Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :
* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network
* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood
* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.
* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them
* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated
* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 01
Comments made in regard to Strategic Allocation Policy R01 - Dunton Hills Garden Village (with particular reference to Policy R01 (II) Spatial Design)

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for Dunton Hills Garden Village. At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome. It is helpful that there is more clarity on implementation.

Some of the matters raised by the Council in its 2018 response (such as the importance of timely infrastructure provision and the detail of infrastructure to be provided) have been addressed.

A key element of the Council's 2018 response focused on the relationship between the DHGV proposal and its likely impact on the adjoining highway network given the scale of the development proposed (almost 260 hectares of residential lead development and some 2,700 new homes over the plan period).

The comments noted that the DHGV proposal adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the DHGV proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the DHGV proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The Policy R01 Dunton Hills Garden Village Strategic Allocation in the current consultation Local Plan includes a section on Transport Impact Mitigations (Section H).

This refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications of this proposal on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures (such as junction improvements, bus routes and public transport improvements) rather than ensuring that the considerable traffic it may generate itself is capable of being accommodated on the wider highway network as well as all the other growth planned for east London and south Essex.

It is welcome that these issues are noted in in the explanatory text to Policy BE11 Strategic Transport Infrastructure (paragraphs 5.97 - 5.102) but they should be referenced in the DHGV proposal because of its scale.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.

Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 02
Comments made in regard to : Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for the Brentwood Enterprise Park

At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome.

The policy / proposal is now for almost 26 hectares of land to be used for employment uses.

Nevertheless, the Local Plan does not evidence why the Brentwood Enterprise Park is would be an acceptable use at an important location in the Green Belt other than to refer the difficulties of accommodating the quantum of development within other parts of the Brentwood borough and the opportunity to capitalize on the connections in the Brentwood Growth Corridor (para. 7.23b).

Havering's 2018 comments noted that a key element in the preparation of the Havering Local Plan has been to ensure that the growth proposed in Havering over the period of the Local Plan is supported by timely and effective provision of infrastructure including transport infrastructure.

The comments noted that the Brentwood Enterprise Park adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the Brentwood Enterprise Park proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The reasoned justification to Policy E11 notes that the proposal has a number of potential access points via the M25 Junction and Warley Street and that it will be expected to mitigate its impacts on the performance of the local and strategic road network. This does not adequately address the strategic implications of this proposal on the wider highway network.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

The recognition of the importance of the proposal including sustainable transport measures for employees is supported and will help reduce traffic on the A127.
Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended :

* to demonstrate why the proposal is compliant with the National Planning Policy Framework

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure

If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to set out the views of Havering Council on the Brentwood Local Plan and to ensure that the Council has an opportunity to contribute to the discussions with the Inspector.

Section H refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures rather than ensuring that the considerable traffic it may generate could be accommodated on the wider highway network as well as all the other growth planned for east London and south Essex. It is welcome that these issues are noted in the explanatory text to Policy BE11 (paragraph 5.97-5.102) but they should be referenced in the DHGV proposal.

Changes to Plan:
Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :
* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network
* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood
* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.
* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them
* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated
* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 01
Comments made in regard to Strategic Allocation Policy R01 - Dunton Hills Garden Village (with particular reference to Policy R01 (II) Spatial Design)

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for Dunton Hills Garden Village. At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome. It is helpful that there is more clarity on implementation.

Some of the matters raised by the Council in its 2018 response (such as the importance of timely infrastructure provision and the detail of infrastructure to be provided) have been addressed.

A key element of the Council's 2018 response focused on the relationship between the DHGV proposal and its likely impact on the adjoining highway network given the scale of the development proposed (almost 260 hectares of residential lead development and some 2,700 new homes over the plan period).

The comments noted that the DHGV proposal adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the DHGV proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the DHGV proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The Policy R01 Dunton Hills Garden Village Strategic Allocation in the current consultation Local Plan includes a section on Transport Impact Mitigations (Section H).

This refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications of this proposal on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures (such as junction improvements, bus routes and public transport improvements) rather than ensuring that the considerable traffic it may generate itself is capable of being accommodated on the wider highway network as well as all the other growth planned for east London and south Essex.

