Chapter 1. Introduction

Duty to Cooperate (page 14)

An updated Position Statement should be provided prior to submission of the Local Plan to explain the full extent of the cooperation undertaken and agreement reached with local authorities and prescribed bodies. This update should make clear the position reached in relation to DHGV, given the importance of this Strategic Allocation to the Local Pan.

6 Submitted forms, commenting on the SA and on the Local Plan.
Form A:Chapters 1-3,
Form B Chapter 4,
Form C Chapter 5,
Form D Chapter 6,
Form E Chapter 7,
Form F Chapter 9
These representations deal with the following chapters in the Plan:
* Chapter 1. Introduction
* Chapter 2. Borough of Villages
* Chapter 3. Spatial Strategy - Vision and Strategic Objectives
In relation to Chapter 1, under Sustainability Appraisal, we also comment on the Sustainability Appraisal report (AECOM, January 2019).

Within our response to question no. 5 below, reference is made to specific pages, paragraphs and/or policies.

Chapter 1. Introduction

Duty to Cooperate (page 14)

Paragraphs 1.11 to 1.15 of the Local Plan briefly describe the Duty to Cooperate, its legal requirements in this regard and its commitment to cooperating with neighbouring authorities and key organisations on strategic planning issues. Paragraph 1.14 indicates the Council will publish a Duty to Cooperate Position Statement to describe the ongoing engagement and provide an update on the activities undertaken so far.
The Duty to Cooperate was introduced by the Localism Act 2011, and is set out in section 33A of the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan preparation in the context of strategic cross boundary matters. This is picked up in the National Planning Policy Framework (NPPF) which makes it clear that (paragraphs 25 - 27):
(a) strategic policy-making authorities should collaborate to identify the strategic matters of relevance;
(b) effective and ongoing joint working between strategic policy-making authorities and relevant authorities is integral to the production of a positively prepared and justified strategy; and
(c) in order to demonstrate this, statements of common ground should be produced (in accordance with the Planning Practice Guidance (PPG) and made publicly available so as to ensure transparency.

The Position Statement makes it clear that engagement with a wide range of stakeholders has taken place over several years which is noted and supported, as it demonstrates a significant effort has been made. CEG can confirm such an effort has been made by the Council with them over the Dunton Hills Strategic Allocation. However, at present CEG is not convinced that the Position Statement demonstrates that the Council has complied with the duty. The Council itself describes the document as a 'snapshot' and an 'initial summary' suggesting more is being done.
The PPG places much more emphasis on statements of common ground as how strategic policy making authorities can demonstrate that a plan is based on effective cooperation and that they have sought to produce a strategy based on agreements with other authorities. The Council has not yet provided the level of detail set out in the PPG and this will need to be worked up in due course.
The PPG also indicates that as the duty relates to the preparation of the plan it cannot be rectified post-submission so if the Inspector finds that the duty has not been complied with the examination would not proceed further. It might well be the case that there is further evidence, to which the Council can point in demonstrating compliance with a duty but it does not appear to be publicly available.
CEG understands that discussions with various authorities and prescribed bodies are well advanced and that an updated Position Statement will be prepared prior to submission to fully document the level of cooperation and the extent of agreement reached.
It is noted that the Position Statement refers to Dunton Hills Garden Village (DHGV) and consultation with Homes England but makes no reference to consultation with other relevant authorities or prescribed bodies which CEG knows has occurred. The updated Position Statement and relevant Statements of Common Ground should explain the full extent of the cooperation and agreement that has been reached in relation to this Strategic Allocation, as CEG is aware that it has been very extensive.
Sustainability Appraisal (Local Plan, page 15) & Interim Sustainability Appraisal (January 2019)
The Planning and Compulsory Purchase Act 2004 makes clear that local planning authorities must carry out a process of sustainability appraisal alongside plan making. This approach is reinforced in the NPPF which states that local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant statutory tests. Sustainability appraisals are required to demonstrate how the plan has addressed relevant economic, social and environmental objectives and avoid significant adverse impacts, wherever possible.
The Council has prepared Interim Sustainability Appraisals throughout the preparation of the Local Plan and this has informed the Spatial Strategy. The latest Interim Sustainability Appraisal explains the seven alternative development scenarios considered and the reasons for supporting some scenarios over others. There is an assessment of each scenario against economic, social and environmental topics based upon the relevant evidence base for each topic. This assessment explains why some scenarios rank higher than others. The Interim Sustainability Appraisal is sound and has been prepared in accordance with legislative requirements and the NPPF.
CEG supports the conclusion regarding DHGV but considers that the Council should supplement the assessment of the options - this could be more empirical and provide a fuller explanation of the conclusions reached, with more cross reference to the outcomes of other evidence base. Furthermore, in considering landscape issues the assessment does not deal with the landscape capacity of sites or areas to accommodate new development.
South Essex Joint Strategic Plan (page 17 - 18)

