This is a minor increase to what is already a substantial proposal. The increment in housing numbers should be easily absorbed into the overall development proposal

The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDDP

I agree with the additional house numbers but believe there could be a further 20 added.

I believe there is capacity to support the additional houses.

move housing development in the other direction

The aim of these focused changes is to reduce housing development from locations in North abd mid Brentwood and place them in Dunton Hills near Thurrock and Basildon. Brentwood's need for housing is around its main towns and villages. Brentwood council is trying to "protect" those areas from development. This plan is not positively prepared. The move is not justified. If it could be justified they would have done this in the original plan. Nothing has changed. It is not effective because it does not meet housing need where it is required. It is not consistent with national policy on sustainability because the A127 cannot cope with the load and pollution. There is no provision in law for limited consultations at this stage of the Local Plan submission so this is not legally compliant. The changes go against wishes of neighbouring authorities and have not been properly discussed so Duty to Cooperate is not met

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!

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!

Rochford District Council raises no objection to the proposed amendments to Brentwood Borough Council's Pre-Submission Draft Local Plan, namely the revised capacities of various sites proposed for development. Brentwood Borough Council should, however, satisfy themselves and the Inspector that the policies subject to amendment, in the context of its wider spatial strategy, are both sound and deliverable. In particular, Brentwood Borough Council should satisfy itself that the rate of development suggested for 'Dunton Hills Garden Village' is deliverable and realistic in order to ensure no unmet needs will arise.

Rochford District Council would like to acknowledge the importance of Brentwood Borough Council continuing to engage positively on strategic issues, including as part of the Association of South Essex Local Authorities (ASELA) and in the preparation of the South Essex Joint Strategic Plan. Brentwood Borough Council is expected to continue to discharge its Duty to Co-operate with Rochford District Council and work positively to ensure that
their mutual aspirations and vision for South Essex, set out in the Memorandum of Understanding dated July 2018, can be realised in the most effective, sustainable and equitable way.

Rochford District Council retains its original comments submitted to Brentwood Borough Council to the Pre-Submission Draft Local Plan consultation in March 2019 where they relate to matters not subject to amendment.

CEG note the Council's proposal to increase the number of new homes to be provided for within the DHGV strategic housing allocation in the plan period to 2033. CEG considers this to be a relatively small increase in the number of new homes when compared to what was previously proposed to be provided by the end of the plan period and the total indicative capacity of the DHGV allocation overall. The increase of 70 new homes equates to a 2.6% increase in new homes to be delivered by the end of the plan period; and is also well within the overall indicative capacity of the allocation site of around 4000 new homes that would be delivered up to and beyond 2033.

Take the houses allocated to Blackmore village

Large site suggest they take additional housing from Blackmore

Dunton is a large site & will have infrastructure & access to transport links, so could take the 50 houses without problem

Believe Dunton should take the 50 houses from Blackmore

A much better solution would be to reprovide the units lost from the Shenfield and Blackmore allocations on sustainable sites in and around Brentwood.
The site at Spital Lane is an ideal candidate, being located on the edge of the town close to services and facilities, having minimal impact on the openness of the Green Belt, and as per the Environment Agency comments on the most recent planning application, being capable of accommodating six houses without any risk of flooding.
We therefore advocate that Spital Lane be allocated for housing in the emerging plan, along with other suitable smaller sites identified in the SHLAA, to make up the housing numbers lost in Shenfield and Blackmore.

The proposed reduction in housing numbers in Shenfield and Blackmore is problematical for two reasons.
First, because it reduces housing numbers in sustainable settlements where growth is needed, and puts them in a less sustainable location.
Second, because in relocating the units to the proposed strategic allocation at Dunton Hills, the provision of these units will inevitably occur later in the plan period, when the focus should be on early provision to address the current housing land supply shortfall.
A much better solution would be to reprovide the units lost from the Shenfield and Blackmore allocations on sustainable sites in and around Brentwood.
The site at Spital Lane is an ideal candidate, being located on the edge of the town close to services and facilities, having minimal impact on the openness of the Green Belt, and as per the Environment Agency comments on the most recent planning application, being capable of accommodating six houses without any risk of flooding.
We therefore advocate that Spital Lane be allocated for housing in the emerging plan, along with other suitable smaller sites identified in the SHLAA, to make up the housing numbers lost in Shenfield and Blackmore.

