ECC acknowledges that the Interim SA Report identifies a good range of both high level and more focused options for exploration, with a clear narrative throughout as to what constitutes a 'reasonable alternative'. This is an important step at this stage in the context of the plan-making process to date and the issues that BBC has faced.

ECC considers that Table 6.2 presents a thorough and useful number of options / permutations related to a spatial strategy for the Plan area. The findings of the Interim SA in regard to the 'preferred allocations' however is similarly high level and is limited to the identification of general cumulative impacts over a broad area. It is considered that the Interim SA should offer more commentary and recommendations regarding the assessment of sites at the 'local / micro level' in order to justify some of the high level conclusions. This is in light of the wide range of impacts identified within the individual site assessments in Appendix III which do not appear to be elaborated on.

ECC also recommends further cumulative impacts could be identified at a more local level. This could serve to further assist BBC in both the site selection of small sites in an area, and also the development of site specific policies at the Regulation 19 stage.

ECC notes that the Interim SA takes the same approach as the 2016 Interim SA when arriving at reasonable alternatives, which seeks to develop the reasonable alternatives for strategic level growth arising from work undertaken in 2015/2016, rather than the overall SA process. ECC recommends that a comprehensive audit trail of those alternatives that have been considered and subject to SA throughout the plan-making process should be produced, including detailing the reasons for rejecting and progressing alternatives at each stage. In addition, the cumulative assessment of the 'givens', for the purposes of satisfying the requirements of SA, should be presented, alongside their cumulative impacts to inform the strategy proposed.

In paragraph 6.3.2 of the Interim SA, reference is made to significant concerns raised to the DHGV allocation in the 2016 consultation having been addressed. ECC seeks clarification as to how these concerns have been addressed, particularly those raised in the ECC response to the BBC 2016 Draft Local Plan.

ECC would draw attention to a number of the conclusions on the Draft Plan in Chapter 10 of the Interim SA, which appraises the Draft Local Plan. It is clear that a significant amount of work is still to be undertaken to address concerns and uncertainties, and ECC seeks clarification that these matters will be addressed as part of the preparation of the pre-submission plan.

Areas of concern as to certain conclusions in the SA are as follows:

* Air Quality - concludes that no significant effects are likely to occur, however highlights there is considerable uncertainty at the current time ahead of further work still to be undertaken, including highway modelling;
* Climate Change - concludes that no significant effects are likely to occur, however highlights there is considerable uncertainty, with further work still to be undertaken, in relation to how the Plan can reduce CO2 emissions, including from transport;
* Economy and Employment - concludes possible significant effects, but uncertainty in the absence of detailed transport modelling;
* Landscape - concludes that there are likely to be significant negative effects; further work required to identify developable parts of sites and strategic open space and landscaping;
* Soil and Contamination - concludes that there are likely to be significant negative effects; an increase in the number of homes required is likely to increase the amount of agricultural land to be lost, some of which is likely to be 'best and most versatile';
* Water Quality and Water Resources - concludes effects are currently uncertain; need for detailed examination of waste water treatment capacity, and further work for robust DM policy to be in place.

ECC welcomes the comments in relation to the following:
* Biodiversity - further work to focus on borough-wide and site specific policy on ensuring development achieves net biodiversity gains
* Community Infrastructure - work on-going to understand issues, working with partners including ECC
* Flooding - thematic and site specific policies to be examined further including master planning and SUDs
* Waste - some waste infrastructure capacity issues locally to be addressed

In terms of assessing heritage in the SA, it is clear that listed buildings and conservation areas have been considered, however there is no reference to the extensive archaeological remains within the Borough. ECC considers that a Historic Environment Characterisation report, including consideration of archaeology, should support the preparation of the draft Local Plan.

ECC also recommends that Section 13.1.2 incudes a bullet point on the impacts for archaeology and historic landscape.

ECC welcomes the draft HRA screening report and the references to co-operating with other Essex local planning authorities (LPAs) on a strategic mitigation scheme for recreational disturbance (RAMS) to deliver measures to avoid adverse impacts on site integrity on European sites. The emerging RAMS is being co-ordinated by ECC for the 11 Essex LPAs needing to provide mitigation measures.

ECC recommends that references to developer contributions towards the Essex Coastal RAMS need to be clear. These should be sought from developers (not new residents), to avoid impacts from recreational disturbance, in combination with other plans and projects. A reference to the need for project level HRA for developments not proposing to contribute to the RAMS may also be helpful. This could be to secure bespoke mitigation measures in certain cases. Furthermore it is recommended that a reference is also made to project level HRA's, to ensure applicants minimise likely impacts from the developments alone in terms of layout.

ECC welcomes the acknowledgement for the need for a mitigation strategy for Epping Forest Special Area of Conservation (SAC) to deal with increased atmospheric pollution, and looks forward to receiving more details on modelling.