The Council helpfully explains the progress that has been made on the Joint Strategic Plan (JSP) and the collaboration that has occurred on this. However, CEG considers that the relationship between the Local Plan and the JSP should be made clearer. It should be clearly explained that adoption of the JSP will only occur after the adoption of the Brentwood Local Plan and because of the timing the Brentwood Local Plan will contribute towards some of the growth requirements of the JSP. To address this, some modifications are suggested in response to question no. 6 below.
Chapter 2. Borough of Villages

CEG supports the characterisation of Brentwood as a Borough of Villages and the Borough Profile (February 2019) evidence base which describes the unique nature of a market town and surrounding villages set amongst countryside as fundamental to the Borough's character. CEG considers that it is entirely appropriate that this characterisation forms a central part of the Vision set out in Chapter 3 of the Local Plan.

Fig. 2.2 (Brentwood Borough Hierarchy) in the Local Plan draws from the existing and proposed settlement hierarchy diagrams set out in the Borough Profile, and shows in plan form how well the Local Plan proposals reflect the Borough of Villages character. This includes the DHGV proposal, which presents a very positive response to meet the Borough's housing needs and will fit into the hierarchy of settlements in the future as set out in Fig. 2.3 (Settlement Hierarchy) in the Local Plan.

Chapter 3. Spatial Strategy - Vision and Strategic Objectives

The Spatial Strategy identifies two growth areas which align with transport corridors; the Central Brentwood Growth Corridor and the South Brentwood Growth Corridor, within which DHGV is proposed. Development outside of these corridors will be limited to retain the local character of the Borough (paragraph 3.21).

The NPPF recognises that the supply of a large number of homes can often best be achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns (paragraph 72). The approach of planning for DHGV is consistent with this and retaining the local character of the Borough.

CEG supports the Vison, the Driving Factors, the Overarching Aims, Strategic Objectives and the Strategic Allocation of DHGV as part of the South Brentwood Growth Corridor set out in Chapter 3. The Spatial Strategy and Development Principles will deliver the Vision. Given the importance attributed to Brentwood as a Borough of Villages and the need for Brentwood to meet its housing needs, the Spatial Strategy is sound; it is positively prepared, justified and consistent with national policy.

Sustainability Appraisal (page 15)

CEG considers a supplementary note or the like should be prepared by the Council to provide a fuller explanation of the conclusions reached in the Interim Sustainability Appraisal and how this has informed the Spatial Strategy which has been adopted.

6 Submitted forms, commenting on the SA and on the Local Plan.
Form A:Chapters 1-3,
Form B Chapter 4,
Form C Chapter 5,
Form D Chapter 6,
Form E Chapter 7,
Form F Chapter 9
These representations deal with the following chapters in the Plan:
* Chapter 1. Introduction
* Chapter 2. Borough of Villages
* Chapter 3. Spatial Strategy - Vision and Strategic Objectives
In relation to Chapter 1, under Sustainability Appraisal, we also comment on the Sustainability Appraisal report (AECOM, January 2019).

Within our response to question no. 5 below, reference is made to specific pages, paragraphs and/or policies.

Chapter 1. Introduction

Duty to Cooperate (page 14)

Paragraphs 1.11 to 1.15 of the Local Plan briefly describe the Duty to Cooperate, its legal requirements in this regard and its commitment to cooperating with neighbouring authorities and key organisations on strategic planning issues. Paragraph 1.14 indicates the Council will publish a Duty to Cooperate Position Statement to describe the ongoing engagement and provide an update on the activities undertaken so far.
The Duty to Cooperate was introduced by the Localism Act 2011, and is set out in section 33A of the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan preparation in the context of strategic cross boundary matters. This is picked up in the National Planning Policy Framework (NPPF) which makes it clear that (paragraphs 25 - 27):
(a) strategic policy-making authorities should collaborate to identify the strategic matters of relevance;
(b) effective and ongoing joint working between strategic policy-making authorities and relevant authorities is integral to the production of a positively prepared and justified strategy; and
(c) in order to demonstrate this, statements of common ground should be produced (in accordance with the Planning Practice Guidance (PPG) and made publicly available so as to ensure transparency.

