To ensure more effective collaboration and joint working it is suggested that Brentwood Council should progress key strategic matters through the South Essex Joint Strategic Plan process as well as with individual local authorities on cross-boundary matters.

Brentwood Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. In addition to the preparation of the SGLS study which includes a high level housing land and capacity assessment, the South Essex authorities are in the course of commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a Strategic Green Belt review and further infrastructure studies.

The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the future approach to be taken in the Local Plan.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Notwithstanding any additional text to the plan setting out key cross-boundary issues it is considered that the Duty to Cooperate has not been met as Brentwood Council has not undertaken effective and on-going engagement regarding the Dunton hills Garden village.

The Brentwood Pre-Submission Local Plan has also therefore not been prepared with a positive and justified strategy.

Whilst in all other respects the Brentwood Plan appears to meet legal requirements it is considered that the Duty to cooperate requirements have not been fully complied with in particular with regard to development of the evidence base and the lack of proper response and agreed outputs by Brentwood Council for evidence and a response on Dunton Hills Garden Village (DHGV).

The National Planning Policy Framework 2018 (updated 2019) sets out in paragraphs 24 to 27 how local authorities should maintain effective cooperation under the Duty to Cooperate. Paragraph 26 highlights that cooperation needs to be effective and on-going between strategic policy-making authorities and relevant bodies to ensure the production of a positively prepared and justified strategy.

Paragraph 27 of the revised NPPF states that in order to demonstrate effective and on-going joint working, strategic policy-making authorities should prepare and maintain statements of common ground.

The updated Planning Policy Guidance for Plan Making (September 2018) includes a section for maintaining effective cooperation and expands on the detail on and for preparing statements of common ground. It is recognised that the duty to cooperate is not a duty to agree and such statements should include agreements and disagreements between strategic plan-making authorities.

There has been ongoing engagement with Brentwood Council under the Duty to Cooperate since the 2016 draft consultation Local Plan. It is recognised that Brentwood has undertaken consultation and engagement on its various technical studies such as the SHMA, employment study and Green Belt review through workshops, meetings and correspondence. There has been a specific workshop on the A127 and more recently Dunton Hills Garden Village. An officer working group set up to consider strategic transport matters and duty to cooperate has resulted in a Statement of Common Ground signed by South Essex authorities, the LB Havering and Highways England in 2018.

In addition a number of meetings have taken place between officers of Thurrock and Brentwood Council regarding the Brentwood Local Plan. At these DTC meetings Thurrock Officers have reiterated the objection to the Brentwood spatial strategy, Dunton Garden village and suggested that alternative options are investigated including potential development at West Horndon and in the A12 Corridor. More recently Thurrock Council has engaged with Brentwood on the preparation of the new Thurrock Local Plan. The new Thurrock local Plan is at issues and Options stage (regulation 18).

It is recognised that Brentwood Council has engaged more effectively on collaboration and joint working on strategic matters through membership of the Association of South Essex Councils (ASELA) and in the preparation of a South Essex Joint Strategic Plan (JSP).

Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.

In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.

More recently, as a member of ASELA, Brentwood Council have signed the Statement of Common Ground for the JSP and Planning Memorandum (MOU) in June/July 2018. A key issue for Brentwood is how the preparation of the Brentwood Local plan will align with the preparation of the South Essex Joint Strategic Plan.

It is acknowledged that additional or updated elements of evidence base has been produced by Brentwood Council since the last local plan consultation of 2016 including a strategic Housing Market assessment update 2018, draft Green Belt review and economic assessment. However other elements of the evidence base do not appear to have been produced or published to support the site proposals in the draft plan such as the HELAA, adequate transport assessment and mitigation and other infrastructure assessments.

Thurrock Council considers that there are key strategic issues and cross-boundary matters of importance in relation to the preparation of the Brentwood Local Plan that remain outstanding and should be addressed through further effective engagement and collaboration between Brentwood Council and Thurrock Council and with the other South Essex authorities under the Duty to cooperate. The key matters include:

* Confirmation of the Brentwood Objectively Assessed need and whether the borough can accommodate its need;
* The spatial strategy and alternative options within the A12 and A127 corridors to accommodate the growth;

* The Thurrock Council concerns regarding the justification of Dunton Garden Village and the need to consider alternative options including at West Horndon;
* Transport and other infrastructure Issues;
* Further development of the Brentwood Local Plan evidence base;
* The development of the South Essex Joint Strategic Plan and evidence.

In particular in recognition of the Thurrock concern about Dunton Hills Garden Village and due to its location close to and adjoining the boundaries between the two authorities Thurrock Council requests further engagement on this development and considerations of alternative options along the A127 Corridor and elsewhere.
Following representations on the earlier Preferred Site Allocation consultation 2018, a number of South Essex planning authorities including Basildon, Thurrock and Essex County Council sought further clarification with Brentwood regarding their concerns regarding the Dunton Hills Garden Village proposal including any comments on a draft of a DHGV development framework. Several joint meetings were held with Brentwood Council to identify the key issues and areas of concern.