It is welcome that these issues are noted in in the explanatory text to Policy BE11 Strategic Transport Infrastructure (paragraphs 5.97 - 5.102) but they should be referenced in the DHGV proposal because of its scale.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.

Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 02
Comments made in regard to : Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for the Brentwood Enterprise Park

At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome.

The policy / proposal is now for almost 26 hectares of land to be used for employment uses.

Nevertheless, the Local Plan does not evidence why the Brentwood Enterprise Park is would be an acceptable use at an important location in the Green Belt other than to refer the difficulties of accommodating the quantum of development within other parts of the Brentwood borough and the opportunity to capitalize on the connections in the Brentwood Growth Corridor (para. 7.23b).

Havering's 2018 comments noted that a key element in the preparation of the Havering Local Plan has been to ensure that the growth proposed in Havering over the period of the Local Plan is supported by timely and effective provision of infrastructure including transport infrastructure.

The comments noted that the Brentwood Enterprise Park adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the Brentwood Enterprise Park proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The reasoned justification to Policy E11 notes that the proposal has a number of potential access points via the M25 Junction and Warley Street and that it will be expected to mitigate its impacts on the performance of the local and strategic road network. This does not adequately address the strategic implications of this proposal on the wider highway network.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

The recognition of the importance of the proposal including sustainable transport measures for employees is supported and will help reduce traffic on the A127.
Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended :

* to demonstrate why the proposal is compliant with the National Planning Policy Framework

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure

If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to set out the views of Havering Council on the Brentwood Local Plan and to ensure that the Council has an opportunity to contribute to the discussions with the Inspector.

Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended:
* to demonstrate why the proposal is compliant with the National Planning Policy Framework
* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering
* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood
* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.
* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them
* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated
* to include cross reference to Policy BE11 Strategic Transport Infrastructure

FORM 01
Comments made in regard to Strategic Allocation Policy R01 - Dunton Hills Garden Village (with particular reference to Policy R01 (II) Spatial Design)

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for Dunton Hills Garden Village. At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome. It is helpful that there is more clarity on implementation.

Some of the matters raised by the Council in its 2018 response (such as the importance of timely infrastructure provision and the detail of infrastructure to be provided) have been addressed.

A key element of the Council's 2018 response focused on the relationship between the DHGV proposal and its likely impact on the adjoining highway network given the scale of the development proposed (almost 260 hectares of residential lead development and some 2,700 new homes over the plan period).

The comments noted that the DHGV proposal adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the DHGV proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the DHGV proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The Policy R01 Dunton Hills Garden Village Strategic Allocation in the current consultation Local Plan includes a section on Transport Impact Mitigations (Section H).

This refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications of this proposal on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures (such as junction improvements, bus routes and public transport improvements) rather than ensuring that the considerable traffic it may generate itself is capable of being accommodated on the wider highway network as well as all the other growth planned for east London and south Essex.

It is welcome that these issues are noted in in the explanatory text to Policy BE11 Strategic Transport Infrastructure (paragraphs 5.97 - 5.102) but they should be referenced in the DHGV proposal because of its scale.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.

Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 02
Comments made in regard to : Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for the Brentwood Enterprise Park

At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome.

The policy / proposal is now for almost 26 hectares of land to be used for employment uses.

Nevertheless, the Local Plan does not evidence why the Brentwood Enterprise Park is would be an acceptable use at an important location in the Green Belt other than to refer the difficulties of accommodating the quantum of development within other parts of the Brentwood borough and the opportunity to capitalize on the connections in the Brentwood Growth Corridor (para. 7.23b).

Havering's 2018 comments noted that a key element in the preparation of the Havering Local Plan has been to ensure that the growth proposed in Havering over the period of the Local Plan is supported by timely and effective provision of infrastructure including transport infrastructure.

