Historic England previously submitted comments on the Brentwood Strategic Growth Options Consultation (dated 10th February 2015) and the Dunton Garden Suburb Consultation (dated 10th February 2015). Brentwood Borough Council has a rich historic environment with 13 conservation areas, 518 listed buildings, 3 historic parks and gardens (registered landscapes) and 12 scheduled monuments across the Authority. Historic England's Heritage at Risk Register records three entries for Brentwood Borough at Chantry Chapel and Mausoleum (grade II* listed building in poor condition), at Thoby Priory ruins (grade II listed building in very bad condition) and at the Church of St Paul, Mores Lane, Bentley, Brentwood (grade II listed building in slow decay with no solution agreed).

Policy 5.1 Spatial Strategy

Since these submissions were made (February 2015) Historic England have issued its own Advice Note 3 'The Historic Environment and Site Allocations in Local Plan' (issued October 2015).

This guidance establishes a five stage site selection methodology for site selection which includes,

* Step One - Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
* Step Two - Assess the contribution of the site to the significance of heritage assets on or within its vicinity
* Step Three - Identify the potential impacts of development upon the significance of heritage asset
* Step Four - Consider how any harm might be removed or reduced, including reasonable alternatives sites. This also involves consideration as to how any enhancements could be achieved and maximised
* Step Five - Determine whether the proposed site allocation is appropriate in light of the NPPF test of soundness.

Historic England drew attention to this methodology in the January 2015 consultation response and can now confirm it has been formally published.

This Advice Note can be accessed at

https://content.historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans.pdf/

Policy 6.1 Sustainable Development

Policy 6.3 General Development Criteria, especially at (g) 'when considering the impact of development on the significance of a designated heritage asset, greater weight should be given to the assets conservation and enhancement'.

Policy 6.6 Strategic Sites and 7.1 Housing-Led policy (confirming a housing led scheme at Dunton Hills Garden Village of up to 2,500 dwellings).

Paragraph 6.32 confirms West Horndon is removed as a strategic allocation for growth to protect the village settlement.

Paragraph 7.1 mentions the use of master plans to agree the form, mix and siting of development.

Paragraph 7.35 notes that at Dunton Hills Garden Village that not all of the landholding will be developed.

Historic England Representations:

Historic England notes that the West Horndon village development area is not now a preferred option. This is consistent with the preferred options consultation (2015) where it was stated that only one of either West Hornton or Dunton would be pursued. Historic England then raised concerns about the cumulative impact and extent of urbanisation along the A127 corridor.

The interim sustainability appraisal (interim SA) to the current draft Local Plan consultation made the point at 14.1.1 that however, Historic England did not suggest outright objection to growth in this area ("an adequate buffer between West Horndon and Dunton would be expected") and concerns from 2015 may now be somewhat allayed, given that a comprehensive Dunton Garden Suburb scheme is no longer being actively considered as an option. A Dunton Hills Garden Village scheme might well impact on the setting of Dunton Hills farmhouse (grade II listed), however.


Historic England would also make reference to the sustainability appraisal for Dunton Garden Suburb Consultation (as produced by LUC and dated November 2014). We refer to this below in our representations.

The deletion of West Hornton is a significant change to the assessment of impacts. The impact upon the setting of historic assets within the site and outside the site are matters that require further detail. The setting of a heritage asset is defined in the glossary of the National Planning Policy Framework and National Planning Policy Guidance confirms that this may therefore be more extensive than curtilage. Historic England previously drew attention to this as it will be a significant material consideration in the assessment of impacts upon these heritage assets.

The NPPG states that 'The extent and importance of setting is often expressed by reference to visual considerations. Although views of or from an asset will play an important part, the way in which we experience an asset in its setting is also influenced by other environmental factors such as noise, dust and vibration from other land uses in the vicinity, and by our understanding of the historic relationship between places. For example, buildings that are in close proximity but are not visible from each other may have a historic or aesthetic connection that amplifies the experience of the significance of each'. Reference is Paragraph: 013Reference ID: 18a-013-20140306 dated 6 03 2014.

The Dunton strategic allocation (site reference 200) has been the subject of previous comments by English Heritage in respect of the Dunton Garden Suburb consultation (February 2015). These comments still apply to the draft Local Plan. This preferred allocation includes heritage assets at Dunton Hills (grade II - a 17th century house), the Church of St Mary (grade II and rebuilt 1873) and Dunton Hall (grade II - an early 19th century house). Setting is also a material matter and this applies to Wayletts (a grade II timber framed farmhouse to the north-east), Barnards (a grade II timber house), to the Church of All Saints (grade II) and a monument in the churchyard (grade II) as well as the historic park and garden at Thorndon Hall (to the north-west), itself a grade II* landscape.

The detailed consideration of setting will be a matter of material importance and such considerations are a constituent part of Local Plan policy 9.5 'Listed Buildings' and policy 6.3 (g) when considering the impact upon the significance of the asset.

The sustainability appraisal for the 2015 Dunton Garden Suburb consultation identified the eastern part of the site as a 'historic environment zone' considered sensitive to change (paragraph 2.15 of this document). It reported that this site
' contains archaeological find areas and medieval sites or find-spots, as well as remnants of historic field patterns of possible Middle Saxon origin. There are two listed buildings in the area, Dunton Hall and Dunton Hills, with others nearby. To the north west of the area is the Registered Park and Garden of Thorndon Park with Old Thorndon Hall and Gardens Scheduled Monument. The major employment and residential development identified for the site could have a significant negative effect on the setting of these historic assets and on the listed buildings within and close to the site unless appropriate mitigation measures such as natural screening are incorporated into the detailed design and layout of the development. Additional road traffic travelling between the development and Brentwood on the A128 could have adverse
effects on the historic assets of Herongate and Ingrave villages on this route and on the centres of Brentwood and Shenfield'.

Paragraph at 2.16 concluded that
'there is potential for a significant negative impact on the heritage environment. This effect is judged to be uncertain as it may be possible to avoid or reduce the potential effects by sensitive layout and design of development'.

The interim sustainability appraisal for the Local Plan, at its page 84, accepts that 'A Dunton Hills Garden Village scheme might well impact on the setting of Dunton Hills farmhouse (grade II listed).'

Historic England therefore recommends that further investigation is required including characterisation work to inform the evidence base. This work will inform the historic environment evidence base consistent with paragraph 169 of the National Planning Policy Framework. Historic England has published guidance which deals with historic characterisation in local and neighbourhood plans. This document is 'Understanding Place - Character and context in local planning' (published 2011 - revised June 2012) and is available at https://content.historicengland.org.uk/images-books/publications/understanding-place-character-context-local-planning/understanding-place-cclp.pdf/

Further guidance is available as
'Understanding Place - Historic Area Assessments: Principles and Practice' (June 2010) and is available at https://content.historicengland.org.uk/images-books/publications/understanding-place-principles-practice/understanding-place-haa.pdf/

The interim sustainability appraisal for the current draft Local Plan consultation states that when considering site options appraisal that
Limited data is available to inform the appraisal. Whilst there is good potential to highlight where development in proximity to a heritage asset might impact negatively on that asset, or its setting, a limitation relates to the fact that it has not been possible to gather views from heritage specialists on sensitivity of assets / capacity to develop sites. This is a notable limitation as potential for development to conflict with the setting of historic assets / local historic character can only really be considered on a case-by-case basis rather than through a distance based criteria. It will also sometimes be the case that development can enhance heritage assets.
(interim SA at page 57).

Historic England would conclude that the need for characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb.

Policies 9.5, 9.6, 9.7, 10.5 and 10.6.

The Local Plan as a whole should be able to demonstrate that it sets out a positive strategy for the historic environment. This means that, on balance, the Local Plan has a positive effect on the historic environment and heritage assets. Policies throughout the plan should help deliver the conservation of the historic environment. The Council have a specific historic environment policy at Policy 9.5 'Listed Buildings', at Policy 9.6 'Conservation Areas' and Policy 9.7 'Ancient Monuments and Archaeological Remains'. Additionally, Policy 10.5 'Public Realm' and Policy 10.6 'High Quality Design Principles' also applies to the historic environment at criterion (f) regarding designated and non-designated 'heritage assets' and at criterion (g) to include information sufficient to assess the potential impact on the significance of the asset and including matters of archaeological significance.

Historic England recommends s additional text is added to Policy 10.6.
For Policy 10.6 'High Quality Design Principles' Historic England would recommend that (f) introduces the concept of optimum viable use at the end of the policy text, dealing with the most appropriate conservation use. National Planning Policy Guidance states that 'If there is only one viable use, that use is the optimum viable use. If there is a range of alternative viable uses, the optimum use is the one likely to cause the least harm to the significance of the asset, not just through necessary initial changes, but also as a result of subsequent wear and tear and likely future changes. The optimum viable use may not necessarily be the most profitable one (guidance continues). Reference is Paragraph: 016Reference ID: 18a-016-20140306 dated 6 03 2014.
Historic England recommends additional suggested text as underlined.
Policy 10.6.(f)
Historic England would recommend additional policy text at the bottom of criterion (f) that sensitive use of heritage assets consistent with their most appropriate conservation use (the optimum viable use) .... (policy continues) ....will be encouraged'.