Support

Support

Anglian Water previously commented on Policy R01 of the Pre-submission Local Plan as part of the earlier consultation. The following comments should be read in conjunction with our earlier comments on the Local Plan.

We note that it is proposed to increase the amount of housing expected to come forward within the plan period at the Dunton Hills Allocation and that the total housing capacity is unchanged. As an infrastructure provider we closely monitor housing growth in our region to align our planned investment with additional demand for water recycling infrastructure. Therefore we have no comments to make relating to the focused change to Policy R01.

Brentwood Borough Council: Addendum of Focussed Changes to the Pre Submission Local Plan
SUBMISSION ON BEHALF OF NATIONAL GRID
National Grid has appointed Wood to review and respond to development plan consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales and National Grid Electricity System Operator (NGESO) operates the electricity transmission network across the UK. The energy is then distributed to the eight electricity distribution network operators across England, Wales and Scotland.
National Grid Gas plc (NGG) owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK's four gas distribution networks where pressure is reduced for public use.
National Grid previously owned part of the gas distribution system known as 'National Grid Gas Distribution limited (NGGDL). Since May 2018, NGGDL is now a separate entity called 'Cadent Gas'.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future
infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect National Grid's assets.
Proposed sites crossed or in close proximity to National Grid infrastructure:
Following a review of the above development plan, the following sites have been identified as being crossed
or in close proximity to National Grid infrastructure. Further details are provided in the table overleaf.

Electricity Transmission
Site Ref Asset Details Appendix Ref E11- Brentwood Enterprise Park
ZB Route - 275Kv two circuit route from Warley substation in Havering to Waltham Cross substation in Epping Forest
ET329 (GT113) Gas Transmission Site Ref Asset Details Appendix Ref R01

Strategic Allocation Brentwood Hills Garden Village
FM05 - Braintree to Horndon GT111

R06 - Land off Nags Head Lane, Brentwood
FM18 - Stapleford Tawney to Tilbury Thames North GT112

E11- Brentwood Enterprise Park
FM18 - Stapleford Tawney to Tilbury Thames North GT113 (ET329)

Please see attached plan referenced ET329, GT111, GT112 & GT113 at Appendix 2. The proposed sites are crossed by a National Grid high voltage electricity transmission overhead line and/or National Grid underground high-pressure gas pipeline. The statutory safety clearances between overhead lines, the ground, and built structures must not be infringed. Where changes are proposed to ground levels beneath an existing line then it is important that changes inground levels do not result in safety clearances being infringed. National Grid can, on request, provide to developers detailed line profile drawings that detail the height of conductors, above ordnance datum, at a specific site. You can find National Grid's guidelines for developing near Over Head Lines here:
https://www.nationalgrid.com/sites/default/files/documents/Development%20near%20overhead%20lines_0.pdf
Electricity Distribution
UK Power Networks owns and operates the local electricity distribution network in Brentwood Borough Council. Contact details can be found at www.energynetworks.org.uk.

National Grid Asset Guidance
National Grid seeks to encourage high quality and well-planned development in the vicinity of its high voltage overhead lines. Land beneath and adjacent to the overhead line route should be used to make a positive contribution to the development of the site and can for example be used for nature conservation, open space, landscaping areas or used as a parking court. National Grid, in association with David Lock Associates has produced 'A Sense of Place' guidelines, which provide detail on how to develop near overhead lines and offers practical solutions which can assist in avoiding the unnecessary sterilisation of land in the vicinity of high voltage overhead lines.
Potential developers of these sites should be aware that it is National Grid policy to retain our existing overhead lines in-situ. The relocation of existing high voltage overhead lines will only be considered for projects of national importance which has been identified as such by central government. National Grid requests that any High-Pressure Gas Pipelines are taken into account when site options are developed in more detail. These pipelines form an essential part of the national gas transmission system and National Grid's approach is always to seek to leave our existing transmission pipelines in situ. Please refer to the Health and Safety Executive (HSE) in the first instance.
National Grid have land rights for each asset which prevents the erection of permanent/ temporary buildings, or structures, changes to existing ground levels, storage of materials etc. Additionally, written permission will be required before any works commence within the National Grid easement strip, and a deed of consent is required for any crossing of the easement. In the first instance please consider checking with the Land Registry for the development area.
If you require any further information in relation to the above and/or if you would like to check if National Grid's transmission networks may be affected by your works, please contact National Grid's Plant Protection team viaplantprotection@nationalgrid.com or visit the website: https://www.linesearchbeforeudig.co.uk/

Further Advice
National Grid is happy to provide advice and guidance to the Council concerning our networks. If we can be of any assistance to you in providing informal comments in confidence during your policy developpment, please do not hesitate to contact us. In addition, the following publications are available from the National Grid website or by contacting us at the address overleaf:
* A sense of place - design guidelines for development near high voltage overhead lines: A sense of place design guidelines for development near high voltage overhead lines:
https://www.nationalgrid.com/sites/default/files/documents/Sense%20of%20Place%20-
%20National%20Grid%20Guidance.pdf
* Guidelines when working near NGG assets: https://www.nationalgridgas.com/land-and-assets/workingnear-
our-assets
* Guidelines when working near NGETT assets: https://www.nationalgridet.com/network-andassets/
working-near-our-assets

SOW N GROW NURSERY AND ADJOINING SITES MAKING UP SITE R07.
BRENTWOOD DISTRICT LOCAL PLAN - ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REGULATION 19 FEBRUARY 2019 AND RELATED DOCUMENTS.

CONSULTATION RESPONSE FOR MR DEREK ARMIGER, MS KIM ARMIGER AND MS MAXINE ARMIGER, ("THE ARMIGER FAMILY"), C/O THE BUNGALOW, SOW N GROW NURSERY, PILGRIMS HATCH, BRENTWOOD, ESSEX CM15 9JH.
I have once again been instructed as Agent by Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger, i.e. the Armiger family, by way of their personal and family Responses, as being the joint owners of the larger part of the land comprising the Sow N Grow Nursery Allocated Site and Bungalow, and dwelling, as defined in Policy R07, and as shown in part, on the plan on page 324 of the Pre-Submission Local Plan. (The balance of the site, separated by a trackway to the allotments and of unknown ownership, is owned by Mrs Heather Dunbar).
Please accept this letter of Response to the Addendum of Focussed Changes to the Pre-Submission Local Plan, and other supporting documents issued for this consultation on behalf of the said, Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger and the Armiger Family.
1 The Armiger Family members individually and collectively have no objection to the Focussed Changes to the Pre-Submission Local Plan with regard to the deleted sites and dwellings allocated in Blackmore and Shenfield and their re-allocation and incorporation into land allocated for residential development in Dunton Green.
2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention. I should be pleased to discuss any matters arising from this Letter and Response with the Local Planning Authority should it wish to do so.
Yours sincerely
Alan Wipperman BA MRICS MRTPI C Dip AF
Copies: Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger.

SOW N GROW NURSERY AND ADJOINING SITES MAKING UP SITE R07.
BRENTWOOD DISTRICT LOCAL PLAN - ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REGULATION 19 FEBRUARY 2019 AND RELATED DOCUMENTS.

CONSULTATION RESPONSE FOR MR DEREK ARMIGER, MS KIM ARMIGER AND MS MAXINE ARMIGER, ("THE ARMIGER FAMILY"), C/O THE BUNGALOW, SOW N GROW NURSERY, PILGRIMS HATCH, BRENTWOOD, ESSEX CM15 9JH.
I have once again been instructed as Agent by Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger, i.e. the Armiger family, by way of their personal and family Responses, as being the joint owners of the larger part of the land comprising the Sow N Grow Nursery Allocated Site and Bungalow, and dwelling, as defined in Policy R07, and as shown in part, on the plan on page 324 of the Pre-Submission Local Plan. (The balance of the site, separated by a trackway to the allotments and of unknown ownership, is owned by Mrs Heather Dunbar).
Please accept this letter of Response to the Addendum of Focussed Changes to the Pre-Submission Local Plan, and other supporting documents issued for this consultation on behalf of the said, Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger and the Armiger Family.
1 The Armiger Family members individually and collectively have no objection to the Focussed Changes to the Pre-Submission Local Plan with regard to the deleted sites and dwellings allocated in Blackmore and Shenfield and their re-allocation and incorporation into land allocated for residential development in Dunton Green.
2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention. I should be pleased to discuss any matters arising from this Letter and Response with the Local Planning Authority should it wish to do so.
Yours sincerely
Alan Wipperman BA MRICS MRTPI C Dip AF
Copies: Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger.

SOW N GROW NURSERY AND ADJOINING SITES MAKING UP SITE R07.
BRENTWOOD DISTRICT LOCAL PLAN - ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REGULATION 19 FEBRUARY 2019 AND RELATED DOCUMENTS.

CONSULTATION RESPONSE FOR MR DEREK ARMIGER, MS KIM ARMIGER AND MS MAXINE ARMIGER, ("THE ARMIGER FAMILY"), C/O THE BUNGALOW, SOW N GROW NURSERY, PILGRIMS HATCH, BRENTWOOD, ESSEX CM15 9JH.
I have once again been instructed as Agent by Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger, i.e. the Armiger family, by way of their personal and family Responses, as being the joint owners of the larger part of the land comprising the Sow N Grow Nursery Allocated Site and Bungalow, and dwelling, as defined in Policy R07, and as shown in part, on the plan on page 324 of the Pre-Submission Local Plan. (The balance of the site, separated by a trackway to the allotments and of unknown ownership, is owned by Mrs Heather Dunbar).
Please accept this letter of Response to the Addendum of Focussed Changes to the Pre-Submission Local Plan, and other supporting documents issued for this consultation on behalf of the said, Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger and the Armiger Family.
1 The Armiger Family members individually and collectively have no objection to the Focussed Changes to the Pre-Submission Local Plan with regard to the deleted sites and dwellings allocated in Blackmore and Shenfield and their re-allocation and incorporation into land allocated for residential development in Dunton Green.
2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention. I should be pleased to discuss any matters arising from this Letter and Response with the Local Planning Authority should it wish to do so.
Yours sincerely
Alan Wipperman BA MRICS MRTPI C Dip AF
Copies: Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger.

By proposing to build so many new builds, a suitable infrastructure and facilities can be encorporated in the planning permission.

Larger sites often take longer to deliver housing, because they typically have complex ownership structures and require significant investment in infrastructure. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that for sites of over 2,000 dwellings, the average timeframe between the validation date of the planning application and the delivery of the first dwelling was just under seven years. This compares with just under three years for smaller sites of up to 99 dwellings and therefore, whilst it is justified to reduce the housing allocation at the sites in Shenfield and Blackmore, the 70 dwellings should be re-distributed to suitable smaller developments rather than being added to DHGV.
Smaller sites are often able to come forward more quickly than larger sites because they are typically in single ownership and require less investment in infrastructure. They also attract smaller, more local housebuilding companies that would not be present on larger sites, enable more early deliveries and constitute a more sustainable approach towards meeting the housing need.
Brownfield sites should also be prioritised in line with the requirements of the NPPF, which states in paragraph 137 that:
'before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development'.
As a result, brownfield land should be utilised, with greenfield land being released only when all sustainably located, available and deliverable sites have been identified as allocations.
In contrast, Brentwood Borough Council propose relying entirely on the delivery of a single, large, greenfield site to be able to demonstrate and maintain a five-year supply in the early plan period - a method that has been criticised by several inspectors at Local Plan Examinations in Braintree District, Tendring District and Colchester Borough Council in relation to North Essex Garden Communities.
Due to the location of the Dunton Hills Garden Village allocation, a significant proportion of Brentwood's housing would be located on the Borough boundary with Basildon. The settlement would adjoin Basildon's Green Belt and although it was once intended for both Councils to locate settlements in this area, Basildon no longer propose this. It could therefore also be considered that the authorities have not complied with their duty to co-operate.
In conclusion, we object to the re-distribution of 70 dwellings into the Dunton Hills Garden Village allocation, considering instead that the dwellings should be re-allocated to more suitable smaller sites and brownfield land. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged, particularly when suitable alternative sites are available.