The comments noted that the Brentwood Enterprise Park adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the Brentwood Enterprise Park proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The reasoned justification to Policy E11 notes that the proposal has a number of potential access points via the M25 Junction and Warley Street and that it will be expected to mitigate its impacts on the performance of the local and strategic road network. This does not adequately address the strategic implications of this proposal on the wider highway network.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

The recognition of the importance of the proposal including sustainable transport measures for employees is supported and will help reduce traffic on the A127.
Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended :

* to demonstrate why the proposal is compliant with the National Planning Policy Framework

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure

If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to set out the views of Havering Council on the Brentwood Local Plan and to ensure that the Council has an opportunity to contribute to the discussions with the Inspector.

Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended:
* to demonstrate why the proposal is compliant with the National Planning Policy Framework
* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering
* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood
* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.
* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them
* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated
* to include cross reference to Policy BE11 Strategic Transport Infrastructure

FORM 01
Comments made in regard to Strategic Allocation Policy R01 - Dunton Hills Garden Village (with particular reference to Policy R01 (II) Spatial Design)

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for Dunton Hills Garden Village. At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome. It is helpful that there is more clarity on implementation.

Some of the matters raised by the Council in its 2018 response (such as the importance of timely infrastructure provision and the detail of infrastructure to be provided) have been addressed.

A key element of the Council's 2018 response focused on the relationship between the DHGV proposal and its likely impact on the adjoining highway network given the scale of the development proposed (almost 260 hectares of residential lead development and some 2,700 new homes over the plan period).

The comments noted that the DHGV proposal adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the DHGV proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the DHGV proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The Policy R01 Dunton Hills Garden Village Strategic Allocation in the current consultation Local Plan includes a section on Transport Impact Mitigations (Section H).

This refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications of this proposal on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures (such as junction improvements, bus routes and public transport improvements) rather than ensuring that the considerable traffic it may generate itself is capable of being accommodated on the wider highway network as well as all the other growth planned for east London and south Essex.

It is welcome that these issues are noted in in the explanatory text to Policy BE11 Strategic Transport Infrastructure (paragraphs 5.97 - 5.102) but they should be referenced in the DHGV proposal because of its scale.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.

Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 02
Comments made in regard to : Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for the Brentwood Enterprise Park

At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome.

The policy / proposal is now for almost 26 hectares of land to be used for employment uses.

Nevertheless, the Local Plan does not evidence why the Brentwood Enterprise Park is would be an acceptable use at an important location in the Green Belt other than to refer the difficulties of accommodating the quantum of development within other parts of the Brentwood borough and the opportunity to capitalize on the connections in the Brentwood Growth Corridor (para. 7.23b).

Havering's 2018 comments noted that a key element in the preparation of the Havering Local Plan has been to ensure that the growth proposed in Havering over the period of the Local Plan is supported by timely and effective provision of infrastructure including transport infrastructure.

The comments noted that the Brentwood Enterprise Park adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the Brentwood Enterprise Park proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The reasoned justification to Policy E11 notes that the proposal has a number of potential access points via the M25 Junction and Warley Street and that it will be expected to mitigate its impacts on the performance of the local and strategic road network. This does not adequately address the strategic implications of this proposal on the wider highway network.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

The recognition of the importance of the proposal including sustainable transport measures for employees is supported and will help reduce traffic on the A127.
Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended :

* to demonstrate why the proposal is compliant with the National Planning Policy Framework

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure

If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to set out the views of Havering Council on the Brentwood Local Plan and to ensure that the Council has an opportunity to contribute to the discussions with the Inspector.

Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended:
* to demonstrate why the proposal is compliant with the National Planning Policy Framework
* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering
* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood
* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.
* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them
* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated
* to include cross reference to Policy BE11 Strategic Transport Infrastructure

FORM 01
Comments made in regard to Strategic Allocation Policy R01 - Dunton Hills Garden Village (with particular reference to Policy R01 (II) Spatial Design)

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for Dunton Hills Garden Village. At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome. It is helpful that there is more clarity on implementation.

Some of the matters raised by the Council in its 2018 response (such as the importance of timely infrastructure provision and the detail of infrastructure to be provided) have been addressed.