Thurrock Council along with Basildon Borough Council and Essex County Council had submitted a joint report to Brentwood in September 2018 highlighting concerns to Brentwood Council regarding the Dunton Hills Garden Village proposal. No response on the matters set out in the document has been received from Brentwood Council.

The Pre-submission Brentwood Local Plan was approved by Brentwood Council in November 2018 without outstanding matters with adjoining the issues regarding Dunton Hills Garden Village having been clearly addressed and outcomes identified despite requests from the three other authorities including Thurrock.

A Duty to Cooperate Position Statement published as part of the Pre-submission consultation but does not include sufficient information about the key issues regarding cross-boundary matters between authorities. It is notes that the statement is intended to have Statements of Common Ground appended at a future date.

The South Essex authorities are considering spatial options to assess the capacity of South Essex to deliver its growth ambitions and have commissioned a strategic Growth Locations Study (SGLS) as part of the evidence to inform the Joint Strategic Plan preparation. In consideration of locations and strategic sites for growth a range of options will form part of the options testing as part of this study. Thurrock Council has previously considered it is premature for the Brentwood Plan to progress with the development of a large settlement such as Dunton Hills Garden village until the outcome of this options testing is known and the locations and nature of growth has been advanced with a degree of certainty and agreement with adjoining authorities due to the cross boundary implications.

To ensure more effective collaboration and joint working it is suggested that Brentwood Council should progress key strategic matters through the South Essex Joint Strategic Plan process as well as with individual local authorities on cross-boundary matters.

Brentwood Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. In addition to the preparation of the SGLS study which includes a high level housing land and capacity assessment, the South Essex authorities are in the course of commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a Strategic Green Belt review and further infrastructure studies.

The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the future approach to be taken in the Local Plan.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Notwithstanding any additional text to the plan setting out key cross-boundary issues it is considered that the Duty to Cooperate has not been met as Brentwood Council has not undertaken effective and on-going engagement regarding the Dunton Hills Garden village.

The Brentwood Pre-Submission Local Plan has also therefore not been prepared with a positive and justified strategy.

To ensure more effective collaboration and joint working it is suggested that Brentwood Council should progress key strategic matters through the South Essex Joint Strategic Plan process as well as with individual local authorities on cross-boundary matters.

Brentwood Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. In addition to the preparation of the SGLS study which includes a high level housing land and capacity assessment, the South Essex authorities are in the course of commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a Strategic Green Belt review and further infrastructure studies.

The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the future approach to be taken in the Local Plan.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Notwithstanding any additional text to the plan setting out key cross-boundary issues it is considered that the Duty to Cooperate has not been met as Brentwood Council has not undertaken effective and on-going engagement regarding the Dunton hills Garden village.

The Brentwood Pre-Submission Local Plan has also therefore not been prepared with a positive and justified strategy.

Whilst in all other respects the Brentwood Plan appears to meet legal requirements it is considered that the Duty to cooperate requirements have not been fully complied with in particular with regard to development of the evidence base and the lack of proper response and agreed outputs by Brentwood Council for evidence and a response on Dunton Hills Garden Village (DHGV).

The National Planning Policy Framework 2018 (updated 2019) sets out in paragraphs 24 to 27 how local authorities should maintain effective cooperation under the Duty to Cooperate. Paragraph 26 highlights that cooperation needs to be effective and on-going between strategic policy-making authorities and relevant bodies to ensure the production of a positively prepared and justified strategy.

Paragraph 27 of the revised NPPF states that in order to demonstrate effective and on-going joint working, strategic policy-making authorities should prepare and maintain statements of common ground.

The updated Planning Policy Guidance for Plan Making (September 2018) includes a section for maintaining effective cooperation and expands on the detail on and for preparing statements of common ground. It is recognised that the duty to cooperate is not a duty to agree and such statements should include agreements and disagreements between strategic plan-making authorities.

There has been ongoing engagement with Brentwood Council under the Duty to Cooperate since the 2016 draft consultation Local Plan. It is recognised that Brentwood has undertaken consultation and engagement on its various technical studies such as the SHMA, employment study and Green Belt review through workshops, meetings and correspondence. There has been a specific workshop on the A127 and more recently Dunton Hills Garden Village. An officer working group set up to consider strategic transport matters and duty to cooperate has resulted in a Statement of Common Ground signed by South Essex authorities, the LB Havering and Highways England in 2018.

In addition a number of meetings have taken place between officers of Thurrock and Brentwood Council regarding the Brentwood Local Plan. At these DTC meetings Thurrock Officers have reiterated the objection to the Brentwood spatial strategy, Dunton Garden village and suggested that alternative options are investigated including potential development at West Horndon and in the A12 Corridor. More recently Thurrock Council has engaged with Brentwood on the preparation of the new Thurrock Local Plan. The new Thurrock local Plan is at issues and Options stage (regulation 18).

It is recognised that Brentwood Council has engaged more effectively on collaboration and joint working on strategic matters through membership of the Association of South Essex Councils (ASELA) and in the preparation of a South Essex Joint Strategic Plan (JSP).

Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.

In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.

More recently, as a member of ASELA, Brentwood Council have signed the Statement of Common Ground for the JSP and Planning Memorandum (MOU) in June/July 2018. A key issue for Brentwood is how the preparation of the Brentwood Local plan will align with the preparation of the South Essex Joint Strategic Plan.

It is acknowledged that additional or updated elements of evidence base has been produced by Brentwood Council since the last local plan consultation of 2016 including a strategic Housing Market assessment update 2018, draft Green Belt review and economic assessment. However other elements of the evidence base do not appear to have been produced or published to support the site proposals in the draft plan such as the HELAA, adequate transport assessment and mitigation and other infrastructure assessments.

Thurrock Council considers that there are key strategic issues and cross-boundary matters of importance in relation to the preparation of the Brentwood Local Plan that remain outstanding and should be addressed through further effective engagement and collaboration between Brentwood Council and Thurrock Council and with the other South Essex authorities under the Duty to cooperate. The key matters include:

* Confirmation of the Brentwood Objectively Assessed need and whether the borough can accommodate its need;
* The spatial strategy and alternative options within the A12 and A127 corridors to accommodate the growth;

* The Thurrock Council concerns regarding the justification of Dunton Garden Village and the need to consider alternative options including at West Horndon;
* Transport and other infrastructure Issues;
* Further development of the Brentwood Local Plan evidence base;
* The development of the South Essex Joint Strategic Plan and evidence.

In particular in recognition of the Thurrock concern about Dunton Hills Garden Village and due to its location close to and adjoining the boundaries between the two authorities Thurrock Council requests further engagement on this development and considerations of alternative options along the A127 Corridor and elsewhere.
Following representations on the earlier Preferred Site Allocation consultation 2018, a number of South Essex planning authorities including Basildon, Thurrock and Essex County Council sought further clarification with Brentwood regarding their concerns regarding the Dunton Hills Garden Village proposal including any comments on a draft of a DHGV development framework. Several joint meetings were held with Brentwood Council to identify the key issues and areas of concern.

Thurrock Council along with Basildon Borough Council and Essex County Council had submitted a joint report to Brentwood in September 2018 highlighting concerns to Brentwood Council regarding the Dunton Hills Garden Village proposal. No response on the matters set out in the document has been received from Brentwood Council.

The Pre-submission Brentwood Local Plan was approved by Brentwood Council in November 2018 without outstanding matters with adjoining the issues regarding Dunton Hills Garden Village having been clearly addressed and outcomes identified despite requests from the three other authorities including Thurrock.

A Duty to Cooperate Position Statement published as part of the Pre-submission consultation but does not include sufficient information about the key issues regarding cross-boundary matters between authorities. It is notes that the statement is intended to have Statements of Common Ground appended at a future date.

The South Essex authorities are considering spatial options to assess the capacity of South Essex to deliver its growth ambitions and have commissioned a strategic Growth Locations Study (SGLS) as part of the evidence to inform the Joint Strategic Plan preparation. In consideration of locations and strategic sites for growth a range of options will form part of the options testing as part of this study. Thurrock Council has previously considered it is premature for the Brentwood Plan to progress with the development of a large settlement such as Dunton Hills Garden village until the outcome of this options testing is known and the locations and nature of growth has been advanced with a degree of certainty and agreement with adjoining authorities due to the cross boundary implications.

To ensure more effective collaboration and joint working it is suggested that Brentwood Council should progress key strategic matters through the South Essex Joint Strategic Plan process as well as with individual local authorities on cross-boundary matters.

Brentwood Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. In addition to the preparation of the SGLS study which includes a high level housing land and capacity assessment, the South Essex authorities are in the course of commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a Strategic Green Belt review and further infrastructure studies.

The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the future approach to be taken in the Local Plan.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Notwithstanding any additional text to the plan setting out key cross-boundary issues it is considered that the Duty to Cooperate has not been met as Brentwood Council has not undertaken effective and on-going engagement regarding the Dunton Hills Garden village.

The Brentwood Pre-Submission Local Plan has also therefore not been prepared with a positive and justified strategy.

It is considered the Brentwood Draft Local Plan and supporting evidence base will require further revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Brentwood Local Plan should be reviewed to take account of further technical evidence and potentially the outcome of other evidence including the testing of other spatial options being considered by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

It is recommended that specific additional evidence base required includes:
* An updated SHMA to take account of the Government policy requirements not to use the 2016-based household projections;
* Further evidence to have assessed the various spatial growth options;
* A more fully developed transport evidence base that includes cumulative and site specific impacts of development on the local and strategic highway network and to identify further infrastructure and /or mitigation measures required together with costing and phasing;
* An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability

Evidence: Thurrock Council has previously made representations on the Brentwood Local Plan at the draft 2016 Local Plan consultation and the 2018 Preferred Site Allocations regarding the lack of sufficient evidence base to support the policies and proposals in the emerging Local Plan.

It is acknowledged that with the publication of the Pre-Submission Brentwood Local Plan (Regulation 19) that significant progress has been made with the provision of new and updated evidence across a range of topic areas. Brentwood Council through its collaboration and support of the South Essex Joint Strategic Plan (JSP) has also been involved in the commissioning of technical evidence to support the JSP including the Strategic Growth Locations study (SGLS), Employment Land Review and Infrastructure Framework. The South Essex authorities are also intending to commission further technical evidence including Green and Blue Infrastructure, a Strategic Green Belt Review and viability work to support the JSP.

However Thurrock Council considers that there are still key elements of the current Brentwood Local Plan base evidence that provide insufficient detail, are out of date or are missing and therefore the local plan is not fully justified in its policies and proposals. Detailed comments regarding the lack of need to update evidence are made in other representations by Thurrock Council on the Pre-Submission Brentwood Local Plan (Regulation 19).

Thurrock Council considers the Brentwood Local Plan is currently unsound because of insufficient or lack of up to date evidence regarding:
* The transport modelling and mitigation measures to support the overall spatial strategy, transport policies and key development locations such as Dunton Hills Garden Village (DHGV);
* The Infrastructure Delivery Plan (IDP) has not been sufficiently developed or contain enough detail to support the growth strategy, policies and site allocations in the plan;
* The SHMA needs to be reviewed and updated to reflect the Government approach to assessing housing need;
* There is insufficient evidence across a range of evidence topics to support the Dunton Hill Garden Village (DHGV) proposal.

It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

Thurrock Council supports in principle the approach taken by Brentwood Council to accommodate its objectively assessed need within Brentwood's boundary, whilst recognising this is an ambitious growth agenda.

It is also recognised that Brentwood Council is committed as a member of the Association of South Essex Authorities (ASELA) to the long term South Essex 2050 Ambition and preparation of a statutory South Essex Joint Strategic Plan (JSP).

Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.

In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.

More recently, as a member of ASELA, Brentwood Council have signed the Statement of Common Ground for the JSP and Planning Memorandum (MOU) in June-July 2018. A key issue for Brentwood is how the preparation of the Brentwood Local plan will align with the preparation of the South Essex Joint Strategic Plan.

The Brentwood Local Plan is being prepared in advance of the South Essex Joint Strategic Plan. The current timetable for the Brentwood local Plan indicates the plan being adopted winter 2019. The South Essex Joint Strategic Plan is at an early stage of plan preparation and development of the technical evidence base. The JSP will initially cover a plan period up to 2038 and therefore five years beyond the Bentwood Local Plan period but will not be adopted until 2021 at the earliest.

Thurrock Council supports the recognition in the Brentwood Pre-Submission Local Plan (Regulation 19) in paragraphs 1.35 to 1.38 in the commitment to joint collaboration undertaken by ASELA, the South Essex 2050 growth and place-making agenda and the preparation of a South Essex Joint Strategic Plan.

Thurrock Council supports the approach in paragraph 1.38 that the Brentwood Local Plan is likely to need to be reviewed at least in part to ensure any opportunities for additional growth and infrastructure in the borough identified in the JSP can be realised.

Thurrock Council supports the approach that a review of the Brentwood Local Plan would be an effective mechanism to allow the policies and growth set out in the JSP to be incorporated into the Bentwood Local Plan and for future alignment of the timescales of both development plans.

It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

It is requested that Brentwood borough council clarify how the proposed settlement hierarchy is supported by the appropriate evidence base. Brentwood borough council should include appropriate reference to the evidence base on this matter in the supporting text

It is requested that Brentwood borough council clarify how the proposed settlement hierarchy is supported by the appropriate evidence base. Settlement Hierarchy - Paragraph 2.8 to 2.10; Figures 2.2 & 2.3

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

It is considered the Brentwood Draft Local Plan and supporting evidence base will require further major revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Brentwood Local Plan should be reviewed to take account of the outcome of testing of other spatial options being considered including the evidence by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

Further work is required to develop the evidence base including the justification for the selection of the spatial options and dismissal of reasonable alternatives, housing capacity and supply further transport evidence and other infrastructure.

Due to the issues highlighted in this response and to the earlier documents it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production. It is recommended that the Brentwood Plan with its current spatial strategy and site allocations should not be submitted for Examination.

The Brentwood Local Plan states in its vision that Brentwood is regarded as a collection of villages (including the proposed Dunton Hills Garden Village). The overall approach of the spatial strategy is to focus growth along two Transit Corridors in the borough at the Central Brentwood Growth Corridor/A12 and the South Brentwood Growth Corridor/A127.

Therefore the overall spatial strategy remains largely the same as the approach set out in the 2016 draft local plan and the 2018 Preferred Site Allocations consultation with development concentrated on land within the borough's transport corridors with Brentwood and Shenfield the main focus of development in the A12 corridor and strategic allocations in the A127 corridor at Dunton Hills Garden Village (35% housing Supply) and Brentwood Enterprise Park (58% of additional employment land). However the revised strategy restates maximising brownfield development and sustainable urban extensions in the transport corridors but also introduces limited growth at larger villages and reinforces the role of a new settlement at Dunton Hills Garden village including the potential for additional dwelling capacity at a later stage or beyond the plan period (up to 4,000 dwellings).