These representations are submitted in response to the publication of:
Brentwood Borough Council Local Plan Consultation on Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)
We object to the following change to the Pre-Submission Local Plan:
* Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,770 homes in the plan period".
We support the following changes to the Pre-Submission Local Plan:
* Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes".
* Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes".
* Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes".
* Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
We support the reduction in housing numbers at the allocation sites in Shenfield and Blackmore, as this is justified by the evidence base.
However, we object to the re-distribution of the 70 dwellings to the Dunton Hills Garden Village (DHGV) allocation, because it would mean that fewer homes would be delivered in the early years of the plan. The reliance on DHGV to deliver such a large proportion of the Borough's housing need within the early years of the plan is too great, particularly when smaller sites are available, some of which are brownfield.
Larger sites often take longer to deliver housing, because they typically have complex ownership structures and require significant investment in infrastructure. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that for sites of over 2,000 dwellings, the average timeframe between the validation date of the planning application and the delivery of the first dwelling was just under seven years. This compares with just under three years for smaller sites of up to 99 dwellings and therefore, whilst it is justified to reduce the housing allocation at the sites in Shenfield and Blackmore, the 70 dwellings should be re-distributed to suitable smaller developments rather than being added to DHGV.
Smaller sites are often able to come forward more quickly than larger sites because they are typically in single ownership and require less investment in infrastructure. They also attract smaller, more local housebuilding companies that would not be present on larger sites, enable more early deliveries and constitute a more sustainable approach towards meeting the housing need.
Brownfield sites should also be prioritised in line with the requirements of the NPPF, which states in paragraph 137 that:
'before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development'.
As a result, brownfield land should be utilised, with greenfield land being released only when all sustainably located, available and deliverable sites have been identified as allocations.
In contrast, Brentwood Borough Council propose relying entirely on the delivery of a single, large, greenfield site to be able to demonstrate and maintain a five-year supply in the early plan period - a method that has been criticised by several inspectors at Local Plan Examinations in Braintree District, Tendring District and Colchester Borough Council in relation to North Essex Garden Communities.
Due to the location of the Dunton Hills Garden Village allocation, a significant proportion of Brentwood's housing would be located on the Borough boundary with Basildon. The settlement would adjoin Basildon's Green Belt and although it was once intended for both Councils to locate settlements in this area, Basildon no longer propose this. It could therefore also be considered that the authorities have not complied with their duty to co-operate.
In conclusion, we object to the re-distribution of 70 dwellings into the Dunton Hills Garden Village allocation, considering instead that the dwellings should be re-allocated to more suitable smaller sites and brownfield land. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged, particularly when suitable alternative sites are available.

Dutton village has the required infrastructure ie trains, bus along with doctors and schools to support increased numbers of dwellings

Reduce housing and industrial units proposed for West Horndon Parish, with particular regard to Dunton Hills Garden Village.

Dear

BRENTWOOD BOROUGH LOCAL PLAN 2016 -2033
RE-OPENED PRE-SUBMISSION REGULATION 19 CONSULTATION

As you are aware, the Pre-Submission Regulation 19 Consultation on the Brentwood Borough Local Plan 2016 - 2033 has been re-opened. This follows a decision by the Borough Council to re-examine housing proposals at four sites in Blackmore and Shenfield. It has been recommended that the housing stock at these four sites will be reduced by seventy homes and this displaced number will be added to the homes to be provided at the proposed Dunton Hills Garden Village. This will be done over the lifespan of the Local Plan.

I write on behalf of West Horndon Parish Council: the Parish that will have to absorb these additional 70 homes. It would be very easy to dismiss this relatively small number of properties given the proposed size of Dunton Hills Garden Village. However, this ignores the fact that these homes will exacerbate an already ill-conceived and poorly planned new Garden Village.

As the central Government requirement to provide new housing within Brentwood Borough has grown, the size of the Garden Village has increased to meet the perceived demand. During the drawing up of the Local Development Plan various lobbying in respect of different proposed sites has taken place and the size of the proposed Dunton Hills Garden Village has grown and grown. It is stated in the Borough Plan that Brentwood is a borough of villages. However, West Horndon Parish, at the southern extreme of the Borough, is being expected to provide a disproportionate amount of the necessary housing and industrial development. It is difficult not to draw the conclusion that Dunton Hills Garden Village is being used as an excuse to ensure that other parts of the Borough do not have to experience the upheaval that will result from extended building works over a number of years.

As noted in earlier representations, the Regulation 19 Local Plan is not consistent in respect of Dunton Hills Garden Village with National Policy. Sustainable development, in terms of providing suitable transportation links, and meeting the challenges of climate change and combatting flooding, needs to be provided. Sustainable movement in West Horndon Parish and surrounding areas is already difficult. It has been shown that it will be extremely problematic with the proposed Garden Village in place. No evidence has been provided by the Borough Council that the impact of growth on the A127 and the A128 has been appropriately assessed. Passenger numbers at West Horndon Station on the C2C line into Fenchurch Street are already at capacity, and no understanding or allowance has been made for how additional passengers can or will be accommodated.

In conclusion, this further increase in the size of the proposed Dunton Hills Garden Village is non-sustainable.

Yours sincerely,

Kim Harding
Clerk to West Horndon Parish Council

As a result of the increase in dwelling numbers for this site allocation BBC should include, within the Plan evidence and supporting text for this Policy, details to demonstrate that the reallocation of dwellings to this site is where the need is (paragraph 59 of the NPPF), and that all other reasonable options for reallocating the dwellings have been fully examined, including making as much use as possible of suitable brownfield sites and underutilised land, and optimising density.

BBC should also update its transport evidence base for the Local Plan to fully assess the transport implications of the change in dwellings numbers on this site allocation.

The policy needs to be further changed to address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.

2. Justified
3. Effective
4. Consistent with National Policy

Paragraph 31 of the NPPF requires planning policies to be underpinned by relevant and up to date evidence.

BBC will need to be satisfied that the increase in dwelling numbers on this site is supported by the appropriate evidence base, including demonstrating that the reallocation of dwellings to this site is where the need is (paragraph 59 of the NPPF), and that all other reasonable options for reallocating the dwellings have been fully examined, including making as much use as possible of suitable brownfield sites and underutilised land, and optimising density (paragraph 137).

BBC will need to be satisfied that the transport implications of the change in dwelling numbers on this site allocation are fully assessed through an updated transport evidence base for the Local Plan.

The proposed change to this policy does not address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.
See
ECC 67 / BBC 22434
ECC 68 / BBC 22435
ECC 69 / BBC 22436
ECC 70 / BBC 22437
ECC 71 / BBC 22438
ECC 72 / BBC 22439
ECC 73 / BBC 22440
ECC 74 / BBC 22441
ECC 75 / BBC 22442
ECC 76 / BBC 22443

ECC's position has not changed on this matter.

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.

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.

This adds homes where they are already planned for the long term, ultimately having no adverse impact on use of land, especially green belt, as other changes would do.

Allocate additional site to delivery at least 70 additional homes in the early years of the plan period (2022/23 - 2024/25). Site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above

