Policy R26 should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken. The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form. Further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.