Thurrock Council has previously objected to the spatial strategy through its various iterations in previous stages of Brentwood Local Plan consultation and those objections remain. It is unclear why the spatial strategy should advocate a free-standing greenfield settlement in the Green Belt and why this should be the preferred location for development compared to existing settlement expansion or green field urban extensions which are likely to be more sustainable, less constrained and are closer to existing transport and other existing infrastructure and services.

The development of the Brentwood Local Plan spatial strategy appears to have:
* not considered a suitable range of reasonable alternative options that are easier to deliver and/or less constrained;
* put forward a large free standing settlement at Dunton Hills at an early stage which has pre-determined the spatial approach without being supported by the evidence;
* not assessed reasonable options for a free standing settlement or large scale settlement expansion elsewhere in the borough that should have been tested through local plan development evidence and SA process;
* developed a spatial strategy without key elements of the evidence base including land availability transport assessment;
* not taken account of the emerging spatial options being pursued by the adjoining authorities such as Thurrock and through the joint work of the South Essex authorities.

The Pre-submission local plan sets out the current position with regard to proposed housing supply with a total provision identified of 7,787 dwellings of which 6,088 dwellings are the proposed allocated sites and with Dunton Hills Garden Village allocation representing 35% of the Brentwood housing supply. This is a slight reduction is supply compared to the previous Preferred Options consultation stage.

Brentwood Council have produced a Housing and Economic Land Availability Assessment (HELAA) that identifies sites with just over 14,000 dwelling capacity that are deliverable and developable. It is unclear therefore why 35% of Brentwood's housing supply is focused on one large scale development in the very south of the borough.

A Site Assessment Study has been produced in 2018 that sets out how sites have been selected for inclusion as allocations. However it is also not fully clear how the sites for proposed allocations have been included and others discounted. Further evidence is required to understand why the proposed allocated sites are considered suitable and other potential allocations dismissed including using the existing evidence by undertaking updates to the land capacity and supply and further information provided from Green Belt review, landscape and infrastructure studies.

Thurrock Council remains concerned with regard to the spatial strategy and the levels and distribution of growth proposed between the A12 and A127 corridors and considers that Brentwood Council has not thoroughly tested reasonable alternative options or appropriately evidenced the spatial strategy in the pre-submission plan compared to alternatives. Thurrock Council also remains concerned about the identification and impact on the Green Belt of the proposed free standing Green Belt settlement of Dunton Hills Garden Village (DHGV). In addition limited new or updated evidence has been made available to demonstrate the deliverability or viability of such a scheme.

Thurrock Council considers that a more appropriate spatial strategy could be a variation of the previous spatial options with growth including Green Belt release concentrated in the A12 Brentwood/Shenfield corridor including at Ingatestone but with some potential along the A127 corridor including Green Belt release at West Horndon.

Further specific issues on the spatial strategy are set out below. This response should also be read in conjunction with comments submitted at the previous stage Growth Options consultation and the separate Dunton Garden Suburb Consultation.

A12 Corridor.
Thurrock Council considers there is further significant potential to provide housing and other development in the A12 Corridor Broad Area including the potential for urban edge expansion of settlements. Areas to the north of Brentwood and north, east and south east of Shenfield and Pilgrims Hatch south of Hutton and development of Ingatestone should be subject to further consideration for edge of settlement expansion as part of a Green Belt Review. It is considered due to the size and extent of the Green Belt in these locations that a limited number of urban expansions are less likely to have a significant harm to the openness of the Green Belt than locations in other broad areas.

The suggested A12 corridor locations have good existing transport services and community infrastructure and open space. The locations are also within reasonable distance of the railway stations.

Thurrock Council considers the role and potential economic and housing benefits of Crossrail in particular with regard to development at Shenfield have not been fully assessed and incorporated into the emerging Brentwood Local Plan, either as part of the current stage or previous consultations.

It is suggested that the role and development of Brentwood and in particular Shenfield as a terminus of Crossrail should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the undersupply of housing requirement currently identified in the Brentwood Local Plan options and supporting evidence.

The A12 widening and delivery of Crossrail will bring about significant increased capacity and accessibility improvements to transport infrastructure for Brentwood in the A12 Broad Corridor during the later-part of the plan period. This will make the A12 Corridor broad area more suitable for development opportunities.

There is also concern as regards the limited level of detail for the evidence base assessing the transport impacts of the various spatial strategy options and a detailed housing, economic and transport assessment of the impacts of Crossrail and with particular reference to Shenfield.








A127 Corridor

Thurrock Council remains concerned about the proposal for any large scale Strategic Green Belt releases either at Dunton Hill Garden Village or the previous option for the Dunton Garden Suburb. There does not appear to be a sufficiently robust evidence base to justify the development.

