Support the Policy as worded.

We believe this policy is basically sound in expecting some community return for the release of land from the Green Belt, and the creation of defensible boundaries for the longer term beyond the Plan period.
We note the type of community benefits being sought as set out in paragraph 8.114. We have been promoting our client's site at Crow Green Lane, Pilgrims Hatch and have consistently included in our proposals provision for a community facility. The type of facility provided would be determined in consultation with the local community.
Paragraph 8.115 mentions a need for smaller units to provide an option to older people wanting to downsize. Again we have consistently included provision within our proposals to meet exactly this particular housing need.
Policy NE13 calls for proposals on Green Belt allocations to establish long term defensible boundaries. Again we have consistently explained how good defensible boundaries can be established around our client's land.

Removal of Allocation R20. This is a small site and should be categorised as a potential windfall site. At present, there appears to be no certainty about its availability.

R10 - We also think that, without any direct evidence of intent on behalf of the landowner, Allocation R10 should also be removed.

Policy R11 - the third sentence of related paragraph 9.137 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 45 homes, anticipated to be delivered between 2023/24 and 2024/25"

Policy R13 - the third sentence of related paragraph 9.146 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 31 homes, anticipated to be delivered between 2023/24 and 2024/25"

All these policies relate to relatively small redevelopment sites within the urban areas of Brentwood and Shenfield. They have all been under consideration since consultations on the Local Plan began with the original Call for Sites in 2009. If indeed these sites are suitable, available and achievable it must be surprising that at least some of them are not yet developed, or in the process of being developed.
Policy R20 concerns the Eagle and Child PH in Shenfield, with an estimated delivery of 20 new dwellings between 2021/22 and 2022/23. This site is surely best regarded as a windfall site, contributing to this stream of new housing supply as and when it is finally redeveloped. The fact that it first appeared in 2009's Call for Sites suggests that there is no urgency on behalf of the current site owners to take things forward. No application has been submitted over the past five years.
Policies R10 to R15 all relate to sites in or close to Brentwood Town Centre. Four of the six are currently used as car parks, three for the town centre and the fourth is the station car park.
Allocation R10 is the Station Car Park. Many such car parks cannot cope with demand as railway passenger numbers continue to increase. Further parking provision will surely be required during the Plan period and, as with other station car parks, multi-storey provision must be one option for increased capacity. This would affect both redevelopment options and the potential number of new houses, if any, the site could provide. Unless the Borough Council can confirm a clear commitment to redevelopment on behalf of the owners that would provide the 100 homes being asked for, then it should be removed as an allocation. We note that delivery is timed for the very end of the Plan period, with a start in around ten years' time. Given what could happen in the intervening decade, we suggest that there is a strong degree of wishful thinking in proposing this land as a residential allocation.
Policies R11, R13 and R14 all relate to existing town centre car parks controlled by the Borough Council. Together they provide nearly 600 or 45% of the publicly available car parking in Brentwood Town Centre. We note that each policy does contain the following caveat:
"development proposals should consider wider Town Centre parking needs in collaboration with other development sites where there is existing parking on site, in order to ensure that current level of Town Centre public parking spaces is maintained".
This would suggest a high degree of cooperation is needed to achieve these sites' redevelopment and maintain the existing level of town centre car parking provision. All three sites have been under consideration since 2009. Anticipated delivery is as follows:
R11 Westbury Road car park - estimated 45 dwellings between 2020/21 and 2021/22, one to two years from now
R13 Chatham Way car park - estimated 31 dwellings between 2020/21 and 2021/22, one to two years from now

R14 William Hunter Way car park - estimated delivery of 300 dwellings between 2022/23 and 2028/29, three to nine years from now.
No planning applications have been submitted on either allocation R11 and R13 in the past five years. It is most unlikely that either site will be able to deliver in one to two years' time. The lead in time for R14 is longer, but again, no proposals for redevelopment here have been submitted in the past five years.
R12 is land at Hunter House, with anticipated delivery of 48 dwellings between 2024/25 and 2026/27. We assume the number of dwellings is based on the application submitted in 2017, and regarded by the Council as finally disposed by notice dated 10 January this year. Paragraph 9.142 referring to Allocation R12 states that the site will provide "... a mix of size and type of homes including affordable in accordance with the Council's policy requirements." It would appear that the applicants' decision not to provide affordable housing in their proposed scheme was one of the main issues of contention.
The latest Five Year Housing Land Supply Statement is for 31 March 2018, published in November 2018. It demonstrates a 4.1 year supply. Around half of the supply required (820 dwellings) during the period 2018 to 2023 is to come from allocations set out in the Pre-Submission Document. We believe there is considerable doubt over R11, R13 and R20's ability to deliver during this period.
The general point we are making here is that a number of the Pre-Submission Document's brownfield allocations have been under consideration for ten years or more. Some of them, like the town centre car parks, will be complicated to redevelop. We have emphasised throughout the Local Plan process that many of these sites were unlikely to make early contributions to meeting housing supply requirements, unlike our client's site at Pilgrims Hatch that is straightforward to develop and in a single, willing ownership. The problem remains, and supports our contention that the Plan needs more easier to develop sites, with an ownership ready to start.

