The Council is broadly supportive of policy PC07 and considers it to be in general accordance with national policy and other local and national objectives. The Council considers the sequential approach taken to prioritising the siting of such uses to be appropriate and supports the use of a retail hierarchy that principally prioritises the siting of such uses in Brentwood's town centres. It is recognised, however, that Brentwood Borough Council may need to review its policy approach early to reflect the retail and leisure strategies of the emerging South Essex Joint Strategic Plan.

The Council welcomes the recognition of the Essex Coast RAMS project and acknowledges the identified need to seek financial contributions to mitigate the impact on protected habitats sites of increased recreational disturbance resulting from housing growth. The Council notes that a supplementary planning document is currently being prepared jointly by a collective of authorities, including both Rochford and Brentwood Councils. This supplementary planning document is expected to provide a robust policy mechanism for the collection of these financial contributions. The Council is satisfied that policy NE02 is a sound and legally compliant approach to funding mitigation as part of the Essex Coast RAMS

The Council is generally supportive of policies BE18 and BE23 and consider them to broadly align with national policy and local and national objectives.
The Council would also like to highlight the role of emerging strategic evidence including the South Essex Green and Blue Infrastructure Study and South Essex Playing Pitch Strategy (including likely future revisions). The Council would encourage Brentwood Borough Council to consider how green and blue infrastructure within its Borough can support, connect and enhance existing green and blue infrastructure networks across South Essex and how new strategic infrastructure can be delivered to support the growth ambitions of the region. The Council would encourage Brentwood Borough Council to continue to engage with its neighbouring authorities through the Association of South Essex Local Authorities (ASELA), and the South Essex Joint Strategic Plan, to ensure that opportunities to deliver strategic green and blue infrastructure networks across South Essex are maximised through the JSP

The Council does not object to the principle of allocating land at Dunton Hills for a new garden village. The advantages of encouraging growth through strategic-scale development and adoption of garden principles are noted, including the opportunity to provide a "critical mass" of population for the purposes of securing meaningful infrastructure improvements and providing the conditions for a sustainable and healthy community to thrive. This approach is considered to broadly align with national policy and emerging Government objectives.
Brentwood Borough Council should, however, satisfy itself and the Inspector that the proposed allocation is capable of sustainably and viably accommodating the level of growth proposed and securing the infrastructure needed. It must be shown that due consideration has been given to the cumulative impacts of growth likely to come forward in the environs of Dunton Hills, including in neighbouring Basildon and Thurrock Boroughs, and that Duty to Co-operate requirements between Brentwood and these Boroughs have been fulfilled. Furthermore, transport improvements must be deliverable and viable to ensure that the impacts of growth at the scale proposed on the strategic highway network, including the A127, is capable of being mitigated.
It is acknowledged that the South Essex Joint Strategic Plan is likely to provide an overarching framework for the delivery of growth across South Essex, including by exploring opportunities for strategic-scale growth elsewhere through garden communities. The Council would therefore encourage Brentwood Borough Council to continue to engage through the Association of South Essex Local Authorities (ASELA) and the South Essex Joint Strategic Plan to ensure that the growth ambitions of the region can be realised in the most sustainable, effective and equitable way. This may require further consideration to be given to Dunton Hills and other proposed allocations to explore their capacity for delivering strategic-scale growth

The Council is broadly supportive of the proposed housing allocations within the draft Plan but suggests that Brentwood Borough Council should satisfy itself and the Inspector that the cumulative impacts of planned and unplanned growth on local and strategic infrastructure can and will be mitigated, both within Brentwood Borough and across South Essex as a whole. In particular, the extent and location of growth proposed should not place undue pressure on the strategic highway network, including the A127, unless adequate mitigation or improvements can be secured. Brentwood Borough Council must ultimately demonstrate that the level of growth planned is both deliverable and sustainable

The Council has no specific observations to make on Brentwood Borough Council's Draft Sustainability Appraisal or Habitats Regulations Assessment for the Pre-Submission Draft (Regulation 19).

The Council acknowledges that Brentwood Borough Council is a fellow member of the Association of South Essex Local Authorities (ASELA) and, as a result, is committed to the preparation of a South Essex Joint Strategic Plan (JSP). As Brentwood's Local Plan precedes the delivery of this joint plan, the Council contends that an early review of this plan will be necessary to reflect the emergence of the overarching framework for growth provided by the South Essex JSP. The Council would encourage Brentwood Borough Council to continue to positively engage through ASELA, and more widely as part of the Duty to Co-operate, to ensure that the aspirations and vision for South Essex, set out in the Memorandum of Understanding dated July 2018, can be realised in the most effective, sustainable and equitable way.
The Council does not dispute that Brentwood Borough Council has fulfilled its Duty to Co-operate with Rochford District Council in the preparation of this draft Plan