable of being made sound. Our concerns and suggested approach to addressing these is set out in this representation.
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2.0 Concerns with proposed focussed changes
2.1 The AFC identifies that the number that proposed allocations R18, R19, R25 and R26 will deliver is required to be reduced by a total of 70 from the figure identified in the PSLP.
2.2 The AFC explains that the justification for this reduction is, in short, that these four sites are no longer considered suitable to accommodate the quantum of development identified in the PSLP.
2.3 We have no details of the evidence supporting this view, providing a revised assessment of the sites' capacities; and none appear to have been published as part of the consultation.
2.4 However, it must be recognised that the NPPF requires:
a) Local Plans to provide a strategy to meet housing needs with sufficient flexibility to be able to respond to rapid change; and
b) Housing requirements to be considered as minimums.
2.5 In light of the above requirements, it is necessary for the Council to take a conservative and precautionary approach in assessing the potential capacity of sites for housing for the purposes of demonstrating that the strategy will meet housing needs. This does not of course mean that policies should restrict capacities, merely that the trajectory should not be overly optimistic.
2.6 As such, regardless of whether the proposed focussed changes to R18, R19, R25 and R26 are ultimately implemented following the current consultation, the trajectory accompanying the Local Plan cannot rely on these sites to deliver the number of dwellings originally proposed in the PSLP.
2.7 In terms of the AFC's proposed solution to addressing the shortfall resulting from the revised assessment of proposed allocations, this is evidently unsound - it is neither justified, consistent with national policy nor effective. Furthermore, it fails to ensure the Local Plan can be considered positively prepared.
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Projected First Year of Completions for Dunton Hills Garden Village
2.8 Appendix 1 to the PSLP provided a housing trajectory based on the proposed allocations. This suggested that 100 dwellings will be completed at Dunton Hills Garden Village in 2022/23. From 2023/24, projected completions fluctuated between 150 and 300 dwellings per annum. Section 2 of our representations considered this in some detail.
2.9 The AFC sets out a revised trajectory to respond to the proposed focussed changes. This shows no change to the number of dwellings projected for DHGV in any year between 2022/23 and 2029/30, and that the first homes (totalling 100 for the year) will still be completed in 2022/23.
2.10 Within our representations on the PSLP we explained that it was wholly unrealistic to suggest that 100 dwellings could be delivered at Dunton Hills Garden Village as soon as 2022/23 (see paragraphs 2.24-2.33). We provided details of two current projects by Arebray Development Consultancy and advised that large strategic sites will take longer to deliver that smaller sites, highlighting a scheme with no major constraints taking 3yrs to deliver the first dwellings after outline permission had been granted. This is supported by other delivery reviews, such as the study by NLP - Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? (November 2016).
2.11 At the time of our PSLP representations, the delivery of DHGV was based on an optimistic assumption that the Brentwood Borough Local Plan would be adopted in 2019. Clearly there is now no such prospect.
2.12 Given the delays to the Local Plan process, and assuming - optimistically - that the Brentwood Borough Local Plan will be adopted in 2020, the trajectory should not show completions at Dunton Hills Garden Village early in the Plan unless robust evidence can be provided to demonstrate that it will come forward quicker than other schemes of comparative size.
2.13 Not only does the above give rise to significant concerns that the PSLP will not ensure housing needs are met in the early years of the plan period, it demonstrates that it would be entirely inappropriate or the AFC to identify DHGV as delivering a greater number of homes by 2033 than the PSLP did. Indeed, the changes proposed in the AFC should have reduced the delivery of homes at DHGV within the Plan period, not increase it.
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Proposed Changes to Dunton Hill Garden Village Delivery Rate
2.14 The housing trajectory within the AFC shows that the number of dwellings per annum to be delivered at Dunton Hills Garden Village will increase from 250 to 275 for 2030/31 and 2031/32, and from 250 to 270 in 2032/33.
2.15 However, no evidence has been presented as justify the increase in projected delivery rate for these years.
2.16 The projected delivery rates for Dunton Hill Garden Village set out within the PSLP were already ambitious - the NLP study referred to above found that the average delivery rate for schemes comprising over 2,000 dwellings was 161 dwellings per annum. Indeed, the analysis shows that the biggest schemes will 'on average,
2.17 deliver fewer than 200 dwellings per annum'. The DHGV proposals would, if realised, exceed the sales rates identified at the Eastern Expansion Area for Milton Keynes (268pa). Specific circumstances for this delivery are explained in a case study within the same report, stating that:
'Serviced parcels with the roads already provided were delivered as part of the Milton Keynes model and house builders are able to proceed straight onto the site and commence delivery. This limited the upfront site works required and boosted annual build rates. Furthermore, there were multiple outlets building-out on different serviced parcels, with monitoring data from Milton Keynes Council suggesting an average of c.12 parcels were active across the build period. This helped to optimise the build rate.' (NLP Start to Finish (November 2016 p.15)
2.18 There is no indication that a similar approach will be taken at DHGV in order to secure such high annual rates of delivery. This is particularly the case from such an early stage in the Plan following adoption for a site that would need to be released from the Green Belt (the rate increases to 250pda in 2024/25 and 300pa from 2026/27, decreasing to 275 in 2030/31).
2.19 The additional increase proposed by the AFC is not justified; is ineffective in ensuring delivery; and risks a shortfall in the timely provision of housing, rendering the Local Plan inconsistent with the NPPF and incapable of being considered positively prepared.
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Delivery of Homes Delayed and Five-Year Housing Land Supply
2.20 There is an acute need for new homes within Brentwood Borough. The provision of new homes within the early years of the plan period is critical.
2.21 As we noted at paragraph 31 of our representations on the PSLP, the Borough is currently significantly short of having a five-year housing land supply as required by the NPPF. It would be wholly inappropriate to delay provision of housing.
2.22 The AFC proposes that the reduction in supply from sites identified as contributing to housing delivery from as early as 2020/21 be compensated for by an increase in the number of new homes to be provided between 2030/31 and 2032/33. In short, upon identifying that fewer homes will be delivered in the early years of the plan period, it is proposed to rectify this through increasing delivery at the end of the plan period. Such an approach is, in our view, wholly inappropriate, and contrary to the NPPF's call to significantly boost the supply of homes.
2.23 We identified within our PSLP representations that the PSLP would not ensure a five-year housing land at all points in the plan period (particularly in the early years). Rather than rectify this defect such that the Local Plan is capable of being found sound, the AFC merely exacerbates this flaw.
Reliance on Dunton Hills Garden Village
2.24 As noted above, the Local Plan is not simply required to provide a strategy for meeting development needs - the NPPF requires it to be sufficiently flexible to be able to respond to rapid change. As such, it is critical that the Local Plan is not overly reliant on a limited number of sites.
2.25 However, the PSLP is heavily reliant on Dunton Hills Garden Village to meet development needs with 34.6% of housing being delivered at the Garden Village, and 44.3% of all allocations. Rather than address this concern, the AFC has simply placed even greater reliance on Dunton Hills Garden Village to meet the Borough's needs with 35.6% of all development at the Garden Village (45.5% of allocations - AFC p.7; amendments to Figure 4.2).
2.26 Such a heavily reliance on a single allocation is neither effective nor consistent with national policy and does not provide flexibility in the Plan. The AFC compounds this failure.
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Summary of Concerns
2.27 The Council acknowledges four proposed sites may not be able to suitably accommodate the numbers previously cited in the PSLP. As such, the Local Plan housing trajectory must be amended to reflect these doubts, and suitable contingency measures should be put in place. Such measures are necessary irrespective of whether or not the policies relating to these four proposed allocations are modified to refer to the quantum of development the Council now consider the sites suitable to accommodate.
2.28 The modifications proposed by the AFC fail to ensure the Local Plan is capable of being found sound. The modifications place further reliance on one site (Dunton Hills Garden Community) to meet development needs, and further reduce the ability of the Local Plan to be able to respond to changing circumstances.
2.29 There is no justification for the suggestion that the delivery rate of Dunton Hills Garden Village can be increased for the three years the AFC suggests, and the number of new homes delivered through this site through the plan period increased. The assumed delivery rate prior to the AFC was already ambitious. In addition, the projected first year for completions is looking increasingly unrealistic given the delays to the Local Plan.
2.30 The AFC acknowledges that fewer dwellings will be delivered by the PSLP in the early years of the plan period, but the proposed increase to compensate for this is not until the end of the plan period, leaving a shortfall in the short term.
2.31 The AFC not only fails to ensure the Local Plan is sound, but it actually exacerbates problems that were present in the PSLP.
2.32 We consider the issues acknowledged within the AFC can be addressed and the PSLP can be made capable of being found sound. We set out the suggested approach to achieving this within Section 4 of this representation.
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3.0 Other Soundness Concerns Resulting from Delays to the Local Plan
3.1 We noted at para 2.11-2.12 of our PSLP representations that the NPPF requires strategic policies to look ahead over a minimum of 15 years from the date of adoption. Within the same paragraphs we noted that an additional 2 years' worth of development should be planned for given the likely timescales for adoption. As the district is predominantly Green Belt and NPPF requires Local Plans to ensure that the Green Belt will endure beyond the plan period, policies should account for needs beyond this period.
3.2 It is now clear that the Local Plan will not be adopted in 2019. As such, the Local Plan's strategic policies are, as currently proposed, falling short of the required period from adoption. This is evidently contrary to the NPPF's requirement to cover a minimum of 15 years. This could have been addressed in the focused changes.
9
4.0 Modifications to Address Concerns
4.1 In order to address the issues set out above, it is considered necessary to ensure the Local Plan compensates for the reduction of 70 dwellings that will now not be delivered in the early years of the plan, by identifying whether other suitable, available and deliverable sites are available that could also deliver early in the Plan period. This necessitates identifying additional allocation(s).
4.2 As a site capable of delivering between 24 dwellings (SHLAA Appendix 6; site 67a) and 50 dwellings (SHLAA Appendix 6; Site 67b), Salmonds Grove represents an ideal site to respond to the above.
4.3 As set out within our representations on the Local Plan, the Council already has sufficient evidence to demonstrate that site 67a (and 67b) are suitable, available, and achievable for residential development, either site can be delivered in the short term and an allocation would be justified, effective, consistent with national policy, and contribute towards ensuring the Local Plan is positively prepared.
4.4 It is also essential that the PSLP is amended to ensure the Local Plan will contain strategic policies which cover at least 15 years.
4.5 The above changes are considered to be necessary in relation to the matters addressed by the AFC. Our concerns in respect of the soundness of the PSLP in relation to other matters are set out in our earlier representations.