The Position Statement makes it clear that engagement with a wide range of stakeholders has taken place over several years which is noted and supported, as it demonstrates a significant effort has been made. CEG can confirm such an effort has been made by the Council with them over the Dunton Hills Strategic Allocation. However, at present CEG is not convinced that the Position Statement demonstrates that the Council has complied with the duty. The Council itself describes the document as a 'snapshot' and an 'initial summary' suggesting more is being done.
The PPG places much more emphasis on statements of common ground as how strategic policy making authorities can demonstrate that a plan is based on effective cooperation and that they have sought to produce a strategy based on agreements with other authorities. The Council has not yet provided the level of detail set out in the PPG and this will need to be worked up in due course.
The PPG also indicates that as the duty relates to the preparation of the plan it cannot be rectified post-submission so if the Inspector finds that the duty has not been complied with the examination would not proceed further. It might well be the case that there is further evidence, to which the Council can point in demonstrating compliance with a duty but it does not appear to be publicly available.
CEG understands that discussions with various authorities and prescribed bodies are well advanced and that an updated Position Statement will be prepared prior to submission to fully document the level of cooperation and the extent of agreement reached.
It is noted that the Position Statement refers to Dunton Hills Garden Village (DHGV) and consultation with Homes England but makes no reference to consultation with other relevant authorities or prescribed bodies which CEG knows has occurred. The updated Position Statement and relevant Statements of Common Ground should explain the full extent of the cooperation and agreement that has been reached in relation to this Strategic Allocation, as CEG is aware that it has been very extensive.
Sustainability Appraisal (Local Plan, page 15) & Interim Sustainability Appraisal (January 2019)
The Planning and Compulsory Purchase Act 2004 makes clear that local planning authorities must carry out a process of sustainability appraisal alongside plan making. This approach is reinforced in the NPPF which states that local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant statutory tests. Sustainability appraisals are required to demonstrate how the plan has addressed relevant economic, social and environmental objectives and avoid significant adverse impacts, wherever possible.
The Council has prepared Interim Sustainability Appraisals throughout the preparation of the Local Plan and this has informed the Spatial Strategy. The latest Interim Sustainability Appraisal explains the seven alternative development scenarios considered and the reasons for supporting some scenarios over others. There is an assessment of each scenario against economic, social and environmental topics based upon the relevant evidence base for each topic. This assessment explains why some scenarios rank higher than others. The Interim Sustainability Appraisal is sound and has been prepared in accordance with legislative requirements and the NPPF.
CEG supports the conclusion regarding DHGV but considers that the Council should supplement the assessment of the options - this could be more empirical and provide a fuller explanation of the conclusions reached, with more cross reference to the outcomes of other evidence base. Furthermore, in considering landscape issues the assessment does not deal with the landscape capacity of sites or areas to accommodate new development.
South Essex Joint Strategic Plan (page 17 - 18)

The Council helpfully explains the progress that has been made on the Joint Strategic Plan (JSP) and the collaboration that has occurred on this. However, CEG considers that the relationship between the Local Plan and the JSP should be made clearer. It should be clearly explained that adoption of the JSP will only occur after the adoption of the Brentwood Local Plan and because of the timing the Brentwood Local Plan will contribute towards some of the growth requirements of the JSP. To address this, some modifications are suggested in response to question no. 6 below.
Chapter 2. Borough of Villages

CEG supports the characterisation of Brentwood as a Borough of Villages and the Borough Profile (February 2019) evidence base which describes the unique nature of a market town and surrounding villages set amongst countryside as fundamental to the Borough's character. CEG considers that it is entirely appropriate that this characterisation forms a central part of the Vision set out in Chapter 3 of the Local Plan.

Fig. 2.2 (Brentwood Borough Hierarchy) in the Local Plan draws from the existing and proposed settlement hierarchy diagrams set out in the Borough Profile, and shows in plan form how well the Local Plan proposals reflect the Borough of Villages character. This includes the DHGV proposal, which presents a very positive response to meet the Borough's housing needs and will fit into the hierarchy of settlements in the future as set out in Fig. 2.3 (Settlement Hierarchy) in the Local Plan.

Chapter 3. Spatial Strategy - Vision and Strategic Objectives

The Spatial Strategy identifies two growth areas which align with transport corridors; the Central Brentwood Growth Corridor and the South Brentwood Growth Corridor, within which DHGV is proposed. Development outside of these corridors will be limited to retain the local character of the Borough (paragraph 3.21).

The NPPF recognises that the supply of a large number of homes can often best be achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns (paragraph 72). The approach of planning for DHGV is consistent with this and retaining the local character of the Borough.

CEG supports the Vison, the Driving Factors, the Overarching Aims, Strategic Objectives and the Strategic Allocation of DHGV as part of the South Brentwood Growth Corridor set out in Chapter 3. The Spatial Strategy and Development Principles will deliver the Vision. Given the importance attributed to Brentwood as a Borough of Villages and the need for Brentwood to meet its housing needs, the Spatial Strategy is sound; it is positively prepared, justified and consistent with national policy.

South Essex Joint Strategic Plan (page 17 - 18)

The below modifications are proposed paragraph 1.38 to ensure the Local Plan is positively prepared and the relationship between it and the JSP is clearer:

"Work on the Joint Strategic Plan is at an early stage with adoption in 2020 expected after the adoption of the Brentwood Local Plan. The Brentwood Local Plan will contribute towards some of the growth requirements of the Joint Strategic Plan. early in that Plan. However, Following the adoption of the Joint Strategic Plan it may be necessary to review the Brentwood Local Plan."

6 Submitted forms, commenting on the SA and on the Local Plan.
Form A:Chapters 1-3,
Form B Chapter 4,
Form C Chapter 5,
Form D Chapter 6,
Form E Chapter 7,
Form F Chapter 9
These representations deal with the following chapters in the Plan:
* Chapter 1. Introduction
* Chapter 2. Borough of Villages
* Chapter 3. Spatial Strategy - Vision and Strategic Objectives
In relation to Chapter 1, under Sustainability Appraisal, we also comment on the Sustainability Appraisal report (AECOM, January 2019).

Within our response to question no. 5 below, reference is made to specific pages, paragraphs and/or policies.

Chapter 1. Introduction

Duty to Cooperate (page 14)

Paragraphs 1.11 to 1.15 of the Local Plan briefly describe the Duty to Cooperate, its legal requirements in this regard and its commitment to cooperating with neighbouring authorities and key organisations on strategic planning issues. Paragraph 1.14 indicates the Council will publish a Duty to Cooperate Position Statement to describe the ongoing engagement and provide an update on the activities undertaken so far.
The Duty to Cooperate was introduced by the Localism Act 2011, and is set out in section 33A of the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan preparation in the context of strategic cross boundary matters. This is picked up in the National Planning Policy Framework (NPPF) which makes it clear that (paragraphs 25 - 27):
(a) strategic policy-making authorities should collaborate to identify the strategic matters of relevance;
(b) effective and ongoing joint working between strategic policy-making authorities and relevant authorities is integral to the production of a positively prepared and justified strategy; and
(c) in order to demonstrate this, statements of common ground should be produced (in accordance with the Planning Practice Guidance (PPG) and made publicly available so as to ensure transparency.

The Position Statement makes it clear that engagement with a wide range of stakeholders has taken place over several years which is noted and supported, as it demonstrates a significant effort has been made. CEG can confirm such an effort has been made by the Council with them over the Dunton Hills Strategic Allocation. However, at present CEG is not convinced that the Position Statement demonstrates that the Council has complied with the duty. The Council itself describes the document as a 'snapshot' and an 'initial summary' suggesting more is being done.
The PPG places much more emphasis on statements of common ground as how strategic policy making authorities can demonstrate that a plan is based on effective cooperation and that they have sought to produce a strategy based on agreements with other authorities. The Council has not yet provided the level of detail set out in the PPG and this will need to be worked up in due course.
The PPG also indicates that as the duty relates to the preparation of the plan it cannot be rectified post-submission so if the Inspector finds that the duty has not been complied with the examination would not proceed further. It might well be the case that there is further evidence, to which the Council can point in demonstrating compliance with a duty but it does not appear to be publicly available.
CEG understands that discussions with various authorities and prescribed bodies are well advanced and that an updated Position Statement will be prepared prior to submission to fully document the level of cooperation and the extent of agreement reached.
It is noted that the Position Statement refers to Dunton Hills Garden Village (DHGV) and consultation with Homes England but makes no reference to consultation with other relevant authorities or prescribed bodies which CEG knows has occurred. The updated Position Statement and relevant Statements of Common Ground should explain the full extent of the cooperation and agreement that has been reached in relation to this Strategic Allocation, as CEG is aware that it has been very extensive.
Sustainability Appraisal (Local Plan, page 15) & Interim Sustainability Appraisal (January 2019)
The Planning and Compulsory Purchase Act 2004 makes clear that local planning authorities must carry out a process of sustainability appraisal alongside plan making. This approach is reinforced in the NPPF which states that local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant statutory tests. Sustainability appraisals are required to demonstrate how the plan has addressed relevant economic, social and environmental objectives and avoid significant adverse impacts, wherever possible.
The Council has prepared Interim Sustainability Appraisals throughout the preparation of the Local Plan and this has informed the Spatial Strategy. The latest Interim Sustainability Appraisal explains the seven alternative development scenarios considered and the reasons for supporting some scenarios over others. There is an assessment of each scenario against economic, social and environmental topics based upon the relevant evidence base for each topic. This assessment explains why some scenarios rank higher than others. The Interim Sustainability Appraisal is sound and has been prepared in accordance with legislative requirements and the NPPF.
CEG supports the conclusion regarding DHGV but considers that the Council should supplement the assessment of the options - this could be more empirical and provide a fuller explanation of the conclusions reached, with more cross reference to the outcomes of other evidence base. Furthermore, in considering landscape issues the assessment does not deal with the landscape capacity of sites or areas to accommodate new development.
South Essex Joint Strategic Plan (page 17 - 18)