Dunton Hill Garden Village/Dunton Garden Suburb
Reference is also made below to the key Thurrock concerns regarding the free standing Dunton Hill Garden Village proposal (that are also covered in other representations) including:
* The Justification for such a free -standing settlement in this location;
* Significant impact and harm to the openness of the Green Belt;
* Coalescence of settlements;
* Detrimental impact on the Landscape;
* The lack of certainty regarding the deliverability of the development;
* Lack of detail on location and phasing of such a development;
* Lack of detail on the viability of such a proposal;
* Impact of the scale of development on adjoining housing markets and ability of Thurrock to deliver its housing;
* Infrastructure delivery and funding;
* Impact on strategic highway network - A127, A128, A13;
* Impact on the local highway network including within Thurrock;
* Lack of comprehensive transport modelling and mitigation measure;
* Assumptions and scoring in the SA/SEA.

Green Belt Issues on the A127 Corridor
The Brentwood Pre-submission Local Plan of 2019 identifies there are several sites for development of brownfield land and Green Belt release along the A127. It is considered that brownfield redevelopment and a Green Belt release at West Horndon would represent a suitable scale of housing development in this location.

It is considered any larger strategic Green Belt development at Dunton Hill Garden Village or the Dunton Garden Suburb or in combination with other development will have significant harm to the openness and function of the Metropolitan Green Belt. The Green Belt west and east of West Horndon meets the purposes of the Green Belt including preventing urban sprawl and coalescence between Basildon and West Horndon in the east and from West Horndon westwards to Cranham and Upminster in London.

The Dunton Hill Garden Village would result in a significant Green Belt release leaving a limited gap between Basildon and West Horndon. Any significant urban extension west of Basildon together with the Dunton Hill Garden Village would also result in potential coalescence and urbanisation of the A127 corridor resulting in significant harm to the openness and strategic function of the Green Belt.

Further Green Belt releases for employment land (Brentwood Enterprise Park) at Junction 29 of the M25 with A127 taken together with a strategic release for housing at Dunton Hills Garden Village will also contribute to a cumulative impact on the openness of the Green Belt in this corridor.

Road Capacity and Impact
The A127 is at capacity at peak times and does not represent a better road transport alternative to the A12. Any larger development is going to require additional road infrastructure investment to improve access. It is noted that further work to assess the capacity and improvements is required to be undertaken by the Local authorities and Essex County. This information should have been available at the pre-submission stage of the plan. In terms of the impact on the A128 there are key maintenance safety mitigation measures that have not been properly identified or addressed.

Employment Provision - Brentwood Enterprise Park
The Brentwood Plan and supporting evidence identifies the requirement for additional employment land. However it is unclear why the employment sites at Brentwood Enterprise Park (Site ref E11), Land at East Horndon Hall (site ref E13) and at Dunton Hills Garden Village (site ref part R01) are proposed in the draft Local Plan. It is not always the case that employment land should be located at busy junctions or along the A127 corridor where it would add to traffic flows on a road at current capacity. The sites are not located close to existing centres and are without easy access for workers other than by car. Alternative locations and options should be investigated including the A12 corridor possibly as part of edge of settlement expansion and in mixed use schemes.

It is considered that the Brentwood Local Plan will need to be re-assessed in light of the implications of the Government requirement to use the standard methodology with CLG 2014-based household projections.
The plan will need to be revised make provision for a higher housing target and provision for additional housing sites to provide a contingency buffer.
In light of the revised housing baseline figures the SA will need to be reviewed to take account of this requirement.
Technical evidence and the IDP will need to be reviewed and where necessary amended to take account of revised housing target.
The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a further review of the South Essex SHMA that would incorporate the outcome of changes to projections and methodology referred to above. It is considered that as a partner in the joint working that Brentwood Council should include any review of its OAHN in the South Essex review SHMA.

The Pre-Submission Brentwood Local Plan (Regulation 19) fails to take into account the latest Government approach (as published in February 2019) to housing need assessment and use of the appropriate household and demographic data and is therefore considered unsound. The baseline housing target in the pre-submission plan of 350 dwellings per annum is now considered inappropriate and out of date. The upper end flexible target of 456 dwellings per annum is now just above the baseline requirement of 452pa as set out in the standard methodology approach.

It is noted that the previous Preferred Site Allocations consultation of 2018 had been based on the then January 2018 Strategic Housing Market Assessment of Objectively Assessed Housing Need providing a figure of 380 dwellings per annum and 7600 dwellings over the plan period 2013-2033. The OAHN figure was based upon a demographic derived need of 280 dpa uplifted by 30% to take account of market signals and 6% contingency figures to allow for possibility of increase due to new official population and housing projections. There is no employment uplift to these figures. The objectively assessed need was therefore using an approach set out in Planning Practice that related to the NPPF of 2012. The Government had published in September 2017 draft options for a standard methodology. The draft target for Brentwood using this methodology and based upon the 2014 CLG Household Projections was 454 dwellings.