Further clarification is required on delivery of the cycle ways structure along the A127 in either physical and monetary terms. Further clarification is required on how funding will be apportioned to developers for these works as this may impact upon the viability and delivery of the employment allocation at Childerditch Industrial Estate. Welcome a discussion with Officers prior to the submission of the Plan and in this respect, we would be happy to enter into a Statement of Common Ground with BDC in the lead up to the Examination of the Plan, to confirm the deliverability of the proposed allocation.

These representations have been prepared by Strutt & Parker on behalf of Childerditch Properties for Brentwood Borough Council's (BBC) Consultation on the Addendum of Focussed Changes (AFC) to the Regulation 19 Pre-Submission Local Plan (PSLP) and in particular, with regards to our client's land interest on the proposed allocation at Childerditch Industrial Estate (draft Policy E12).
Childerditch Properties request the right for Strutt & Parker or any other professional advisor acting on their behalf to provide further responses in Hearing Statements or at the relevant sessions of the Examination in Public following the submission of the PSLP.
Childerditch Properties are the sole owners of Childerditch Industrial Estate. Representations have previously been made on their behalf in respect of the site throughout the Plan making process, including at the Call for Sites stage, as part of the 2013 Preferred Options Consultation and, most recently, as part of the main PSLP Regulation 19 Consultation in March 2019.
Given that this is a focussed Consultation, this representation will focus on the documents published with the AFC and other points made within our previous representations are not repeated here.
Background
Whilst it is noted that this Consultation focusses on the redistribution of housing growth planned within the Borough, we are aware that the supporting Infrastructure Delivery Plan (IDP) was updated in October 2019 and published as part of the AFC, and therefore our comments focus on this document.
Within our representations to the Regulation 19 Consultation, we provided commentary on the IDP published by BBC for the Borough at that time. The IDP includes, at Figure 3.14 of Chapter 3, a sustainable transport plan for the Southern Growth Corridor affecting Childerditch Industrial Estate, which includes indicative locations for new cycle ways and a new bus route to connect Childerditch Industrial Estate, Brentwood Enterprise Park, Dunton Hills Garden Village and West Horndon Industrial Estate (to be redeveloped).
Comments
As set out within our previous representations, we support the principle of improving walking and cycling links within the land owned by our client, which extends to Little Warley Hall Lane. However, we would still question the extent to which these new cycle ways could be delivered along the A127 corridor, as this would require every land owner to be committed to this initiative.
We previously queried who would be responsible for delivering the cycle way infrastructure improvement and it has since been confirmed within the Part B Schedule of the IDP that this will be Essex County Council (ECC). However, we are concerned that we have not been party to discussions with BBC or ECC on how this new cycle way may be delivered in either physical and monetary terms. We consider that further clarification is required on this prior to the submission of the Plan.
The Part B Schedule of the IDP provides an indicative cost for delivering the cycle way improvements, which is noted as being £7,000,000 and states that the provisional funding sources will be from Section 106/CIL. What is not clear is what proportion of these costs would be secured from developers and how much would be funded by BBC and/or ECC. This requires further clarification to provide greater certainty on delivery. It should be noted that within Chapter 3 of the IDP, these cycle way improvements are given the reference T16, but within the Part B Schedule they are given the reference T17. These anomalies also exist for other items of infrastructure identified within the IDP.
In addition to the cycle way improvements, the IDP identifies additional infrastructure that is expected to be funded by developers (to what extent is unknown). This includes the creation of a new 'West Horndon Transport Interchange', new 'Bus Route Infrastructure' and 'West Horndon Public Realm Improvements'. Further clarification is required on how funding will be apportioned to developers for these works.
Our concern is that if our client is required to provide a disproportionate contribution toward these infrastructure works through a Section 106 Agreement, this may impact upon the viability and delivery of the employment allocation at Childerditch Industrial Estate. Not only does our submission at Regulation 19 relate to the provision of new employment units at the Estate, but also the redevelopment of the existing Estate. It is my client's intention to provide a more efficient and effective layout, which will create additional floor space for new employment opportunities, as demonstrated within the proposed masterplan copied at Appendix 1 of our representations to the PSLP. These works represent a significant investment and cost for our client. It will therefore be important to ensure that contributions to infrastructure improvements are reasonable, necessary and directly relate to the allocation to ensure our plans for the Estate can come forward. We would therefore welcome a discussion with Officers on this point prior to the submission of the Plan and in this respect, we would be happy to enter into a Statement of Common Ground with BDC in the lead up to the Examination of the Plan, to confirm the deliverability of the proposed allocation.
In conclusion, we continue to strongly support the proposed allocation at Childerditch Industrial Estate, as set out in our representations to the PSLP, and will continue to promote the Estate as the Plan progresses to Examination in Public, in consultation with BBC and key stakeholders. We will also seek to prepare a Statement of Common Ground with BBC to set out clarity on the proposed allocation, including agreed objectives for the site and delivery requirements, including matters relating to the provision of necessary infrastructure. In this respect and having regard to the infrastructure identified within the IDP for the Southern Growth Corridor, we seek greater certainty on how this will be delivered, in both physical and monetary terms. We have not been party to discussions with BBC or ECC on this and would therefore welcome a discussion with Officers on this point prior to the submission of the Plan. Should Officers wish to contact me to discuss these matters further, please do not hesitate to contact me on the details at the head of this letter.

Your Ref: Notification of Brentwood Borough Council Local Plan Consultation.
Our Ref: 298186

Dear Phil Drane,
Publication of Brentwood Borough Council's Addendum of Focussed Changes to the Pre-Submission Local Plan, its accompanying updated Sustainability Appraisal and Habitats Regulations Assessment.
We note the changes listed in the above documents and the rebalancing of housing numbers towards Dunton Hills Garden Village.
We do not consider the modifications significantly change our position submitted to the Council as part of Reg 19 consultation, via email on 5th April 2019 (Our Ref 272769).
If you wish to discuss any of the above in more detail please do not hesitate to contact us again.
Thank you.
Yours sincerely
Laura Chellis

Thank you for your e-mail dated October 15 2019 advising of the preparation of focussed changes to the Brentwood Local Plan and the associated public consultation on these from October 16 to November 26 2019.

The consultation documents linked to the Focussed changes consultation have been reviewed particularly in regard to the comments submitted by London Borough of Havering earlier this year (copies attached for information).

The focussed changes do not address nor resolve issues that Havering raised in its original Regulation 19 consultation in Spring 2019.

The representations submitted previously still stand and should be reported to the Inspector when the Brentwood Local Plan is formally submitted.

Please continue to keep me / Havering informed as the Brentwood Local Plan is progressed. Thank you.

1. This response relates to the changes to Policy R01 (1) (Dunton Hills Garden Village Strategic Allocation).
2. Brentwood Borough Council is an active partner in the Thames Chase Community Forest (TCCF) and in 2014, alongside other partner organisations, accepted and adopted the Thames Chase Plan as the strategy document guiding the creation and development of the area known as the Thames Chase Community Forest. In partnership with others, the Council is therefore committed to achieving the objectives and targets within that plan.
3. The Brentwood Borough Council Local Plan Addendum of Focussed Changes to the Pre-Submission Local Plan should take full account of the Thames Chase Plan. The Council is a key partner and as per item 1 above; adopted the existing Plan in 2014. The Addendum of Focussed Changes should acknowledge the Council's commitment to achieving the objectives and targets within the Thames Chase Plan.
4. The Thames Chase Trust is a member of the Green Infrastructure Working Group and Community Interest Groups for the Dunton Hills Garden Village Development. The Thames Chase Plan has clear synergy with the proposed development and its interaction with people, wildlife and the landscape.
5. Within the Thames Chase Plan, Areas 4 (Thorndon and Warley Woods) and 5 (Havering and Essex Fringe) apply to Brentwood Borough Council. Our five Forest-wide programmes align with the core aims of the National Planning Policy Framework (NPPF) and the Brentwood Borough Council Local Plan (See items below).
6. The Brentwood Borough Council Local Plan references the National Planning Policy
Framework (NPPF). Please note that this aligns with the Thames Chase Plan. The NPPF recognises the ongoing role that Community Forests have to play in realising sustainable development. Paragraph 92 of the NPPF states:
Quote:
"Community Forests offer valuable opportunities for improving the environment around towns, by upgrading the landscape and providing for recreation and wildlife. An approved Community Forest plan may be a material consideration in preparing development plans and in deciding planning applications."
Unquote.
7. Consequently, the Thames Chase Plan sets out five Forest-wide programmes of delivery that are in alignment with the core aims of the NPPF: Forestry; Landscape Regeneration; Access; People; Promotion.
8. These five programmes not only encompass woodland and landscape regeneration, but also how that environment needs to be accessed and used by people to support health and wellbeing, education and economic growth. As well as echoing the ambition of the NPPF, the Community Forest Plan can also help strengthen Local Plan policies relating to these themes, supporting development of new Local Plans and development management decisions.
9. The Thames Chase Trust would seek to see reference made to the Thames Chase
Community Forest (TCCF); its importance to the area in and around the emerging
Dunton Hills Garden Village and the diverse range of benefits it has provided to date and has the potential to do so in the future. It would also be beneficial to see a map of the borough, the Dunton Hills Garden Village area and its relationship, in terms of location, with the TCCF area and boundary.
10. The TCCF is closely aligned with the Strategic Objectives identified in the Brentwood Borough Council Local Plan and the Thames Chase Plan supports many of the objectives identified by the Council. The full document can be viewed at: www.thameschase.org.uk. In conclusion, it is very welcome to see clear alignment between the Brentwood Borough Council Local Plan Addendum of Focussed Changes to the Pre-Submission Local Plan and the Thames Chase Plan, however, the Thames Chase Trust would like to see direct reference made to the TCCF within the document, including any supporting documents. The Thames Chase Trust believes that there is more scope to include further references that would acknowledge the
wider range of opportunities provided by the Community Forest, particularly in relation to emerging developments such Dunton Hills Garden Village (Policy R01).
Thank you for the opportunity to comment.

Focussed Change 1 increases the minimum number of dwellings to be delivered at Dunton Hills Garden Village by 2032/33 by 70 dwellings to 2,770 dwellings. Whilst the change is a relatively small increase, given the absence of evidence to support the rate of delivery proposed, an objection is maintained.
It is noted from the Sustainability Appraisal Addendum (paragraph 2.9.3) that it concluded there is a degree of increased risk associated with reliance on this site, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery. Although it also noted discussions between the Council and site promoter indicated this was deliverable, it maintained there was an uncertain negative implication for the achievement of the Housing objectives.
Therefore, given the concerns shared with the authors of the Sustainability Appraisal, and in the absence of any evidence to demonstrate the amended number of dwellings is capable of being delivered within the Plan period, an objection is made to the focussed change on the grounds of soundness that it is not justified, as required by the Framework.
Appendix 1: Schedule of Focussed Changes
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that it does not demonstrate a five year supply on adoption of the Plan.
Focussed Change 13 within the Schedule amends the Local Development Plan Housing Trajectory and reduces the five year supply of deliverable housing by 70 dwellings. This is on the basis of the Plan being adopted in 2020, and the five year supply being calculated for Years 5 to 9 of the trajectory. Whilst the change is a relatively small reduction in supply, it still further reduces supply and an objection is maintained on the grounds of soundness in that it is not consistent with national policy in failing to identify a five year supply of specific deliverable sites against the housing requirement.
Sustainability Appraisal Addendum
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that the Spatial Strategy is reliant upon the delivery of a significant level of growth away from where the vast majority of housing and employment needs of the Borough are derived (Central Brentwood Growth Corridor). The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraph 2.9.4) that this concern is now acknowledged.
HLM also submitted an objection to the Pre-Submission Local Plan on the grounds that the housing provision within Policy SP02 does not reflect the minimum number of homes needed. The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraphs 2.9.3 and 2.9.5) that it is acknowledged the minimum number of homes needed (Local Housing Need) now equates to 454 dwellings per annum, which as a consequence means the Plan no longer makes any provision for a housing supply buffer. The Addendum therefore notes that the absence of a buffer, and the greater reliance upon one site (Dunton Hills Garden Village) to meet the housing need in a location some distance from where the need is largely derived (Central Brentwood) places a greater degree of uncertainty and risk that the Housing objectives will not be met.
As housing affordability is acknowledged as a significant concern for the Borough, HLM would respectfully request the Council consider through the Examination process additional allocation(s) within the Central Brentwood area in order to maintain its supply buffer and reduce the uncertainty and risks associated with the current Plan in relation to failing to meet housing need in areas where the need is derived. In this regard, HLM would also encourage the Council again to consider the evidence submitted as to the benefits of allocating or safeguarding Land west of Ongar Road for residential development.

The Council should consider through the Examination process additional allocation(s) within the Central Brentwood area in order to maintain its supply buffer and reduce the uncertainty and risks associated with the current Plan in relation to failing to meet housing need in areas where the need is derived. In this regard, HLM would also encourage the Council again to consider the evidence submitted as to the benefits of allocating or safeguarding Land west of Ongar Road for residential development.

Focussed Change 1 increases the minimum number of dwellings to be delivered at Dunton Hills Garden Village by 2032/33 by 70 dwellings to 2,770 dwellings. Whilst the change is a relatively small increase, given the absence of evidence to support the rate of delivery proposed, an objection is maintained.
It is noted from the Sustainability Appraisal Addendum (paragraph 2.9.3) that it concluded there is a degree of increased risk associated with reliance on this site, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery. Although it also noted discussions between the Council and site promoter indicated this was deliverable, it maintained there was an uncertain negative implication for the achievement of the Housing objectives.
Therefore, given the concerns shared with the authors of the Sustainability Appraisal, and in the absence of any evidence to demonstrate the amended number of dwellings is capable of being delivered within the Plan period, an objection is made to the focussed change on the grounds of soundness that it is not justified, as required by the Framework.
Appendix 1: Schedule of Focussed Changes
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that it does not demonstrate a five year supply on adoption of the Plan.
Focussed Change 13 within the Schedule amends the Local Development Plan Housing Trajectory and reduces the five year supply of deliverable housing by 70 dwellings. This is on the basis of the Plan being adopted in 2020, and the five year supply being calculated for Years 5 to 9 of the trajectory. Whilst the change is a relatively small reduction in supply, it still further reduces supply and an objection is maintained on the grounds of soundness in that it is not consistent with national policy in failing to identify a five year supply of specific deliverable sites against the housing requirement.
Sustainability Appraisal Addendum
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that the Spatial Strategy is reliant upon the delivery of a significant level of growth away from where the vast majority of housing and employment needs of the Borough are derived (Central Brentwood Growth Corridor). The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraph 2.9.4) that this concern is now acknowledged.
HLM also submitted an objection to the Pre-Submission Local Plan on the grounds that the housing provision within Policy SP02 does not reflect the minimum number of homes needed. The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraphs 2.9.3 and 2.9.5) that it is acknowledged the minimum number of homes needed (Local Housing Need) now equates to 454 dwellings per annum, which as a consequence means the Plan no longer makes any provision for a housing supply buffer. The Addendum therefore notes that the absence of a buffer, and the greater reliance upon one site (Dunton Hills Garden Village) to meet the housing need in a location some distance from where the need is largely derived (Central Brentwood) places a greater degree of uncertainty and risk that the Housing objectives will not be met.
As housing affordability is acknowledged as a significant concern for the Borough, HLM would respectfully request the Council consider through the Examination process additional allocation(s) within the Central Brentwood area in order to maintain its supply buffer and reduce the uncertainty and risks associated with the current Plan in relation to failing to meet housing need in areas where the need is derived. In this regard, HLM would also encourage the Council again to consider the evidence submitted as to the benefits of allocating or safeguarding Land west of Ongar Road for residential development.

Sste E10 as a whole should be removed from the Green Belt to allow flexibility moving forwards for not only for effective landscaping but also for the security of access arrangements.