The Council helpfully explains the progress that has been made on the Joint Strategic Plan (JSP) and the collaboration that has occurred on this. However, CEG considers that the relationship between the Local Plan and the JSP should be made clearer. It should be clearly explained that adoption of the JSP will only occur after the adoption of the Brentwood Local Plan and because of the timing the Brentwood Local Plan will contribute towards some of the growth requirements of the JSP. To address this, some modifications are suggested in response to question no. 6 below.
Chapter 2. Borough of Villages

CEG supports the characterisation of Brentwood as a Borough of Villages and the Borough Profile (February 2019) evidence base which describes the unique nature of a market town and surrounding villages set amongst countryside as fundamental to the Borough's character. CEG considers that it is entirely appropriate that this characterisation forms a central part of the Vision set out in Chapter 3 of the Local Plan.

Fig. 2.2 (Brentwood Borough Hierarchy) in the Local Plan draws from the existing and proposed settlement hierarchy diagrams set out in the Borough Profile, and shows in plan form how well the Local Plan proposals reflect the Borough of Villages character. This includes the DHGV proposal, which presents a very positive response to meet the Borough's housing needs and will fit into the hierarchy of settlements in the future as set out in Fig. 2.3 (Settlement Hierarchy) in the Local Plan.

Chapter 3. Spatial Strategy - Vision and Strategic Objectives

The Spatial Strategy identifies two growth areas which align with transport corridors; the Central Brentwood Growth Corridor and the South Brentwood Growth Corridor, within which DHGV is proposed. Development outside of these corridors will be limited to retain the local character of the Borough (paragraph 3.21).

The NPPF recognises that the supply of a large number of homes can often best be achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns (paragraph 72). The approach of planning for DHGV is consistent with this and retaining the local character of the Borough.

CEG supports the Vison, the Driving Factors, the Overarching Aims, Strategic Objectives and the Strategic Allocation of DHGV as part of the South Brentwood Growth Corridor set out in Chapter 3. The Spatial Strategy and Development Principles will deliver the Vision. Given the importance attributed to Brentwood as a Borough of Villages and the need for Brentwood to meet its housing needs, the Spatial Strategy is sound; it is positively prepared, justified and consistent with national policy.

6 Submitted forms, commenting on the SA and on the Local Plan.
Form A:Chapters 1-3,
Form B Chapter 4,
Form C Chapter 5,
Form D Chapter 6,
Form E Chapter 7,
Form F Chapter 9
These representations deal with the following chapters in the Plan:
* Chapter 1. Introduction
* Chapter 2. Borough of Villages
* Chapter 3. Spatial Strategy - Vision and Strategic Objectives
In relation to Chapter 1, under Sustainability Appraisal, we also comment on the Sustainability Appraisal report (AECOM, January 2019).

Within our response to question no. 5 below, reference is made to specific pages, paragraphs and/or policies.

Chapter 1. Introduction

Duty to Cooperate (page 14)

Paragraphs 1.11 to 1.15 of the Local Plan briefly describe the Duty to Cooperate, its legal requirements in this regard and its commitment to cooperating with neighbouring authorities and key organisations on strategic planning issues. Paragraph 1.14 indicates the Council will publish a Duty to Cooperate Position Statement to describe the ongoing engagement and provide an update on the activities undertaken so far.
The Duty to Cooperate was introduced by the Localism Act 2011, and is set out in section 33A of the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan preparation in the context of strategic cross boundary matters. This is picked up in the National Planning Policy Framework (NPPF) which makes it clear that (paragraphs 25 - 27):
(a) strategic policy-making authorities should collaborate to identify the strategic matters of relevance;
(b) effective and ongoing joint working between strategic policy-making authorities and relevant authorities is integral to the production of a positively prepared and justified strategy; and
(c) in order to demonstrate this, statements of common ground should be produced (in accordance with the Planning Practice Guidance (PPG) and made publicly available so as to ensure transparency.

The Position Statement makes it clear that engagement with a wide range of stakeholders has taken place over several years which is noted and supported, as it demonstrates a significant effort has been made. CEG can confirm such an effort has been made by the Council with them over the Dunton Hills Strategic Allocation. However, at present CEG is not convinced that the Position Statement demonstrates that the Council has complied with the duty. The Council itself describes the document as a 'snapshot' and an 'initial summary' suggesting more is being done.
The PPG places much more emphasis on statements of common ground as how strategic policy making authorities can demonstrate that a plan is based on effective cooperation and that they have sought to produce a strategy based on agreements with other authorities. The Council has not yet provided the level of detail set out in the PPG and this will need to be worked up in due course.
The PPG also indicates that as the duty relates to the preparation of the plan it cannot be rectified post-submission so if the Inspector finds that the duty has not been complied with the examination would not proceed further. It might well be the case that there is further evidence, to which the Council can point in demonstrating compliance with a duty but it does not appear to be publicly available.
CEG understands that discussions with various authorities and prescribed bodies are well advanced and that an updated Position Statement will be prepared prior to submission to fully document the level of cooperation and the extent of agreement reached.
It is noted that the Position Statement refers to Dunton Hills Garden Village (DHGV) and consultation with Homes England but makes no reference to consultation with other relevant authorities or prescribed bodies which CEG knows has occurred. The updated Position Statement and relevant Statements of Common Ground should explain the full extent of the cooperation and agreement that has been reached in relation to this Strategic Allocation, as CEG is aware that it has been very extensive.
Sustainability Appraisal (Local Plan, page 15) & Interim Sustainability Appraisal (January 2019)
The Planning and Compulsory Purchase Act 2004 makes clear that local planning authorities must carry out a process of sustainability appraisal alongside plan making. This approach is reinforced in the NPPF which states that local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant statutory tests. Sustainability appraisals are required to demonstrate how the plan has addressed relevant economic, social and environmental objectives and avoid significant adverse impacts, wherever possible.
The Council has prepared Interim Sustainability Appraisals throughout the preparation of the Local Plan and this has informed the Spatial Strategy. The latest Interim Sustainability Appraisal explains the seven alternative development scenarios considered and the reasons for supporting some scenarios over others. There is an assessment of each scenario against economic, social and environmental topics based upon the relevant evidence base for each topic. This assessment explains why some scenarios rank higher than others. The Interim Sustainability Appraisal is sound and has been prepared in accordance with legislative requirements and the NPPF.
CEG supports the conclusion regarding DHGV but considers that the Council should supplement the assessment of the options - this could be more empirical and provide a fuller explanation of the conclusions reached, with more cross reference to the outcomes of other evidence base. Furthermore, in considering landscape issues the assessment does not deal with the landscape capacity of sites or areas to accommodate new development.
South Essex Joint Strategic Plan (page 17 - 18)

The Council helpfully explains the progress that has been made on the Joint Strategic Plan (JSP) and the collaboration that has occurred on this. However, CEG considers that the relationship between the Local Plan and the JSP should be made clearer. It should be clearly explained that adoption of the JSP will only occur after the adoption of the Brentwood Local Plan and because of the timing the Brentwood Local Plan will contribute towards some of the growth requirements of the JSP. To address this, some modifications are suggested in response to question no. 6 below.
Chapter 2. Borough of Villages

CEG supports the characterisation of Brentwood as a Borough of Villages and the Borough Profile (February 2019) evidence base which describes the unique nature of a market town and surrounding villages set amongst countryside as fundamental to the Borough's character. CEG considers that it is entirely appropriate that this characterisation forms a central part of the Vision set out in Chapter 3 of the Local Plan.

Fig. 2.2 (Brentwood Borough Hierarchy) in the Local Plan draws from the existing and proposed settlement hierarchy diagrams set out in the Borough Profile, and shows in plan form how well the Local Plan proposals reflect the Borough of Villages character. This includes the DHGV proposal, which presents a very positive response to meet the Borough's housing needs and will fit into the hierarchy of settlements in the future as set out in Fig. 2.3 (Settlement Hierarchy) in the Local Plan.