A key element of the Council's 2018 response focused on the relationship between the DHGV proposal and its likely impact on the adjoining highway network given the scale of the development proposed (almost 260 hectares of residential lead development and some 2,700 new homes over the plan period).

The comments noted that the DHGV proposal adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the DHGV proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the DHGV proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The Policy R01 Dunton Hills Garden Village Strategic Allocation in the current consultation Local Plan includes a section on Transport Impact Mitigations (Section H).

This refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications of this proposal on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures (such as junction improvements, bus routes and public transport improvements) rather than ensuring that the considerable traffic it may generate itself is capable of being accommodated on the wider highway network as well as all the other growth planned for east London and south Essex.

It is welcome that these issues are noted in in the explanatory text to Policy BE11 Strategic Transport Infrastructure (paragraphs 5.97 - 5.102) but they should be referenced in the DHGV proposal because of its scale.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.

Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 02
Comments made in regard to : Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for the Brentwood Enterprise Park

At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome.

The policy / proposal is now for almost 26 hectares of land to be used for employment uses.

Nevertheless, the Local Plan does not evidence why the Brentwood Enterprise Park is would be an acceptable use at an important location in the Green Belt other than to refer the difficulties of accommodating the quantum of development within other parts of the Brentwood borough and the opportunity to capitalize on the connections in the Brentwood Growth Corridor (para. 7.23b).

Havering's 2018 comments noted that a key element in the preparation of the Havering Local Plan has been to ensure that the growth proposed in Havering over the period of the Local Plan is supported by timely and effective provision of infrastructure including transport infrastructure.

The comments noted that the Brentwood Enterprise Park adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the Brentwood Enterprise Park proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The reasoned justification to Policy E11 notes that the proposal has a number of potential access points via the M25 Junction and Warley Street and that it will be expected to mitigate its impacts on the performance of the local and strategic road network. This does not adequately address the strategic implications of this proposal on the wider highway network.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

The recognition of the importance of the proposal including sustainable transport measures for employees is supported and will help reduce traffic on the A127.
Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended :

* to demonstrate why the proposal is compliant with the National Planning Policy Framework

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure

If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to set out the views of Havering Council on the Brentwood Local Plan and to ensure that the Council has an opportunity to contribute to the discussions with the Inspector.

Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended:
* to demonstrate why the proposal is compliant with the National Planning Policy Framework
* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering
* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood
* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.
* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them
* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated
* to include cross reference to Policy BE11 Strategic Transport Infrastructure

FORM 01
Comments made in regard to Strategic Allocation Policy R01 - Dunton Hills Garden Village (with particular reference to Policy R01 (II) Spatial Design)

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for Dunton Hills Garden Village. At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome. It is helpful that there is more clarity on implementation.

Some of the matters raised by the Council in its 2018 response (such as the importance of timely infrastructure provision and the detail of infrastructure to be provided) have been addressed.

A key element of the Council's 2018 response focused on the relationship between the DHGV proposal and its likely impact on the adjoining highway network given the scale of the development proposed (almost 260 hectares of residential lead development and some 2,700 new homes over the plan period).

The comments noted that the DHGV proposal adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the DHGV proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the DHGV proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The Policy R01 Dunton Hills Garden Village Strategic Allocation in the current consultation Local Plan includes a section on Transport Impact Mitigations (Section H).

This refers to mitigations necessary to support the DHGV proposal but these do not adequately address the strategic implications of this proposal on the wider highway network. The focus of the measures is about 'fitting' the proposal into the network with local measures (such as junction improvements, bus routes and public transport improvements) rather than ensuring that the considerable traffic it may generate itself is capable of being accommodated on the wider highway network as well as all the other growth planned for east London and south Essex.

It is welcome that these issues are noted in in the explanatory text to Policy BE11 Strategic Transport Infrastructure (paragraphs 5.97 - 5.102) but they should be referenced in the DHGV proposal because of its scale.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

Please set out what modification(s) you consider necessary to make the Local Plan sound or legally compliant, having regard to the matters that you identified above.

