LLLP consider that policy SP01 requires modification at D(a) and D(d) to ensure that it is positively framed and that the approach to securing sustainable development accords with the NPPF and is more flexible.

Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Section 4, Policy SP01: Sustainable
Development.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Policy SP01 sets the overall approach and criteria for achieving sustainable
development in the Borough. LLLP supports the overall approach and intention of
the policy but has specific concerns with respect to criterion point D.
Criterion D
5. Point D of Policy SP01 states that development will be supported where it
contributes towards delivering the Strategic Objectives and meets 11 specific
criteria. LLLP have concerns about D(a) and D(d) as follows.
Criterion D(a)
6. Criterion D(a) states that development will be supported where it preserves and
enhances the character and settlement setting of the Borough's villages.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
7. As drafted the criterion appears to be overly prescriptive. "Preservation" of the
character and settlement setting is inflexible and by definition anticipates that there
is no change to the existing situation. The spatial strategy and growth proposals set
out in the Plan will, inevitably, lead to change to the character and setting of
settlements (including towns, villages and the countryside).
8. The NPPF does not require the preservation of character and setting and is couched
in more positive terms, particularly at paragraph 170 which seeks to inter alia: (a)
protect and enhance valued landscapes; and (b) recognise the intrinsic character
and beauty of the countryside.
Criterion D(d)
9. Criterion D(d) seeks to ensure that the transport network can satisfactorily
accommodate the travel demand generated and that traffic generation would not
give rise to adverse highway conditions or highway safety concerns or an
unacceptable loss of amenity.
10. LLLP consider that the phrasing of criterion D(d) is not consistent with the NPPF at
paragraph 102(d). This paragraph of the NPPF confirms that the environmental
impacts of traffic and transport infrastructure should be identified and assessed and
that appropriate opportunities for avoiding or mitigating any adverse effects are
identified.
11. Criterion D(d) of Policy SP01 makes no reference to the ability of development
schemes and proposals to mitigate any adverse effects that may be identified. The
policy wording needs to reflect the potential for adverse highways conditions to be
mitigated through appropriate interventions such as contributions to infrastructure
improvements
Conclusions
12. LLLP object to Policy SP01. The policy is not sound as it is not:
* Consistent with the NPPF - for the reasons identified in this representation,
Policy SP01 is not consistent with the NPPF and is considered to be too
prescriptive with respect to Criterion D(a) and Criterion D(d). The policy is
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
not positively framed for these criteria and would be overly restrictive for the
effective consideration of future development proposals.
Modifications Required
13. LLLP consider that policy SP01 requires modification at D(a) and D(d) to ensure that
it is positively framed and that the approach to securing sustainable development
accords with the NPPF and is more flexible.

Policy SP06 should be modified by deletion of Point A entirely. Point B should be revised to include flexibility for the provision of supporting documentation on a site by- site basis in accordance with the relevant planning application validation list

Policy SP06: Effective Delivery of Development
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy SP06: Effective Delivery of
Development; particularly Point A and Point B.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Points A and B of Policy SP06: Effective Delivery of Development are concerned
with securing the timely and efficient delivery of strategic sites and areas of
change.
5. The policy indicates a raft of additional tasks and steps for larger sites including
strategic and site-area masterplans, collaborative and partnership working to
derive scheme proposals.
6. While LLLP support the need for collaborative working with stakeholders, it is
concerned that the requirements set out in SP06 are overly onerous and
unjustified. It is not clear why the additional steps and documents are necessary
and how they would lead to more efficient or timely development delivery.
7. The planning application and decision-taking process as laid out in the NPPF
includes opportunities for extensive stakeholder and consultee engagement as
well as pre-application review and evolution of development proposals of all
scales. This allows for a coherent and effective approach to site development to
be undertaken already and therefore already provides the mechanisms to achieve
this in the way that paragraph 4.45 of the Local Plan envisages.
Conclusions
8. LLLP conclude that Point A and Point B of Policy SP06 are not:
* Justified - for the reasons identified in this representation, the approach is
not justified. The planning system already includes adequate opportunities
and mechanisms for early engagement, partnership and stakeholder work
and collaborative planning. There is no need for the additional measures
proposed in Policy SP06 at Points A or B and it is unclear as to which
size/scale of allocated sites the policy may be applied;
* Effective - the measures set out in SP06 will not necessarily lead to more
effective planning or decision-taking. Some of the steps may serve to slow
or restrict the ability to bring development sites forwards in a timely fashion.
There is a need to balance the collaborative and participatory approach
envisaged in SP06 with the timely determination of development proposals
for larger sites.
Modifications Required
9. Policy SP06 should be modified by deletion of Point A entirely. Point B should be
revised to include flexibility for the provision of supporting documentation on a site by- site basis in accordance with the relevant planning application validation list.

LLLP consider that the Strategic Objectives should be modified at an appropriate point in SO1 to clearly state that the Local Plan will meet the Borough's identified housing requirement.

Strategic Objectives
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Section 3, the Strategic Objectives on page
38.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Strategic Objectives - Overall
4. LLLP are concerned that the none of the four Strategic Objectives identify the need
to meet in full the Borough's housing requirement. The need to meet housing
requirements is noted as one of the spatial strategy driving factors (at paragraph
3.1c) but this has not been translated clearly into the Plan's Strategic Objectives.
5. Coupled with LLLP's concern that the Plan's Vision statement (see LLLP's separate
representation) fails to reflect the three dimensions of sustainable development as
laid out in the National Planning Policy Framework at paragraph 8, it is considered
that the failure to clearly state that the Plan will meet housing needs as one of the
key Strategic Objectives means that the Plan is not effective and is not consistent
with the NPPF.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Strategic Objective One: Managing Growth Sustainably
6. Strategic Objective One (SO1) is concerned with directing development to the most
sustainable locations in the Borough, ensuring that the characteristics and patterns
of settlements are protected and enhanced to provide a strong sense of place.
7. LLLP supports the intention of SO1 to manage and direct growth to sustainable
locations but is deeply concerned that the proposed spatial strategy and site
allocations resulting fails to achieve this Strategic Objective.
8. LLLP's separate representations (with regard to inter alia: the sequential use of land,
demonstrating housing provision, managing growth and the Dunton Hills Garden
Village proposals) set out greater details of the concerns and deficiencies in the
BBLP's proposed spatial strategy. Those concerns are not re-iterated herein but
provide the context for LLLP's objection to SO1 as drafted.
Conclusions
9. LLLP object to the Strategic Objectives generally (and SO1 in particular) as there is
no firm, clear commitment in any of the stated objectives to meet, in full, the
Borough's housing requirement.
10. The Strategic Objectives are not sound as they are not:
* Positively prepared - clearly establishing that the Plan will have the objective
of meet the area's objectively assessed housing needs;
* Consistent with national planning policies - The Strategic Objectives are not
consistent with national planning policies, including at paragraphs 8, 11(b),
and 16(d).
Modifications Required
11. LLLP consider that the Strategic Objectives should be modified at an appropriate
point in SO1 to clearly state that the Local Plan will meet the Borough's identified
housing requirement.