1.0 Introduction and background
1.1 This representation on the Brentwood Borough Council's Addendum of Focussed Changes to the Pre Submission Local Plan (AFC) is made by Strutt & Parker on behalf of Turn2Us.
1.2 Turn2Us is a national, registered charity with a mission to fight poverty in the UK and Ireland, helping individuals who are struggling financially to gain access to financial help. Each year the charity assists several million people in a range of different ways. It has seen a steady increase in the number of people turning to the charity for help in recent years. The charity receives no Government funding. It is through donations and legacies that it raises funds, and the charity is committed to ensuring long-term financial sustainability
1.3 Turn2Us is the freeholder of the majority of the area of land between Hutton Village, Rayleigh Road and Church Lane. A small portion of this land, located immediately adjacent to the existing settlement and adjoining Rayleigh Road and Hutton village, measuring 2.4 ha is being actively promoted by Turn2Us for residential allocation in the Council's new Local Plan.
1.4 Strutt & Parker have made representations on the Brentwood Borough Pre-Submission Local Plan (February 2019) (PSLP) on behalf of Turn2Us and in relation to this land at Rayleigh Road, Hutton (site reference 219 in the Council's plan-making process).
1.5 Concerns regarding the soundness of the PSLP set out in our representations made remain, but are not repeated here to avoid duplication.
1.6 This representation focuses on the proposed focussed changes to the PSLP, set out in the consultation draft of 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";
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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".
1.7 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).
1.8 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 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).
1.9 We 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.
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.
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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 as to what may be delivered.
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.
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.
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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 Dunton Hills Garden Village 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 (see paragraphs 35-38) 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. At the time of our PSLP representations, it was based on an optimistic assumption that the Brentwood Borough Local Plan would be adopted in 2019. Clearly there is now no such prospect. Indeed, given the current stage in the process and the extent of delays, even adoption before the end of 2020 would now be challenging.
2.11 The PSLP proposes that Dunton Hills Garden Village will comprise around 4,000 dwellings (2,700 to be delivered by 2033). A study by NLP (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? (November 2016)) reviewed 70 strategic sites which have delivered / will deliver more than 500 dwellings. The study reviewed sites varied in size (from 504 to 15,000 dwellings) and location. The study identified that the average planning approval period for schemes comprising more than 2,000 dwellings was 6.1 years. Following planning approval, the study found that a period of 0.8 years could be expected before the first completions on such sites. In short, it would be appropriate to allow for a period of 7 years from anticipated first planning application before first completions. Indeed, given the NPPF requirement to ensure a flexible strategy, it would be prudent to allow for longer.
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 until 2027/28 at the earliest, 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 wholly inappropriate to assume Dunton Hills Garden Village will accommodate an even greater number of dwellings by 2033 than the PSLP did.
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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 previously found that the average delivery rate for schemes comprising over 2,000 dwellings was only 161 dwellings per annum.
2.17 The further 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.
Delivery of homes delayed and five-year housing land supply
2.18 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.
2.19 As we noted at paragraph 31 of our representations on the PSLP, the Borough currently is 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.
2.20 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.
2.21 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).
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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
2.22 As noted early within this representation, 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.
2.23 As such, it is critical that the Local Plan is not overly reliant on a limited number of sites.
2.24 However, the PSLP placed great reliance on Dunton Hills Garden Village to meet development needs.
2.25 Rather than address this concern, the AFC has simply placed even greater reliance on Dunton Hills Garden Village to meet the Borough's needs.
2.26 Such reliance on a single scheme is neither effective nor consistent with national policy.
Specialist accommodation for an ageing population
2.27 Proposed allocation R19 is one of the sites the Council has revised down the projected capacity of. In the case of R19, down from 75 to 45 dwellings. The AFC states that the reasons for the reduction in projected contribution from this site include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitat impacts; and flooding.
2.28 The PSLP also suggested that there was "potential" for proposed allocation to accommodate a care home of around 40 beds. As noted in our PSLP representations, the PSLP provides little confidence there is reasonable prospect of a care home being delivered through development of this site.
2.29 In light of the additional concerns now set out in the AFC, prospects of provision of specialist accommodation to meet the needs of older people are further diminished.
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Overview
2.30 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.
2.31 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.
2.32 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.
2.33 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.
2.34 The AFC does not address the potential implications for the provision of accommodation for older people in light of the concerns it has identified in respect of proposed allocation R19. It neither explains why the site's potential to accommodate a care home is unaffected by the concerns it identifies, nor propose anything to address potential shortfall of this form of specialist accommodation assuming its potential to be provided here is affected.
2.35 The AFC not only fails to ensure the Local Plan is sound, but it actually exacerbates problems that were present in the PSLP.
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2.36 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.
3.0 Other soundness concerns resulting from delays to the Local Plan
3.1 As we noted in our PSLP representations (paragraph 12) the NPPF requires strategic policies to look ahead over a minimum of 15 years from the date of adoption. Within the same paragraph we noted that even assuming (optimistically) adoption of the Local Plan in 2019, the PSLP would only cover a 14-year period and as such does not conform to national policy.
3.2 It is now clear that the Local Plan will not be adopted in 2019. Adoption before the end of 2020 is considered optimistic. Before the end of 2021 is more realistic. As such, the Local Plan's strategic policies would - as currently proposed - only last for 13 years at best; more likely, they would cover a 12-year period from adoption.
3.3 This is evidently contrary to the NPPF's requirement to cover a minimum of 15 years.
4.0 Curing defects
4.1 In order to address the issues set out within this representation, it is necessary to ensure the Local Plan compensates for the reduction of 70 dwellings to be delivered in the early years of the plan period resulting from the revised capacity assessment of four proposed allocations in an effective and justified manner, and one which ensures the Local Plan is consistent with national policy and positively prepared. In this instance, this necessitates identifying additional allocation(s) which:
a) Together, in total, will deliver at least 70 additional homes; and
b) Can deliver this number of homes in the early years of the plan period (2022/23 - 2024/25).
4.2 Furthermore, additional allocations should also include those which will contribute towards meeting the accommodation needs of older people, given that the Council has identified concerns relating to a proposed allocation in which the PSLP states there is potential for a care home.
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4.3 As a site capable of delivering approximately 60 homes along with extra care accommodation (Use Class C2), allocation of site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above.
4.4 As set out within our representations on the Local Plan, the Council already has sufficient evidence to demonstrate site 219 is suitable, available, and achievable for residential development along with extra care accommodation; can be delivered in the short term; and that its allocation would be justified, effective, consistent with national policy, and contribute towards ensuring the Local Plan is positively prepared.
4.5 In addition, and separately, it is imperative to amend the PSLP to ensure the Local Plan will contain strategic policies which cover at least 15 years. As such, the plan period should be extended to 2036 and modifications proposed to ensure development needs for this period are addressed.
4.6 For the avoidance of doubt, the above actions are considered necessary in relation to the matters addressed by the AFC. We have identified separate and additional concerns (along with suggested actions to cure such defects) in respect of the soundness of the PSLP as a whole within our previous representations made at the appropriate time. These concerns remain.