Removal of Allocation R20. This is a small site and should be categorised as a potential windfall site. At present, there appears to be no certainty about its availability.

R10 - We also think that, without any direct evidence of intent on behalf of the landowner, Allocation R10 should also be removed.

Policy R11 - the third sentence of related paragraph 9.137 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 45 homes, anticipated to be delivered between 2023/24 and 2024/25"

Policy R13 - the third sentence of related paragraph 9.146 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 31 homes, anticipated to be delivered between 2023/24 and 2024/25"

All these policies relate to relatively small redevelopment sites within the urban areas of Brentwood and Shenfield. They have all been under consideration since consultations on the Local Plan began with the original Call for Sites in 2009. If indeed these sites are suitable, available and achievable it must be surprising that at least some of them are not yet developed, or in the process of being developed.
Policy R20 concerns the Eagle and Child PH in Shenfield, with an estimated delivery of 20 new dwellings between 2021/22 and 2022/23. This site is surely best regarded as a windfall site, contributing to this stream of new housing supply as and when it is finally redeveloped. The fact that it first appeared in 2009's Call for Sites suggests that there is no urgency on behalf of the current site owners to take things forward. No application has been submitted over the past five years.
Policies R10 to R15 all relate to sites in or close to Brentwood Town Centre. Four of the six are currently used as car parks, three for the town centre and the fourth is the station car park.
Allocation R10 is the Station Car Park. Many such car parks cannot cope with demand as railway passenger numbers continue to increase. Further parking provision will surely be required during the Plan period and, as with other station car parks, multi-storey provision must be one option for increased capacity. This would affect both redevelopment options and the potential number of new houses, if any, the site could provide. Unless the Borough Council can confirm a clear commitment to redevelopment on behalf of the owners that would provide the 100 homes being asked for, then it should be removed as an allocation. We note that delivery is timed for the very end of the Plan period, with a start in around ten years' time. Given what could happen in the intervening decade, we suggest that there is a strong degree of wishful thinking in proposing this land as a residential allocation.
Policies R11, R13 and R14 all relate to existing town centre car parks controlled by the Borough Council. Together they provide nearly 600 or 45% of the publicly available car parking in Brentwood Town Centre. We note that each policy does contain the following caveat:
"development proposals should consider wider Town Centre parking needs in collaboration with other development sites where there is existing parking on site, in order to ensure that current level of Town Centre public parking spaces is maintained".
This would suggest a high degree of cooperation is needed to achieve these sites' redevelopment and maintain the existing level of town centre car parking provision. All three sites have been under consideration since 2009. Anticipated delivery is as follows:
R11 Westbury Road car park - estimated 45 dwellings between 2020/21 and 2021/22, one to two years from now
R13 Chatham Way car park - estimated 31 dwellings between 2020/21 and 2021/22, one to two years from now

R14 William Hunter Way car park - estimated delivery of 300 dwellings between 2022/23 and 2028/29, three to nine years from now.
No planning applications have been submitted on either allocation R11 and R13 in the past five years. It is most unlikely that either site will be able to deliver in one to two years' time. The lead in time for R14 is longer, but again, no proposals for redevelopment here have been submitted in the past five years.
R12 is land at Hunter House, with anticipated delivery of 48 dwellings between 2024/25 and 2026/27. We assume the number of dwellings is based on the application submitted in 2017, and regarded by the Council as finally disposed by notice dated 10 January this year. Paragraph 9.142 referring to Allocation R12 states that the site will provide "... a mix of size and type of homes including affordable in accordance with the Council's policy requirements." It would appear that the applicants' decision not to provide affordable housing in their proposed scheme was one of the main issues of contention.
The latest Five Year Housing Land Supply Statement is for 31 March 2018, published in November 2018. It demonstrates a 4.1 year supply. Around half of the supply required (820 dwellings) during the period 2018 to 2023 is to come from allocations set out in the Pre-Submission Document. We believe there is considerable doubt over R11, R13 and R20's ability to deliver during this period.
The general point we are making here is that a number of the Pre-Submission Document's brownfield allocations have been under consideration for ten years or more. Some of them, like the town centre car parks, will be complicated to redevelop. We have emphasised throughout the Local Plan process that many of these sites were unlikely to make early contributions to meeting housing supply requirements, unlike our client's site at Pilgrims Hatch that is straightforward to develop and in a single, willing ownership. The problem remains, and supports our contention that the Plan needs more easier to develop sites, with an ownership ready to start.