Chapter 3. Spatial Strategy - Vision and Strategic Objectives

The Spatial Strategy identifies two growth areas which align with transport corridors; the Central Brentwood Growth Corridor and the South Brentwood Growth Corridor, within which DHGV is proposed. Development outside of these corridors will be limited to retain the local character of the Borough (paragraph 3.21).

The NPPF recognises that the supply of a large number of homes can often best be achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns (paragraph 72). The approach of planning for DHGV is consistent with this and retaining the local character of the Borough.

CEG supports the Vison, the Driving Factors, the Overarching Aims, Strategic Objectives and the Strategic Allocation of DHGV as part of the South Brentwood Growth Corridor set out in Chapter 3. The Spatial Strategy and Development Principles will deliver the Vision. Given the importance attributed to Brentwood as a Borough of Villages and the need for Brentwood to meet its housing needs, the Spatial Strategy is sound; it is positively prepared, justified and consistent with national policy.

6 Submitted forms, commenting on the SA and on the Local Plan.
Form A:Chapters 1-3,
Form B Chapter 4,
Form C Chapter 5,
Form D Chapter 6,
Form E Chapter 7,
Form F Chapter 9
These representations deal with the following chapters in the Plan:
* Chapter 1. Introduction
* Chapter 2. Borough of Villages
* Chapter 3. Spatial Strategy - Vision and Strategic Objectives
In relation to Chapter 1, under Sustainability Appraisal, we also comment on the Sustainability Appraisal report (AECOM, January 2019).

Within our response to question no. 5 below, reference is made to specific pages, paragraphs and/or policies.

Chapter 1. Introduction

Duty to Cooperate (page 14)

Paragraphs 1.11 to 1.15 of the Local Plan briefly describe the Duty to Cooperate, its legal requirements in this regard and its commitment to cooperating with neighbouring authorities and key organisations on strategic planning issues. Paragraph 1.14 indicates the Council will publish a Duty to Cooperate Position Statement to describe the ongoing engagement and provide an update on the activities undertaken so far.
The Duty to Cooperate was introduced by the Localism Act 2011, and is set out in section 33A of the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan preparation in the context of strategic cross boundary matters. This is picked up in the National Planning Policy Framework (NPPF) which makes it clear that (paragraphs 25 - 27):
(a) strategic policy-making authorities should collaborate to identify the strategic matters of relevance;
(b) effective and ongoing joint working between strategic policy-making authorities and relevant authorities is integral to the production of a positively prepared and justified strategy; and
(c) in order to demonstrate this, statements of common ground should be produced (in accordance with the Planning Practice Guidance (PPG) and made publicly available so as to ensure transparency.

The Position Statement makes it clear that engagement with a wide range of stakeholders has taken place over several years which is noted and supported, as it demonstrates a significant effort has been made. CEG can confirm such an effort has been made by the Council with them over the Dunton Hills Strategic Allocation. However, at present CEG is not convinced that the Position Statement demonstrates that the Council has complied with the duty. The Council itself describes the document as a 'snapshot' and an 'initial summary' suggesting more is being done.
The PPG places much more emphasis on statements of common ground as how strategic policy making authorities can demonstrate that a plan is based on effective cooperation and that they have sought to produce a strategy based on agreements with other authorities. The Council has not yet provided the level of detail set out in the PPG and this will need to be worked up in due course.
The PPG also indicates that as the duty relates to the preparation of the plan it cannot be rectified post-submission so if the Inspector finds that the duty has not been complied with the examination would not proceed further. It might well be the case that there is further evidence, to which the Council can point in demonstrating compliance with a duty but it does not appear to be publicly available.
CEG understands that discussions with various authorities and prescribed bodies are well advanced and that an updated Position Statement will be prepared prior to submission to fully document the level of cooperation and the extent of agreement reached.
It is noted that the Position Statement refers to Dunton Hills Garden Village (DHGV) and consultation with Homes England but makes no reference to consultation with other relevant authorities or prescribed bodies which CEG knows has occurred. The updated Position Statement and relevant Statements of Common Ground should explain the full extent of the cooperation and agreement that has been reached in relation to this Strategic Allocation, as CEG is aware that it has been very extensive.
Sustainability Appraisal (Local Plan, page 15) & Interim Sustainability Appraisal (January 2019)
The Planning and Compulsory Purchase Act 2004 makes clear that local planning authorities must carry out a process of sustainability appraisal alongside plan making. This approach is reinforced in the NPPF which states that local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant statutory tests. Sustainability appraisals are required to demonstrate how the plan has addressed relevant economic, social and environmental objectives and avoid significant adverse impacts, wherever possible.
The Council has prepared Interim Sustainability Appraisals throughout the preparation of the Local Plan and this has informed the Spatial Strategy. The latest Interim Sustainability Appraisal explains the seven alternative development scenarios considered and the reasons for supporting some scenarios over others. There is an assessment of each scenario against economic, social and environmental topics based upon the relevant evidence base for each topic. This assessment explains why some scenarios rank higher than others. The Interim Sustainability Appraisal is sound and has been prepared in accordance with legislative requirements and the NPPF.
CEG supports the conclusion regarding DHGV but considers that the Council should supplement the assessment of the options - this could be more empirical and provide a fuller explanation of the conclusions reached, with more cross reference to the outcomes of other evidence base. Furthermore, in considering landscape issues the assessment does not deal with the landscape capacity of sites or areas to accommodate new development.
South Essex Joint Strategic Plan (page 17 - 18)