Historic England note that site 038B
Land East of Thorndon Avenue, West Horndon is not a preferred site.
Historic England note that site 162 Little Warley Hall Farm, Little Warley Hall Lane, Little Warley is not a preferred site.
Historic England note that 058A and 058B
Hall Lane Farm, Little Warley is not a preferred site.
Historic England notes that the interim sustainability appraisal for the draft Local Plan at paragraph 14.1.2 also reports that notes that 'As for the A12 urban extension allocations, these do not raise major concerns from a heritage perspective, although it is noted that: the proposed extension at 'Land east of Nags Head Lane, Brentwood' is in close proximity to several listed buildings at Brook Street; and also that the large Officers Meadow site at Shenfield will have implications for the Chelmsford Road, along which there are a number of listed buildings'.

Historic England recommend reference to its Advice Note 3 (AN3) 'The Historic Environment and Site Allocations in Local Plan' (issued October 2015)
and to its Good Practice Advice Note 3 'The Setting of Heritage Assets', (issued March 2015) which is available at
https://content.historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/gpa3.pdf/

Historic England note that the following sites are also not preferred and as:
033 Land to the south of Lodge Close, east of Hutton is not preferred
211 Land and building on the West of Church Lane, Hutton is not preferred
219 Land to the East of Hutton Village, Hutton, Shenfield is not preferred
008 Woodlands, School Road, Kelvedon Hatch is not preferred
008B Woodlands School, Rayleigh Road, Hutton
is not preferred
008C Land adjacent Woodlands School, Rayleigh Road, Hutton is not preferred
028A Land east of Running Waters, Brentwood
is not preferred
028B Land east of Running Waters, Brentwood
is not preferred
028C Land east of Running Waters, Brentwood
is not preferred.
Historic England concerns here for the setting of heritage assets as a result of sites 028A/028B/028C is noted in the interim Sustainability Appraisal at its pages 83 and 84.
038A and B Land East of Thorndon Avenue, West Horndon are also not preferred and dealt with at page 84 of the interim Sustainability Appraisal.
192 Heron Hall, Herongate, Brentwood is not preferred
212 Coombe Woods, Beredens Lane, Warley is not preferred
167 Land adjacent Hill Cottage, Warley Road, and Mill House, Mascalls Lane, Warley is not preferred
218 Land East of Hall Lane, Shenfield is not preferred
052 Land rear of Little Jericho, Church Street, Blackmore is not preferred.
202 Land to the South of Blackmore, off Blackmore Road is not preferred
076 Land south of Redrose Lane, backing onto Orchard Piece, Blackmore is not preferred.
077 Land south of Redrose Lane, backing onto Woollard Way, Blackmore is not preferred.
174 Land south of Hook End Road, Doddinghurst
is not preferred
183 Former sewage pumping station at Ingrave Hall, Ingrave is not preferred
209 Land to South of Blackmore Road, Doddinghurst is not preferred
056A Land at Hayden and Ardslia, Wyatts Green Road, Wyatts Green is not preferred
056B Land at Hayden and Ardslia, Wyatts Green Road, Wyatts Green is not preferred
196 Land to North West of Lowes Farm, Wyatts Green Road, Wyatts Green is not preferred
018 Thoby Priory, Thoby Lane, Mountnessing is not preferred.
217 Eagle Field, Kelvedon Hatch is not preferred
194 Brizes Corner Field, Blackmore Road, Kelvedon Hatch is not preferred
074 Land at Church Road, Kelvedon Hatch is not a preferred site.
187 Employment sites - not preferred.
109 Employment sites - not preferred.
100 Baytree Centre, Brentwood is a preferred site. This site falls within the town centre conservation area and the principal access from the High Street is also within the conservation area. A group of three listed buildings (60, 62 and 64 High Street) lies to the immediate north-east of the site and the Ruins of the Old Chapel of St Thomas a Becket (a grade II listed building and scheduled monument) lies further to the east.

Historic England recommends a detailed heritage impact assessment is produced to provide appropriate policy guidance. It may be deemed appropriate, within the tests of s106 planning obligations in the CIL regulations, that some funding and other interpretation enhancements from this development are deployed to the benefit of the Chapel of St Thomas A Becket. The Brentwood Town Centre Regeneration Strategy of 2010 highlights protecting and enhancing the town's heritage as a key policy objective of its regeneration strategy.