We welcome the opportunity to submit representations to the above consultation on behalf S & J Padfield and Partners, who control the land identified as Codham Hall Farm (E10) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E10.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and landscaping, flexibility regarding the delivery of infrastructure requirements, and also the specific wording of the development principles for Policy E10.
The information submitted to the Council was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. The principal change referenced was for amendments to be made to the boundary of the allocation. The application is currently shown with two distinct areas - The existing employment area and some additional land is shown as white land, with surrounding land hatched in green.
In the absence of such detail on a map, or clarity within Policy E10, it is not clear whether the whole site is removed from the Green Belt which is not consistent with national policy or effective. With the majority of the site already being utilised for employment purposes and the whole site not contributing to the Green Belt purposes, it is considered that the site as a whole should be removed from the Green Belt to allow flexibility moving forwards for not only for effective landscaping but also for the security of access arrangements.
We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission.
.../Page 2
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments should able be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E10.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E10 at pre-submission stage in March made the case that the Codham Hall Farm can be relied upon to deliver a proportion of the Borough's employment land requirement. Whilst none of the focused changes directly impact on the proposed delivery of site E10, the Consultation does provide an opportunity to set out updates on key matters and reiterate the points made through our Regulation 19 representation, including the provision of further clarity on the allocation boundary. Also published alongside the plan are a number of evidence base documents, which we have commented on within this representation.
Infrastructure Delivery Plan
We note that alongside the AFC, other documents comprising the Local Plan Evidence Base have also been updated. The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 29-31 of the document covering the contribution made by the Codham Hall Farm, on top of the employment opportunities that are currently established on the site.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note these measures are listed as Medium to Long term. It is anticipated that employment provision at Codham Hall Farm will commence early in the Local Plan period to provide jobs to support growth in the Borough, particularly as a range of uses are already established.
.../Page 3
We consider the Transport & Movement document should make reference to the potential role that Demand Responsive public transport can play. This is being progressed by parties seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC). The sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which are unlikely to be the solution adopted at Codham Hall Farm.
Additional work is required with regards to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land, and the progression of development on key sites should therefore not be reliant on this from day one.
With regards to specific mitigation measures, other references within the Transport and Movement section relate to access and infrastructure improvements at specific road junctions. Codham Hall North has existing access form the M25 Jct. 29, but is also able to work closely with the Brentwood Enterprise Park site (draft allocation ref: E11) to improve upon the existing arrangement. This can be achieved through a range of options currently being discussed with ECC Highways and Highways England, and we are also in discussion with Planning Officers at Brentwood Borough Council to determine how such improvements can be delivered.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, Codham Hall Farm continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation set out that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We note that the allocation at Brentwood Enterprise Park (E11) is also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of Codham Hall North along the corridor. We note that paragraph 9.6.6 suggests that all sites will have good or excellent access onto the strategic highways network, while the draft plan indicates that access may be achieved via the B186. We note the updates from the version discussed in January that have been made to the October 2019 version finds that they do not lead to significant implications for economy related objections.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Through appropriate design and landscaping, adverse impacts can be avoided. A 'neutral or depending on implementation' scoring for a number of these criteria would be much more appropriate

We welcome the opportunity to submit representations to the above consultation on behalf S & J Padfield and Partners, who control the land identified as Codham Hall Farm (E10) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E10.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and landscaping, flexibility regarding the delivery of infrastructure requirements, and also the specific wording of the development principles for Policy E10.
The information submitted to the Council was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. The principal change referenced was for amendments to be made to the boundary of the allocation. The application is currently shown with two distinct areas - The existing employment area and some additional land is shown as white land, with surrounding land hatched in green.
In the absence of such detail on a map, or clarity within Policy E10, it is not clear whether the whole site is removed from the Green Belt which is not consistent with national policy or effective. With the majority of the site already being utilised for employment purposes and the whole site not contributing to the Green Belt purposes, it is considered that the site as a whole should be removed from the Green Belt to allow flexibility moving forwards for not only for effective landscaping but also for the security of access arrangements.
We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission.
.../Page 2
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments should able be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E10.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E10 at pre-submission stage in March made the case that the Codham Hall Farm can be relied upon to deliver a proportion of the Borough's employment land requirement. Whilst none of the focused changes directly impact on the proposed delivery of site E10, the Consultation does provide an opportunity to set out updates on key matters and reiterate the points made through our Regulation 19 representation, including the provision of further clarity on the allocation boundary. Also published alongside the plan are a number of evidence base documents, which we have commented on within this representation.
Infrastructure Delivery Plan
We note that alongside the AFC, other documents comprising the Local Plan Evidence Base have also been updated. The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 29-31 of the document covering the contribution made by the Codham Hall Farm, on top of the employment opportunities that are currently established on the site.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note these measures are listed as Medium to Long term. It is anticipated that employment provision at Codham Hall Farm will commence early in the Local Plan period to provide jobs to support growth in the Borough, particularly as a range of uses are already established.
.../Page 3
We consider the Transport & Movement document should make reference to the potential role that Demand Responsive public transport can play. This is being progressed by parties seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC). The sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which are unlikely to be the solution adopted at Codham Hall Farm.
Additional work is required with regards to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land, and the progression of development on key sites should therefore not be reliant on this from day one.
With regards to specific mitigation measures, other references within the Transport and Movement section relate to access and infrastructure improvements at specific road junctions. Codham Hall North has existing access form the M25 Jct. 29, but is also able to work closely with the Brentwood Enterprise Park site (draft allocation ref: E11) to improve upon the existing arrangement. This can be achieved through a range of options currently being discussed with ECC Highways and Highways England, and we are also in discussion with Planning Officers at Brentwood Borough Council to determine how such improvements can be delivered.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, Codham Hall Farm continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation set out that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We note that the allocation at Brentwood Enterprise Park (E11) is also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of Codham Hall North along the corridor. We note that paragraph 9.6.6 suggests that all sites will have good or excellent access onto the strategic highways network, while the draft plan indicates that access may be achieved via the B186. We note the updates from the version discussed in January that have been made to the October 2019 version finds that they do not lead to significant implications for economy related objections.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

Transport & Movement chapter of the IDP should make reference to the Demand Responsive public transport. Additional work is required with regards to the proposed cycle network for the SGC.

We welcome the opportunity to submit representations to the above consultation on behalf S & J Padfield and Partners, who control the land identified as Codham Hall Farm (E10) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E10.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and landscaping, flexibility regarding the delivery of infrastructure requirements, and also the specific wording of the development principles for Policy E10.
The information submitted to the Council was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. The principal change referenced was for amendments to be made to the boundary of the allocation. The application is currently shown with two distinct areas - The existing employment area and some additional land is shown as white land, with surrounding land hatched in green.
In the absence of such detail on a map, or clarity within Policy E10, it is not clear whether the whole site is removed from the Green Belt which is not consistent with national policy or effective. With the majority of the site already being utilised for employment purposes and the whole site not contributing to the Green Belt purposes, it is considered that the site as a whole should be removed from the Green Belt to allow flexibility moving forwards for not only for effective landscaping but also for the security of access arrangements.
We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission.
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Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments should able be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E10.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E10 at pre-submission stage in March made the case that the Codham Hall Farm can be relied upon to deliver a proportion of the Borough's employment land requirement. Whilst none of the focused changes directly impact on the proposed delivery of site E10, the Consultation does provide an opportunity to set out updates on key matters and reiterate the points made through our Regulation 19 representation, including the provision of further clarity on the allocation boundary. Also published alongside the plan are a number of evidence base documents, which we have commented on within this representation.
Infrastructure Delivery Plan
We note that alongside the AFC, other documents comprising the Local Plan Evidence Base have also been updated. The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 29-31 of the document covering the contribution made by the Codham Hall Farm, on top of the employment opportunities that are currently established on the site.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note these measures are listed as Medium to Long term. It is anticipated that employment provision at Codham Hall Farm will commence early in the Local Plan period to provide jobs to support growth in the Borough, particularly as a range of uses are already established.
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We consider the Transport & Movement document should make reference to the potential role that Demand Responsive public transport can play. This is being progressed by parties seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC). The sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which are unlikely to be the solution adopted at Codham Hall Farm.
Additional work is required with regards to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land, and the progression of development on key sites should therefore not be reliant on this from day one.
With regards to specific mitigation measures, other references within the Transport and Movement section relate to access and infrastructure improvements at specific road junctions. Codham Hall North has existing access form the M25 Jct. 29, but is also able to work closely with the Brentwood Enterprise Park site (draft allocation ref: E11) to improve upon the existing arrangement. This can be achieved through a range of options currently being discussed with ECC Highways and Highways England, and we are also in discussion with Planning Officers at Brentwood Borough Council to determine how such improvements can be delivered.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, Codham Hall Farm continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation set out that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We note that the allocation at Brentwood Enterprise Park (E11) is also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of Codham Hall North along the corridor. We note that paragraph 9.6.6 suggests that all sites will have good or excellent access onto the strategic highways network, while the draft plan indicates that access may be achieved via the B186. We note the updates from the version discussed in January that have been made to the October 2019 version finds that they do not lead to significant implications for economy related objections.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

The Council should have considered the merits of identifying additional, suitable sites to deliver in the short-medium term, including those which provide specialist accommodation to meet an identified local need, such as the land west of Crossby Close (site 073). As discussed above and shown in Appendix B, this represents a suitable site with local support for specialist accommodation that has been overlooked.

1.0 Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of M Scott Properties Ltd (Scott Properties) pursuant to Brentwood Borough Council's (the Council) Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) (Focussed Changes). They are submitted in addition to and should be read alongside those submitted in response to the previous Regulation 19 consultation held in February - March 2019.
1.2 Scott Properties have an interest in land to the west of Crossby Close, Mountnessing (the Site), which has been actively promoted as part of the Council's plan-making process, site reference 073 (AECOM (January 2019) SA Report). Previous representations have been made at various stages of the Local Plan, including the Call for Sites exercises and each consultation regarding the emerging Local Plan.
1.3 Scott Properties, in their capacity as a provider of specialist accommodation, are promoting the Site for specialist accommodation for those aged 55 and over, as well as those with, or supporting someone with a disability, in order to address an identified and unmet need locally and within the Borough.
1.4 Our earlier response to the Regulation 19 Consultation included evidence which demonstrated the existence of a local need for specialist accommodation within Mountnessing, and support for this type of accommodation through an online local needs consultation which received 92 positive responses.
1.5 These representations raise concerns as to:
 the impact of the higher Local Housing Need (LHN) figure;
 the lack of reasonable alternatives considered in making the Focussed Changes;
 the ability of the Focussed Changes to meet local housing needs, particularly older people; and
 the robustness of the SHLAA in light of the Focussed Changes.
2.0 Higher Local Housing Need (LHN)
2.1 These representations seek to focus on the proposed focussed changes to the Pre-Submission Local Plan (PSLP), set out in the consultation draft of the Focussed Changes. However, there are inevitable consequences resulting from the proposed amendments that draw together matters not specifically intended to be the focus of the addendum. We highlight these to ensure there is a holistic understanding of the effects of the changes proposed in the addendum and changes to national and local circumstances that should be considered prior to submission of the Plan.
2.2 Since the publication of the Pre-Submission Local Plan, Planning Practice Guidance (PPG) has been updated (in February 2019, during the previous Regulation 19 consultation) and confirms that the 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report Addendum - October 2019 (the SA Addendum) confirms at paragraph 2.9.3 that the LHN figure is now understood to equate to 454 dwellings per annum (dpa).
2.3 We expressed our concerns in our response to the previous Regulation 19 representations that there was insufficient flexibility within the PSLP's target figure of 456 dpa, which incorporates a 20% buffer on the housing requirement of 350 dpa as set out therein.2 Based on the actual housing need figure, as confirmed at 454 dpa within the SA Addendum, there now exists a buffer of just two dwellings per annum, which does not provide sufficient flexibility to ensure the Borough's housing needs are met. This is confirmed in paragraph 2.9.6 of the SA Addendum, which states that:
"the proposed supply figure of 456 dpa can no longer be said to put in place a significant 'buffer' over-and above the housing requirement."
2.4 In addition, it also highlights the risks of delays in delivery, as a result of increasing the housing supply to be provided at Dunton Hill Garden Village (DHGV) within the Plan period, confirming the importance of a buffer over-and-above the housing requirement for this reason. The Nathaniel Litchfield Study From Start to Finish (2016) confirms that the planning process takes on average 2.5 years for a planning application determination period for schemes of up to 500 units, but that this can double for schemes of 1,000 units and over. This not only confirms that it is unlikely that DHGV will deliver as early as 2022/23 as stated in the housing trajectory, but also points towards a necessity to ensure there is adequate provision within the Plan to meet housing requirements in the short-term. Within our earlier representations we stated that is was unrealistic that DHGV could deliver 100 dwellings as soon as 2022/23 as set out in the PSLP. Given that this was predicated (partly) on the adoption of the Local Plan in 2019, this timeframe is now clearly unrealistic and adoption by the end of 2020 remains challenging, with obvious implications for the proposed trajectory.
2.5 We consider that the Focussed Changes should have included an update to the LHN and the trajectory, without which the Plan can no longer be considered sound. Paragraph 11 of the NPPF requires plan-makers to positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change (our emphasis). It is considered that this is now not the case as a result of the updated LHN, given the Focussed Changes make no attempt to positively seek opportunities to meet development needs within the Borough. This is also set out in our comments regarding the lack of consideration of reasonable alternatives. This renders the plan inconsistent with national policy and unsound.
2.6 Paragraph 2.9.3 of the SA Addendum states that:
"It is fair to conclude that there is naturally a degree of increased risk associated with reliance on DHGV, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery; however, discussions between the Council and the site promoter have served to indicate that the 70 homes additionally assigned to the site through the Focussed Changes are deliverable within the plan period, and indeed can be delivered in a timely fashion such that the Local Plan housing delivery trajectory is unaffected."
2.7 The updated housing trajectory in the Focussed Changes shows the 70 homes reallocated to DHGV, as a result of the decreases from Focused Changes numbers.2-5, between years 15 and 17 (2030-2033), which does not represent delivery in a 'timely fashion', nor is the trajectory unaffected as a result. The Focussed Changes reduce the housing delivery within the earlier years of the Plan and thus the Plan's ability to meet its needs within those years. Our concern as to the robustness of the decision to adopted a stepped trajectory as raised in our response to the previous Regulation 19 consultation remains. We consider that the effect of the Focussed Changes in further reducing the Plan's ability to meet its needs within the earlier years of the Plan; a concern that we raised in our previous Regulation 19 response.
2.8 We have concerns as to the accuracy of the updated housing trajectory, which shows an increase in the Total Housing Provision within years 12 and 13, but no corresponding increases within the expected delivery from the Plan Allocations. Furthermore, the additional housing allocated to DHGV in year 17 does not correspond with the Total Housing Provision. This results in an over-estimated supply within years 12 and 13, and an under-estimation in year 17. We would expect the Council to clarify these errors, as it is casts uncertainty as to the exact effect of the Focussed Changes on the housing trajectory.
2.9 The table attached at Appendix A shows the updated housing trajectory (assuming a Total Housing Provision that aligns with expected delivery of the allocations) against the updated LHN. This shows that by year 7 (2022/23) there will be a deficit of 1,151 dwellings, and this is based on optimistic delivery rates for sites without planning permission expected to deliver in year 5 and onwards, so likely represents the best-case scenario. It also assumes that DHGV will commence delivery as early as year 7 (2022/23), which, as stated above and within our response to the previous Regulation 19 consultation, is an unrealistic expectation.