Policy R01 : Dunton Hills Garden Village Strategic Allocation should be amended :

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the DHGV proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along the corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure (where the Local Plan addresses some issues relating to the wider highways network albeit without referring to DHGV)

FORM 02
Comments made in regard to : Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park

London Borough of Havering commented in 2018 at the Regulation 18 consultation stage of the Brentwood Local Plan and commented on the emerging proposals for the Brentwood Enterprise Park

At that stage there was relatively little detail on the emerging proposal other than a location and an overview of the likely issues to be addressed.

In the current consultation document, more detail on the proposal has been provided and this is welcome.

The policy / proposal is now for almost 26 hectares of land to be used for employment uses.

Nevertheless, the Local Plan does not evidence why the Brentwood Enterprise Park is would be an acceptable use at an important location in the Green Belt other than to refer the difficulties of accommodating the quantum of development within other parts of the Brentwood borough and the opportunity to capitalize on the connections in the Brentwood Growth Corridor (para. 7.23b).

Havering's 2018 comments noted that a key element in the preparation of the Havering Local Plan has been to ensure that the growth proposed in Havering over the period of the Local Plan is supported by timely and effective provision of infrastructure including transport infrastructure.

The comments noted that the Brentwood Enterprise Park adjoined the A127 trunk road. This is a key route into Havering and intersects with the A12 trunk road at the Gallows Corner intersection.

Havering's comments noted that the A127 is already well trafficked and that Gallows Corner is already highly congested, an accident 'hot-spot' and gives rise to environmental problems such as poor air quality.

Havering's comments noted that other stakeholders had previously objected in principle to the extent of development along the A127 corridor and said that the Brentwood Enterprise Park proposal should be considered in that regard.

Havering's comments also highlighted the importance of Transport for London being afforded the opportunity to comment on the implications of the proposal because the A127 is a Transport for London route once it is within the London boundary.

Havering's comments said that the Local Plan proposal should highlight the joint working taking place between authorities along the A127 corridor because this is an important means to the various authorities ensuring the scale and timing of development along the corridor is taken into account.

Havering continues to liaise with other stakeholders (such as Highways England and Transport for London) on the importance of investment in transport infrastructure and to that end strongly supports the work of the A127 Task Force group of authorities and interested parties in lobbying for improvements to the A127 Corridor in the recognition of the growth planned along it.

The reasoned justification to Policy E11 notes that the proposal has a number of potential access points via the M25 Junction and Warley Street and that it will be expected to mitigate its impacts on the performance of the local and strategic road network. This does not adequately address the strategic implications of this proposal on the wider highway network.

There is no recognition in the proposal about the likely adverse environmental impacts of significant additional traffic along the A127 (including within Havering) resulting from the proposal such as noise, vibration and reductions in air quality.

The recognition of the importance of the proposal including sustainable transport measures for employees is supported and will help reduce traffic on the A127.
Policy PC03 Employment Land Allocations, Policy E11 Brentwood Enterprise Park and Site Allocation E11 Brentwood Enterprise Park should be amended :

* to demonstrate why the proposal is compliant with the National Planning Policy Framework

* to provide explicit commentary on the likely significant implications of the proposal for the wider strategic highway network given the proximity to Havering

* to recognize the importance of working with other stakeholders (such as Transport for London and London Borough of Havering so that there can be certainty that the impacts of the Brentwood Enterprise Park proposal are satisfactory and can be accommodated without any adverse impact on the network beyond Brentwood

* to recognize the role of the established joint working between authorities along the A127 corridor to ensure that the significant growth along this corridor is understood, assessed and mitigated as necessary.

* to recognize the merit of the preparation of a Statement of Common Ground or Memorandum of Understanding between relevant stakeholders to recognize the issues involved and set out a joint commitment to recognizing these and addressing them

* to recognize that the scale of the Brentwood Enterprise Park proposal and the traffic it will generate is likely to have significant adverse environmental impacts for the wider area (including Havering) and that these need to be considered and mitigated

* to include cross reference to Policy BE11 Strategic Transport Infrastructure

If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to set out the views of Havering Council on the Brentwood Local Plan and to ensure that the Council has an opportunity to contribute to the discussions with the Inspector.