Removal of Allocation R20. This is a small site and should be categorised as a potential windfall site. At present, there appears to be no certainty about its availability.

R10 - We also think that, without any direct evidence of intent on behalf of the landowner, Allocation R10 should also be removed.

Policy R11 - the third sentence of related paragraph 9.137 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 45 homes, anticipated to be delivered between 2023/24 and 2024/25"

Policy R13 - the third sentence of related paragraph 9.146 should be re-worded, for the reasons outlined in our answer to Question 5 above, as follows:
"The site will provide for around 31 homes, anticipated to be delivered between 2023/24 and 2024/25"

All these policies relate to relatively small redevelopment sites within the urban areas of Brentwood and Shenfield. They have all been under consideration since consultations on the Local Plan began with the original Call for Sites in 2009. If indeed these sites are suitable, available and achievable it must be surprising that at least some of them are not yet developed, or in the process of being developed.
Policy R20 concerns the Eagle and Child PH in Shenfield, with an estimated delivery of 20 new dwellings between 2021/22 and 2022/23. This site is surely best regarded as a windfall site, contributing to this stream of new housing supply as and when it is finally redeveloped. The fact that it first appeared in 2009's Call for Sites suggests that there is no urgency on behalf of the current site owners to take things forward. No application has been submitted over the past five years.
Policies R10 to R15 all relate to sites in or close to Brentwood Town Centre. Four of the six are currently used as car parks, three for the town centre and the fourth is the station car park.
Allocation R10 is the Station Car Park. Many such car parks cannot cope with demand as railway passenger numbers continue to increase. Further parking provision will surely be required during the Plan period and, as with other station car parks, multi-storey provision must be one option for increased capacity. This would affect both redevelopment options and the potential number of new houses, if any, the site could provide. Unless the Borough Council can confirm a clear commitment to redevelopment on behalf of the owners that would provide the 100 homes being asked for, then it should be removed as an allocation. We note that delivery is timed for the very end of the Plan period, with a start in around ten years' time. Given what could happen in the intervening decade, we suggest that there is a strong degree of wishful thinking in proposing this land as a residential allocation.
Policies R11, R13 and R14 all relate to existing town centre car parks controlled by the Borough Council. Together they provide nearly 600 or 45% of the publicly available car parking in Brentwood Town Centre. We note that each policy does contain the following caveat:
"development proposals should consider wider Town Centre parking needs in collaboration with other development sites where there is existing parking on site, in order to ensure that current level of Town Centre public parking spaces is maintained".
This would suggest a high degree of cooperation is needed to achieve these sites' redevelopment and maintain the existing level of town centre car parking provision. All three sites have been under consideration since 2009. Anticipated delivery is as follows:
R11 Westbury Road car park - estimated 45 dwellings between 2020/21 and 2021/22, one to two years from now
R13 Chatham Way car park - estimated 31 dwellings between 2020/21 and 2021/22, one to two years from now

R14 William Hunter Way car park - estimated delivery of 300 dwellings between 2022/23 and 2028/29, three to nine years from now.
No planning applications have been submitted on either allocation R11 and R13 in the past five years. It is most unlikely that either site will be able to deliver in one to two years' time. The lead in time for R14 is longer, but again, no proposals for redevelopment here have been submitted in the past five years.
R12 is land at Hunter House, with anticipated delivery of 48 dwellings between 2024/25 and 2026/27. We assume the number of dwellings is based on the application submitted in 2017, and regarded by the Council as finally disposed by notice dated 10 January this year. Paragraph 9.142 referring to Allocation R12 states that the site will provide "... a mix of size and type of homes including affordable in accordance with the Council's policy requirements." It would appear that the applicants' decision not to provide affordable housing in their proposed scheme was one of the main issues of contention.
The latest Five Year Housing Land Supply Statement is for 31 March 2018, published in November 2018. It demonstrates a 4.1 year supply. Around half of the supply required (820 dwellings) during the period 2018 to 2023 is to come from allocations set out in the Pre-Submission Document. We believe there is considerable doubt over R11, R13 and R20's ability to deliver during this period.
The general point we are making here is that a number of the Pre-Submission Document's brownfield allocations have been under consideration for ten years or more. Some of them, like the town centre car parks, will be complicated to redevelop. We have emphasised throughout the Local Plan process that many of these sites were unlikely to make early contributions to meeting housing supply requirements, unlike our client's site at Pilgrims Hatch that is straightforward to develop and in a single, willing ownership. The problem remains, and supports our contention that the Plan needs more easier to develop sites, with an ownership ready to start.

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

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

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

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

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

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