2.10 As a result of the increased LHN, the Total Housing Provision within the Plan provides a buffer of only 69 dwellings over the Plan's total housing requirement, which equates to just 0.9% of the requirement across the Plan period. The PSLP sought to provide a buffer of 20% against the housing requirement and we would highlight that the Chelmsford Local Plan, which has recently been examined, proposes a 20% buffer and this has been found to be suitable by the Inspector. The situation for the PSLP is that, again, the Plan demonstrates a lack of flexibility contrary to best practice, contrary to the rationale of the PSLP itself and contrary to Paragraph 11(a) of the NPPF. The Plan is therefore not positively prepared, nor will it be effective in meeting its needs across the Plan period.
3.0 Ability to Meet Local Housing Need (LHN)
3.1 Our representations to the previous Regulation 19 consultation highlighted the ageing population within the Borough, as recognised within paragraph 6.6 of the PSLP, and our concerns as to the lack of provision for specialist accommodation within the PSLP to meet present and future needs.
3.2 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report October 2019 (the SA) states at paragraph 9.5 that:
"There is also a need to address the health inequalities that exist within the population, and which are set to worsen, including because of the ageing population."
3.3 The Focussed Changes reduce the Plan's ability to meet local needs, particularly those of an ageing population, firstly, by reducing housing numbers in areas where housing needs are likely to be the highest, as quoted within the SA Addendum.3
3.4 Policies R25 and R26 require a provision for a minimum of 25% of the dwellings provided to be made available to those with a local connection, or to those aged 50 and over. The reduction in the number of dwellings not only reduces the potential availability of housing suitable for older people, but also raises concerns as to viability, as recognised within the SA Addendum. It states at paragraph 2.9.2 that:
"A reduced number of homes will have implications for scheme viability, and it is noted that these sites are subject to a policy requirement in respect of reserving a minimum of 25% of the proposed dwellings to be reserved for people with a strong and demonstrable local connection or those over 50 years of age; however, it is not possible to conclude any significant risk of the schemes becoming undeliverable."
3.5 Although this concludes that the schemes themselves may not become undeliverable, there is a real possibility that viability will affect the provision for these 25% homes for local people and those aged 50 and over coming forward through these allocations.
3.6 In addition, the Brentwood Local Development Plan Health Impact Assessment Version 3 October 2019 (HIA) notes that the reduction in dwellings on allocation R19 means that no wheelchair accessible dwellings will be required on site, taking it below the 60 dwelling threshold as set out in Policy HP01 of the PSLP.
3.7 Although the reduction in housing numbers on R18-19 and R25-26 will be redistributed to DHGV as part of the Focussed Changes, we would reiterate our concerns in relation to the provision and delivery of specialist accommodation at DHGV. Firstly, as stated above, the redistributed housing is not expected to be delivered at DHGV until year 12, reducing the ability of the Plan to address needs earlier in the Plan period.
3.8 Secondly, the provision for specialist accommodation at DHGV is to be delivered in accordance with Policy HP04. Paragraph 9.9.4 of the SA states that the provision of specialist accommodation at DHGV is not clear. Our response to the Regulation 19 consultation also raised concerns as to the lack of clarity regarding the definition of specialist accommodation within the supporting text of this Policy. The supporting text fails to give an accurate representation as to which type of specialist accommodation the Plan is seeking to deliver and for which group(s).
3.9 In light of this, it is considered that the Focussed Changes negatively affect the delivery of specialist accommodation for older people within the Plan period. We consider that the identification of additional suitable sites to meet needs within the short to medium term of the Plan period would enable the Plan to meet its housing needs specifically for older people. In the absence of this, we consider the Plan to be unsound and in direct conflict with the 'Housing for older and disabled people' 26 June 2019 addition to the NPPG.
4.0 Lack of Reasonable Alternatives Considered
4.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report Addendum (October 2019) (the SA Addendum) states at paragraph 1.2.5 that as part of preparing the Focussed Changes and updating the SA, there was not considered to be a need to give further formal consideration to reasonable alternatives, as it was considered unlikely that alternatives would lead to notably different side effects. This was in reliance of Planning Practice Guidance (PPG) paragraph 009 Reference ID: 11-009-20140306, which states:
"The sustainability appraisal should only focus on what is needed to assess the likely significant effects of the plan."
4.2 We consider that the conclusions as to the effects of the Focused Changes, particularly in respect of the 'Housing' objective as stated within the Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report October 2019 (SA) clearly demonstrate that reasonable alternatives should have been considered.
4.3 The SA states that there will be 'uncertain negative implications' for the achievement of the 'Housing' objectives.4 This is on the basis that the housing has been reduced in areas where needs are likely to be highest, and, has been moved to Dunton Hills Garden Village (DHGV), potentially increasing the risk of not delivering the housing requirement. It also makes reference to the higher LHN figure. In comparison, the PSLP, prior to the Focussed Changes, was assessed as likely to have 'significant positive effects' on the basis of ability to meet the LHN and provide for specialist accommodation.
4.4 In our previous representations to the Regulation 19 consultation, we disputed this conclusion and the ability of the plan to deliver specialist accommodation. A number of concerns were received from respondents to the Regulation 19 consultation as to the effectiveness of the Plan to meet the needs of older people, which should have prompted the Council to review the strategy in this regard as part of the Focussed Changes. The Site (reference 073) has consistently been promoted for specialist accommodation for older people, to meet a locally identified need within Mountnessing, as detailed in our previous representations, and represents a missed opportunity. Not only would this help to address a locally identified need, it would also enable delivery in the early years of the plan period; two concerns that were prevalent in the responses to the Regulation 19 consultation. This further supports the argument that reasonable alternatives to the Focussed Changes should have been considered.
4.5 Despite this, the SA then goes onto conclude that the assessment of the PSLP against the housing objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects). This is clearly not the case, and it is considered that this conclusion is both incorrect and misleading.
4.6 It is considered that the change from 'significant positive effects' (PSLP) to 'uncertain negative implications' (Focussed Changes) in achieving the 'Housing' objective amounts to a significant effect of the Focussed Changes. Therefore, in accordance with the PPG (as referenced above), consideration should have been given to reasonable alternatives, and the definitive conclusion that alternatives would not have led to notably different side effects is unjustified. As a minimum, the Council should have considered reasonable alternatives to ascertain whether there was a more suitable strategy which would enable the Plan to meet its housing needs, thus enabling the Plan to achieve a more positive and beneficial outcome in respect of the 'Housing' objective. We consider this to be fundamentally important to ensuring a sound Local Plan.
4.7 Given the decrease in housing within areas with the highest needs as raised in the SA, regard should have been had to allocating additional suitable sites to meet housing needs at a local level (which the plan failed to do prior to the Focussed Changes). This would help to address local housing requirements, including the provision of specialist accommodation, as well as providing a more substantial buffer over and above the increased LHN and help to minimise the risks associated with potential delays in delivery at DHGV; a concern that is highlighted in the SA.
4.8 Following from this, it would seem highly appropriate to consider settlements on key transport corridors such as Mountnessing, that contain sites that scored better than many of the allocated sites in the SA such as Site 073 (Land adjacent to Mountnessing Primary School), that could deliver housing to meet identified local needs within the first 5 years of the Plan, before choosing, what should be a last resort given the trajectory already discussed, increasing housing numbers at DHGV. Our representations to the previous Regulation 19 consultation contained evidence of local support via a social media consultation, which received 96 responses in total, all of whom were interested in a new build bungalow specifically for those aged 55 and over on the Site.5 Appendix B contains a summary of this. This demonstrates a locally supported site which is a suitable alternative to the Focussed Changes, yet one which has been overlooked.
4.9 The Plan has failed to consider alternative, suitable sites, to balance the reduction in housing numbers in the sites subject to the Focussed Changes when identifying suitable solutions to correct this.
5.0 Robustness of SLAA
5.1 We argued clearly within previous representations that the approach to assessing sites within the SA using the 'traffic light' scoring system was primitive, inconsistent and unjustified, which resulted in subjective and ill-informed conclusions. This is clearly shown in relation to the Site - land west of Crossby Close, Mountnessing, as shown below:
 the Site scored higher than many of the allocated sites, yet was not allocated due to 'potential highways access issues' despite previous representations confirming Essex County Council Highways have no objection to the access, and which agree with the proposed access strategy;
 the scoring system as to a Site's classification of agricultural land (criterion 17) the dataset for which, as confirmed in the SA, is described as 'of a poor resolution.' This resulted in some sites being scored 'red' or 'amber' when in fact they were brownfield or non-agricultural land. The Site was incorrectly assessed as 'amber' for this criterion, yet it has not been in agricultural use since the current owner's acquisition in 1995 (with evidence adduced as part of our response to the previous Regulation 19 consultation to support this);
5.2 This further demonstrates inconsistencies and inaccuracies within the site assessment process, which we consider fails to demonstrate that the Plan has been positively prepared. However, despite pointing these out, the Focussed Changes do not include any rectification of these errors, and instead has taken a selective and non-transparent approach to amend existing allocations in response to objections received in the previous Regulation 19 consultation. We consider that this should have formed part of the consideration of reasonable alternatives to the Focussed Changes, which, as discussed above, was unjustifiably overlooked by the Council, in preference for amending the evidence base to suit the desired outcome. As a result, the Plan is not justified and cannot be considered sound.
6.0 The Unclear Approach to R18, R19, R25 and R26
6.1. The Council has decided to reduce the densities on allocations R18, R19, R25 and R26 (Focussed Changes 2-5), citing a considerable number of representations raising concerns as to the suitability of the sites for the proposed densities as the justification.
6.2. In redistributing the housing numbers from the above allocations to DHGV, the large number of objections received during the previous Regulation 19 consultation in respect of DHGV, including from statutory consultees, have been ignored. Instead, the Focussed Changes have gone against a number of comments, which highlight the unrealistic delivery timetable, and the need for sites which can deliver in the early years of the Plan.
6.3. There were also objections received in respect of other allocations within the Plan, as well as comments in respect of omission sites, such as our response to that consultation, which sought to clarify inaccuracies about the Site within the site assessment and show that earlier concerns regarding the access arrangements had been addressed.
6.4. The Addendum of Focussed Changes explains that the total loss of 70 homes across the four aforementioned sites will be off-set by altering another allocation to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the addendum does confirm that the overall number of new homes will not be increased, merely that there will be a faster rate of delivery at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than previously projected (resulting in fewer post-2033).
6.5. We have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply altering Dunton Hills Garden Village to deliver at a greater rate than previously calculated, and at just a fast enough rate to account for the shortfall created by the need to reduce the proposed capacities for site R18, R19, R25, and R26. The lack of clarity in how both the reduction and the increase have been justified is unhelpful in being able to comment on the justification for the Focused Changes.
7.0 Cross-boundary and Statutory Consultee Objections
7.1. Basildon Borough Council have objected to the DHGV allocation in its response to the previous Regulation 19 consultation, in which it raised concerns regarding the cross-boundary impacts of this site, questioning the soundness of the Plan in this respect. Similarly, Essex County Council also raised concerns in respect of the transport evidence base for DHGV. As part of the Focussed Changes, the Council have seemingly overlooked these comments, in the absence of any evidence to the contrary, seeking instead to direct more housing numbers to this allocation within the Plan period, and failing to consider any reasonable alternatives.
7.2. As for the key concerns raised, it is concerning that the site assessments undertaken to date have failed to identify the numerous cited issues raised by respondents. Notwithstanding the inaccuracies in the assessment of our Site (land west of Crossby Close, Mountnessing) as mentioned above and in detail in our response to the previous Regulation 19 consultation, this casts further doubt on the robustness and the overall accuracy of the site assessment process which underpins the allocations within the Plan. This also substantiates our previous concerns that the site assessment process was inadequate, and therefore potentially undermines the remaining allocations within the Plan, as it is unclear as to whether any significant objection was raised in relation to those through the previous Regulation 19 consultation.
8.0 Conclusion
8.1. We consider that the Plan remains unsound as a result of the Focussed Changes. The higher confirmed LHN has not been incorporated within the Plan, nor the effects of this on whether the Plan should identify a suitable buffer to provide flexibility to adapt to rapid change. The Plan is therefore failing to meet the requirements of the NPPF and failing to meet the identified need for the Borough. The Focussed Changes do not demonstrate that the Plan will be effective in meeting housing needs, given it seeks to re-direct housing delivery from the short-term to the later years of the Plan, further decreasing its ability to meet its needs early in the Plan period. This is particularly concerning given the results of the Housing Delivery Test for the Borough (2019).
8.2. The trajectory as set out in the Focussed Changes remains overly optimistic, with the concerns as to the effects of a slippage in delivery at DHGV raised forming part of the reason for the SA conclusions that the Focussed Changes will have 'uncertain negative effects' on the 'Housing' objective. We strongly disagree with the SA's further conclusions that the assessment of the PSLP against the 'Housing' objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects).
8.3. The decision to discount the need for consideration of reasonable alternatives is inconsistent with national policy, and unjustified. This is apparent from the SA conclusions (discussed above), and we are highly concerned that this has reduced the ability of the Plan to meet the housing needs of the Borough going forward. The Council should have considered the merits of identifying additional, suitable sites to deliver in the short-medium term, including those which provide specialist accommodation to meet an identified local need, such as the land west of Crossby Close (site 073). As discussed above and shown in Appendix B, this represents a suitable site with local support for specialist accommodation that has been overlooked.