The Council helpfully explains the progress that has been made on the Joint Strategic Plan (JSP) and the collaboration that has occurred on this. However, CEG considers that the relationship between the Local Plan and the JSP should be made clearer. It should be clearly explained that adoption of the JSP will only occur after the adoption of the Brentwood Local Plan and because of the timing the Brentwood Local Plan will contribute towards some of the growth requirements of the JSP. To address this, some modifications are suggested in response to question no. 6 below.
Chapter 2. Borough of Villages

CEG supports the characterisation of Brentwood as a Borough of Villages and the Borough Profile (February 2019) evidence base which describes the unique nature of a market town and surrounding villages set amongst countryside as fundamental to the Borough's character. CEG considers that it is entirely appropriate that this characterisation forms a central part of the Vision set out in Chapter 3 of the Local Plan.

Fig. 2.2 (Brentwood Borough Hierarchy) in the Local Plan draws from the existing and proposed settlement hierarchy diagrams set out in the Borough Profile, and shows in plan form how well the Local Plan proposals reflect the Borough of Villages character. This includes the DHGV proposal, which presents a very positive response to meet the Borough's housing needs and will fit into the hierarchy of settlements in the future as set out in Fig. 2.3 (Settlement Hierarchy) in the Local Plan.

Chapter 3. Spatial Strategy - Vision and Strategic Objectives

The Spatial Strategy identifies two growth areas which align with transport corridors; the Central Brentwood Growth Corridor and the South Brentwood Growth Corridor, within which DHGV is proposed. Development outside of these corridors will be limited to retain the local character of the Borough (paragraph 3.21).

The NPPF recognises that the supply of a large number of homes can often best be achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns (paragraph 72). The approach of planning for DHGV is consistent with this and retaining the local character of the Borough.

CEG supports the Vison, the Driving Factors, the Overarching Aims, Strategic Objectives and the Strategic Allocation of DHGV as part of the South Brentwood Growth Corridor set out in Chapter 3. The Spatial Strategy and Development Principles will deliver the Vision. Given the importance attributed to Brentwood as a Borough of Villages and the need for Brentwood to meet its housing needs, the Spatial Strategy is sound; it is positively prepared, justified and consistent with national policy.

Policy SP01 Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas as follows:
"i. preserves, and where appropriate, enhances heritage assets and conservation areas;"

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed to reflect that housing provision reflects a 'minimum'. This also ensures consistency with national policy and guidance, and Local Plan Policy R01.
To ensure that the plan is positively prepared and consistent with the NPPF criterion A should be updated to reflect that "provision should be made for a minimum of 7,752 new residential dwellings...".

CEG supports the inclusion of Figure 4.2 to explain how housing provision will occur. The column entitled 'Net homes' should either be retitled 'Minimum net homes' and/or a footnote should be included relating to DHGV to the effect that 2,700 is the minimum to be provided, consistent with the wording of Local Plan Policy R01.

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed to reflect that housing provision reflects a 'minimum'. This also ensures consistency with national policy and guidance, and Local Plan Policy R01.
To ensure that the plan is positively prepared and consistent with the NPPF criterion A should be updated to reflect that "provision should be made for a minimum of 7,752 new residential dwellings...".

CEG supports the inclusion of Figure 4.2 to explain how housing provision will occur. The column entitled 'Net homes' should either be retitled 'Minimum net homes' and/or a footnote should be included relating to DHGV to the effect that 2,700 is the minimum to be provided, consistent with the wording of Local Plan Policy R01.

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Policy SP05, Construction Management (page 58)
Criterion B might usefully clarify that this refers to "... other major 'committed' development..."

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.