The Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available.

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning