The Council supports Brentwood Borough Council's commitment to planning to meet its identified housing needs in full, plus the incorporation of a 20% buffer in supply. The incorporation of a buffer is considered to be a prudent and sensible approach to providing flexibility and contingency in supply and is considered to broadly align with national policy and government objectives.
The Council acknowledges the difficulties expressed by Brentwood Borough Council with regard to delivering homes at the significant higher rate in the short term and raises no objection, in principle, to the stepped delivery rates proposed, provided that Brentwood Borough Council satisfies itself and the Inspector that such a stepped approach is deliverable.
The Council suggests that an early review of the Plan will be necessary to reflect the emerging housing strategy of the South Essex Joint Strategic Plan and to reflect any implications this has on the delivery of housing within Brentwood Borough

The Council does not wish to raise any issues of soundness or legal compliance with respect to Brentwood Borough Council's proposed approach to strategic transport infrastructure but wishes to make the following general comments.
The Council is generally supportive of the commitments made to maximising and improving the capacity of strategic transport infrastructure within Brentwood Borough. The Council recognises the important potential for encouraging modal shifts and improvements to connectivity across South Essex to support the uptake of sustainable transport solutions and underpin the sustainable growth aspirations of the region.
The Council would support ongoing engagement with Essex County Council and other partners to ensure that opportunities to deliver sustainable transport improvements are maximised in the implementation phase of the draft Plan. Such improvements should consider linkages not just to and from London boroughs but across South Essex, recognising the role of Brentwood Borough as a gateway to and from London for communities across South Essex, including Rochford District. Exploration of the potential to deliver such improvements should also underpin the ongoing development of the South Essex Joint Strategic Plan.
The Council notes the proximity of the proposed Dunton Hills Garden Village to West Horndon and other railway stations. In order to sustainably manage the impact of such growth on the strategic highway network, Brentwood Borough Council should satisfy itself and the Inspector that West Horndon station can sustainably support the proposed growth at Dunton Hills and that connectivity to West Horndon station can comprehensively be planned for through the implementation of the Plan.
The Council supports the principle of delivering highway improvements through the implementation of the Plan and the ongoing development of the South Essex Joint Strategic Plan. In particular, the role of the A127 within South Essex, including for communities in both Brentwood and Rochford is recognised, as are its well-known capacity challenges at peak times. The commitment to a more co-ordinated approach to this key route is supported by a Statement of Common Ground which has been signed by local authorities along the route and Transport for London. Essex County Council, as highway authority for both authorities, should continue to be duly consulted to ensure that the impacts of planned growth on strategic highways across South Essex, including the quantum of growth set out in the draft Brentwood Plan, can adequately be mitigated and that strategic solutions can be planned for.

The Council is broadly supportive of Policy BE13 and acknowledges the importance of ensuring new developments are well supported by sustainable transport options. Policy BE13 is considered to broadly align with national policy and legislative requirements. Brentwood Borough Council, informed by Essex County Council and other partners, should satisfy itself and the Inspector that Policy BE13 will be positive and effective in ensuring that both planned and unplanned growth will be supported by suitable and convenient sustainable transport options and that therefore growth, as a whole, will have limited dependency on use of less sustainable transport options (e.g. use of the private car).

The Council is broadly supportive of Policy BE16 and acknowledges the importance of ensuring that new developments are sustainably supported by transport infrastructure. Policy BE16 is considered to accord with the minimum requirements under national policy and relevant legislation. Brentwood Borough Council, by taking an evidence-led approach and informed by Essex County Council, should satisfy itself and the Inspector that policy BE16 (and other relevant policies) can adequately ensure that both planned and unplanned growth will not place undue pressure on the strategic highway network, including the A127, without securing the necessary mitigation or improvements. The transport impacts of proposed developments, and the scope for improvements and other mitigation, should duly consider the impacts on communities and businesses beyond Brentwood's immediate administrative boundary, including those in Rochford District

The Council is broadly supportive of the provisions of policy HP01 and does not have any specific concerns around its soundness or legal compliance.

The Council acknowledges that demographic shifts and changing preferences are likely to increase the demand for specialist accommodation into the future, particularly forms of accommodation for older people. The Council supports Brentwood Borough Council's commitment to working with Essex County Council, and other partners, to consider how best to plan for changing preferences towards specialist accommodation.
The Council is broadly supportive of policy HP04 and considers it to generally accord with national policy and other local and national objectives. Brentwood Borough Council should, however, satisfy itself and the Inspector that the proposed policy will be adequate to meet identified specialist accommodation needs in full. Furthermore, the Council would support a commitment to reviewing this policy if a shortfall in provision is identified through monitoring. A review of this policy may also be needed to reflect the emerging housing strategy of the South Essex Joint Strategic Plan

The Council acknowledges that affordability of housing is an acute and strategic issue for the whole of South Essex, including both Rochford and Brentwood, and considers that one of the primary objectives of the South Essex JSP should be to address the impacts that a lack of affordability is having on the health and vitality of the region, including by seeking to significantly increase the delivery of affordable housing across South Essex.
The Council considers policy HP05 to broadly accord with the requirements of national policy and other local and national objectives. Brentwood Borough Council should, however, satisfy itself and the Inspector that the specific requirements of the policy are based on robust and proportionate evidence and that the proposed approach would be, in the main, viable. A review of this policy may also be needed to reflect the emerging housing strategy of the South Essex Joint Strategic Plan.

The Council supports Brentwood's commitment to meeting the identified accommodation needs for Gypsies and Travellers (meeting the PPTS definition) in full. Brentwood Borough Council should, however, satisfy itself and the Inspector that the proposed policy (and other relevant policies) would be deliverable at the site-level. Brentwood Borough Council should consider mechanisms for reviewing its policy approach if a shortfall in provision becomes evident through its monitoring, or to reflect any change in circumstances that arise through the development of a strategic approach as part of the emerging South Essex Joint Strategic Plan.

The Council is broadly supportive of policy PC01 and considers it to generally align with national policy and other local and national objectives. The Council particularly supports reference to the significance of technological improvements, changing working patterns and rural enterprise on the regional economy.
There is an expectation that the development of the South Essex Joint Strategic Plan will be a key driving force for realising an economic vision for the whole region. Fundamental to this vision will be complementary local and regional economic growth, diversification and improvements to connectivity. As a result, the principles of policy PC01 should not be considered to sit in isolation and should be considered to form building blocks for the development of wider economic aspirations beyond Brentwood's authority boundary. The Council would encourage Brentwood Borough Council to remain engaged as part of the Association of South Essex Local Authorities (ASELA) to ensure that the economic aspirations of the whole region can be realised, which are expected to complement and build upon the types of principles listed in policy PC01.

The Council is broadly supportive of policy PC02 and Brentwood Borough Council's suggested approach to delivering 47.4 hectares of new employment land. The Council does not have any detailed comments to make regarding the proposed allocation of specific sites; however, it considers that Brentwood Borough Council should satisfy itself and the Inspector that the impacts of developing such sites, considered cumulatively
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as part of Brentwood Borough Council's wider growth strategy, can and will be adequately mitigated, particularly for sites in proximity to key strategic routes including the A127. The Council considers that opportunities to integrate sustainable transport improvements and social infrastructure as part of new allocations should be maximised, informed by Essex County Council and other partners