Due to the uncertainty regarding the proposed Government options for assessment of need and pending new demographic projections Brentwood Council plan housing target numbers slightly above the then assessed objectively assessed housing need to allow some degree of flexibility and to make a contingency. Furthermore it is noted that the Council considered that there was potential to accommodate the housing numbers proposed by the Government proposed standardised methodology at Dunton Hills Garden Village. Thurrock Council had sought further clarification as to the actual level of housing requirement and provision that will be included in the local plan and that this can be accommodated within the Brentwood Borough boundary.

The revised NPPF and Guidance of July 2018 stated the standard methodology should be used for calculating objectively assessed need and use of the most recently published household projections. At the time the 2014 CLG based Household Projection formed the starting point with a OAN figure of 452 homes per annum.


In September 2018, ONS published 2016-based Household Projections. Using the standard methodology these projections show a reduced rate of household growth resulting in a reduced housing requirement for Brentwood of 350 dwellings per annum. It is this figure that have been used to assess the OAN for Brentwood in the revised SHMA of November 2018 and incorporated as the baseline housing target figure in the Pre-Submission Brentwood Local Plan (Regulation 19). The Pre-Submission Plan includes a higher figure of 456 dwellings per annum as an upper range to provide flexibility and act as a contingency figure. The total housing provision in the Brentwood local plan is 7,752 dwellings between 2016-2033 (456 dwellings per annum).

However in February 2019 the Government published a revised NPPF, Planning Guidance and response to its consultation on assessing need. It has made clear that the 2016-based household projections should not be used for the standard methodology calculation and the 2014 CLG household projections used instead.

Therefore the Brentwood Pre-Submission Local Plan (Regulation 19) in making an upper provision for up to 456 homes per annum just meets the OAN for housing in the plan period having regard to the current standard methodology. However the baseline housing target of 350 dwellings is now based upon a methodology that does not comply with Government Policy. This calls into question the soundness of the plan but also means the plan no longer provides for a contingency above the OAN and no buffer requirement to meet any failure of the thresholds of the housing delivery test.

The Government's recently published Housing Delivery Test figure for Brentwood indicate that it is required to provide a 20% buffer. As the Housing requirement for Brentwood is now based upon the higher standard methodology figure of 452 dwellings per annum. It is unclear whether Brentwood is able to meet these figures for its five year supply as the Pre-submission plan housing trajectory was assuming 310 dwellings in the early period of the plan.

It is considered that the Brentwood Local Plan will need to be re-assessed in light of the implications of the Government requirement to use the standard methodology with CLG 2014-based household projections.
The plan will need to be revised make provision for a higher housing target and provision for additional housing sites to provide a contingency buffer.
It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

The overall approach of the Brentwood Local Plan remains the same as the previous consultations of the draft 2016 plan and 2018 Preferred Site Allocations consultation with Brentwood Council proposing to accommodate all of the identified objectively assessed need for housing and employment within the Borough Boundary during the plan period. However the period of the plan now covers 2016-2033. The Local Plan includes a revised housing requirement of 7,752 dwellings (up from 7,240 dwellings in the 2016 Local Plan consultation and up from 7600 dwellings in the 2018 consultation) and a provision of approximately 47.4ha of net employment land.

Brentwood Council intends to plan for housing numbers and land supply above its assessment of identified Objectively Assessed Housing Need of 350 dwellings per annum to allow some degree of flexibility and to make a contingency for future housing requirements. Furthermore it is noted that Brentwood Council considers that there is potential to accommodate the housing numbers proposed by the Government standardised methodology with further capacity at Dunton Hills Garden Village.

Thurrock Council seeks further clarification as to whether level of growth proposed for Brentwood could be accommodated in the plan in light of the concerns with regard to the assessment of housing need being required to be altered to meet Government policy at 452 dpa and due to the current concerns regarding the proposed strategic location at Dunton Hills Garden Village to accommodate this growth. Thurrock Council would wish to further engage with Brentwood Council to discuss other alternative options in the borough including at West Horndon.

The Pre-Submission Brentwood Local Plan (Regulation 19) fails to take into account the latest Government approach (as published in February 2019) to housing need assessment and use of the appropriate household and demographic data and is therefore considered unsound. The baseline housing target in the pre-submission plan of 350 dwellings per annum is now considered inappropriate and out of date. The upper end flexible target of 456 dwellings per annum is now just above the baseline requirement of 452pa as set out in the standard methodology approach.

Therefore the Brentwood Pre-Submission Local Plan (Regulation 19) in making an upper provision for up to 456 homes per annum just meets the OAN for housing in the plan period having regard to the current standard methodology. However the baseline housing target of 350 dwellings is now based upon a methodology that does not comply with Government Policy. This calls into question the soundness of the plan but also means the plan no longer provides for a contingency above the OAN and no buffer requirement to meet any failure of the thresholds of the housing delivery test.

The Government's recently published Housing Delivery Test figure for Brentwood indicate that it is required to provide a 20% buffer. As the Housing requirement for Brentwood is now based upon the higher standard methodology figure of 452 dwellings per annum. It is unclear whether Brentwood is able to meet these figures for its five year supply as the Pre-submission plan housing trajectory was assuming 310 dwellings in the early period of the plan.