The 2.8 ha of land at Crow Green Lane, Pilgrims Hatch owned by Wiggins Gee Homes Limited is in single ownership, available now, and could be used for much needed affordable housing. It is not subject to objections from other major parties to the Local Plan preparation process. It does not have serious implications for local and regional infrastructure. It is located in the Local Plan's A12 Growth Corridor, enjoying far better environmental and social conditions than some of the other allocations being proposed in this Corridor. Its effect on the Green Belt would be negligible compared to DHGV.

Brentwood Local Development Plan
Addendum of Focussed Changes to the Pre
Submission Local Plan
(Regulation 19) Consultation
1. The focussed changes amount to reducing the capacity of proposed housing land allocations R18, R19, R25 and R26 by a total of 70 units, and transferring it to the Dunton Hills Garden Village Strategic Allocation Policy R01 (I).
2. The focussed changes document sets out reasons for reducing the estimated capacity of allocations R18, R19, R25 and R26. The reductions are being made as a result of concerns expressed in responses to the Pre-Submission Local Plan consultation earlier this year. These concerns related to a range of factors including development in the Green Belt, access, traffic generation, impact on wildlife and the natural environment, and flood risk. All of these factors would have been considered by the Local Planning Authority (LPA) in their original selection of these sites for inclusion in the Pre-Submission draft. This underlines the subjective nature of many planning criteria, the need for flexibility and the avoidance of fixed attitudes in the evaluation of development land allocations.
3. As brief as they were, at least some justification underlies reducing R18, R19, R25 and R26's potential capacity. No justification is given for transferring this lost capacity to the Dunton Hills Garden Village Strategic Allocation. Perhaps the LPA thinks there is no need for an explanation. Dunton Hills Garden Village is a big enough hole in which to lose an extra 70 houses without having to think about any alternative solution.
4. As we made clear in our representations to the Pre-Submission Local Plan consultation, we think Dunton Hills Garden Village is surrounded by too much controversy and too many outstanding issues over the timing of housing delivery and the capacity of local and regional infrastructure to fully support this strategic proposal. Brentwood's immediate neighbours continue to maintain strong opposition to the proposal, as was made clear in the report to the Policy, Resources & Economic Development Committee at their meeting on 11 September 2019.
5. The LPA is surely ill-advised to regard Dunton Hills Garden Village as a sort of "cure-all" repository for the Borough's planning problems, when it is the subject of such a degree of uncertainty and controversy. There is a very simple solution as to where to re-locate the 70 or so units lost from R18, R19, R25 and R26; the 2.8 ha of land at Crow Green Lane, Pilgrims Hatch that we have been promoting on behalf of the owners, Wiggins Gee Homes Limited. Here is a site, in single ownership, that is available now, which could be used for much needed affordable housing. It is not subject to objections from other major parties to the Local Plan preparation process. It does not have serious implications for local and regional infrastructure. It is located in the Local Plan's A12 Growth Corridor, enjoying far better environmental and social conditions than some of the other allocations being proposed in this Corridor.
6. The Crow Green Lane site's only sin is its location in the Metropolitan Green Belt. But then so are many of the Plan's other proposed allocations. Its effect on the Green Belt would be negligible compared to the strategic hole that would be created by Dunton Hills Garden Village Policy R01 (I), threatening the Green Belt's integrity in this part of Essex.
7. The Pre-Submission Local Plan would be made more sound by transferring the 70 dwellings from allocations R18, R19, R25 and R26 to the certainty of the land at Crow Green Lane, rather than the uncertainty and controversy of the proposed Dunton Hills Garden Village.
8. This representation should be read in conjunction with our clients' responses earlier this year to the Pre-Submission Local Plan Consultation. We confirm we are agreeable to this representation being passed to the Inspectorate along with previous representations.