* It is considered that the Brentwood Local Plan will need to be re-assessed in light of the implications of the Government requirement to use the standard methodology with CLG 2014-based household projections.
* The plan will need to be revised make provision for a higher housing target and provision for additional housing sites to provide a contingency buffer.

It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

It is recommended that specific additional evidence base required includes:
* A more fully developed transport evidence base that includes cumulative and site specific impacts of development on the local and strategic highway network and to identify further infrastructure and /or mitigation measures required together with costing and phasing;
* An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability.

Despite the need for further clarification on the transport network impacts, there is an opportunity to work collaboratively on the plan to deliver sustainable transport measures that will benefit Thurrock. The Southern Growth Corridor includes measures as the West Horndon New Transport Interchange, a new multi-modal interchange at West Horndon Station that could also serve Northern Thurrock developments. Cycle routes on this part of the plan can also be connected with Thurrock's network.

Sustainable Transport and Transport Policies

Whilst Thurrock Council supports in principle the overall aims of the sustainable transport Policies in the Brentwood Pre-Submission Local Plan (Regulation 19) it is concerned about the realism and practical deliverability of this approach.

Both the Brentwood Pre-Submission Local Plan and the IDP refer to ongoing work with other stakeholders or further evidence being required. There is insufficient information in the plan policies and supporting test about the actual schemes and measures that are required to deliver such an overall transport strategy. Although additional information is provided on schemes in the Infrastructure Delivery Plan (IDP) it is still considered there is not enough evidence in terms of the transport measures; their costs and phasing to support the proposals in the Local Plan including at Dunton Hills Garden Village.

Generally, there seems to be insufficient information to support the change in travel behaviour that is needed to support the ambition and policies of the local plan. More information is needed in relation to sustainable travel initiatives, cost of implementation/operation (where relevant) and, importantly, how residents and commuters will be encouraged and empowered to use and embrace the suggested sustainable travel initiatives. It is unlikely that simply delivering more cycle routes, cycle parking provision, EV charging etc will result in the required increase in sustainable modes of travel, without some form of behavioural change provision. It is unclear how the suggested improvements to walking, cycling, public transport and EVs will deliver meaningful benefit if they are not supported by a package of behaviour change components which set out and support the need to use sustainable travel options.

It is encouraging to note in the IDP that the travel survey data which identifies the levels of travel to work by train and those travelling to work driving by car or van. However, it is also noted that cycling, walking and bus travel to work are lower in Brentwood than the East of England. Promotion of walking and cycling is recognized in the plan through extending the Public Rights of Way network and the introduction of strategic walking and cycling routes for new sites.

Thurrock Council would suggest that more can be done to ensure that, where possible, these should be connected with the wider network, including Thurrock's network, especially on the south corridor.

While it is encouraging that the plan identifies the need to maximise the value of railway connectivity through improvements to the train stations in the borough, there is need for more clarity in terms of measures, costs and phasing of works.

The A12 widening and delivery of Crossrail will bring about significant increased capacity and accessibility improvements to transport infrastructure for Brentwood in the A12 Broad Corridor during the later-part of the plan period. This will make the A12 Corridor broad area more suitable for development opportunities. It is considered there is insufficient information on the benefits of Crossrail or the transport measures that should be provided if such an option is pursued.

The plan recognises that there has been no major relief, gyratory or one-way system within the town centre, and that traffic continues to be funnelled into a road system that has not significantly changed for many years. Additional AQ monitoring data should be included. It would also be beneficial to understand how the sustainable travel initiatives, identified within the plan, will deliver AQ and health benefits.

Transport Technical evidence
The Modelling description provided within the Transport and Movement section is somewhat vague. It mentions three scenarios: Base Case (observed data), Reference Case (background growth) and Local Plan Growth (adding on trips associated with the Local Plan proposals); and the use of spreadsheet model. However, there is no mention of data collection (source, year, etc.), only the use of digital road network for Essex with flows and speed at the links. It is considered that additional data collection is needed to inform the plan.
For trip distribution and assignment models, there is no mention of the software of procedure used. This information is also omitted from the junction models, although it is noted that this may be contained in supporting documentation elsewhere.

The evidence lists junctions that are "under stress", but it is not clear if this means that the junctions are saturated. There is no additional detail as to what level of stress or saturation is experienced. Therefore it is difficult to understand the extent of the existing or future issues that might be experienced.

For the junctions that are listed, there is no mention of problems in the Base Case (level of services, delays, speeds, etc.) or the expected impact for the Local Plan Growth scenario. It is suggested that additional work is needed here.

Thurrock Council suggests that additional work is needed in relation to the breakdown of costs and phasing of delivery. Again, without this information, it is difficult to understand the impact on the wider network and Thurrock area.

Despite the need for further clarification on the transport network impacts, there is an opportunity to work collaboratively on the plan to deliver sustainable transport measures that will benefit Thurrock. The Southern Growth Corridor includes measures as the West Horndon New Transport Interchange, a new multi-modal interchange at West Horndon Station that could also serve Northern Thurrock developments. Cycle routes on this part of the plan can also be connected with Thurrock's network.