ECC notes that the evidence base for the Local Plan includes a Local Wildlife (LoWS) Review (2012) which enables consideration to be given to minimising impacts of site allocations on these non-statutory designated sites for biodiversity. However ECC advises that BCC should carry out assessments in relation to the preferred site allocations, including DHGV, to establish if they contain Priority habitats and species which could meet the criteria for new LoWS.

ECC welcomes the inclusion of a clear and concise vision for the Draft Local Plan, but recommends that reference to health and wellbeing, and the encouragement of healthy active lifestyles should also be included.

ECC welcomes the inclusion of a clear set of strategic objectives. It is recognised that BBC is seeking to ensure the strategic objectives are consistent with the national planning guidance through managing growth; creating sustainable communities; seeking economic prosperity; protecting and enhancing the environment; improving quality of life and providing community infrastructure; and addressing transport and movement matters. This is consistent with the PPG. However concern is raised with the increase in objectives from the 2016 Draft Local Plan (13), to the current consultation (23), and whether they reflect the strategic priorities for the Borough, or whether they are providing more detail which should be reserved for the policies within the Plan.

The strategic objectives clearly send the message that the purpose of the new Plan will be to align key infrastructure with sustainable growth, the development and resilience of health and wellbeing, creating a prosperous economy, whilst protecting the environment. ECC welcomes the anticipated benefits of this approach.

ECC seeks clarity on how Objective 13 (protecting the core office market) may be achieved. Recent evidence does not suggest that this is being supported, with existing commercial sites having been, or still being at risk of being lost to residential, including Library House, New North House, and BNY Mellon House.

ECC welcomes the protection and enhancement of the environment through Objective 16.

ECC is supportive of Objectives SO17 and SO22 in terms of BBC's support for enhancing the green infrastructure network and connectivity across the Borough. ECC is also supportive of Objective SO23 regarding supporting a low carbon future and inclusion of electric vehicle charging points.

Objectives S021, S022 and S023 all cover Sustainable Transport and the document makes reference to the fact that sustainable transport is central to their plan making, which is supported in principle by ECC.

ECC acknowledges and supports the need for improvements for sustainable travel and the need for modal shift, however there are areas of the strategic highway network such as the A127 that will require significant mitigation measures if economic growth is to be realised.

ECC is concerned that the Objectives that cover transport and movement (S021, S022 and S023) do not recognise the need for highway infrastructure to facilitate movement of goods / commuters.

As Highway Authority, ECC acknowledges the following strategic objectives, namely SO2 (Growth in transport corridors); SO5 (Growth accommodated by existing or proposed infrastructure), SO19 - (secure delivery of transportation and community infrastructure). ECC also welcomes the addition of the specific transport and movement strategic objectives SO21 (public transport infrastructure and connections), SO22 (cycling, walking and green transport corridors), and SO23 (infrastructure for low carbon future) in the Draft Local Plan.

ECC also recommends that reference be made to ensuring that proposals address the need for strategic and general highways infrastructure.

In order that the strategic objectives are met it is imperative that timely and appropriate highway modelling is undertaken. Further comments relating to highways and transportation matters are provided in the Spatial Strategy section below.

Housing -
ECC acknowledges BBC's work that seeks to meet housing needs in full over the Plan period (7,600/380 dpa) and supports the 20 year Plan period (2013 - 2033). This would deliver the BBC's housing need in full and support the projected number of jobs/workers forecast in the Plan period. ECC supports the prioritisation of bringing forward brownfield sites and all appropriate land within existing urban areas, and through maximising density where appropriate. This will direct development towards existing settlements, particularly those that already benefit from access to a range of services and access to sustainable transport modes. However, in doing so any strategy will need to demonstrate that the level of growth can be accommodated by the existing and new social and physical infrastructure.

ECC acknowledges that BBC will need to be satisfied that the Local Plan is supported by a proportionate evidence base and that all reasonable alternatives have been considered. See ECC earlier commentary on the SA.

Following its response to the 2016 consultation, ECC continues to seek further clarification on a number of issues in relation to the proposed spatial strategy including:
* how the A127 Corridor provides more opportunities for growth than the A12 Corridor;
* identification of any cross border implications of the spatial strategy given its role as highway, education, minerals and waste, and lead local flood authority, and public health responsibilities;
* identification of what infrastructure is necessary to deliver the spatial strategy, strategic and individual site allocations; and
* a full assessment of the highway and transportation implications of the proposed spatial strategy, both in terms of the impacts of the individual preferred site allocations, and cumulatively.

ECC therefore withholds support until the appropriate highway modelling has been undertaken, to assess both the site specific and cumulative impacts of such developments on the local, and wider highway network.

Transport and Highways -
BBC commissioned PBA to assess the impact of options for strategic development within the Borough in the coming years. The `Brentwood Borough Local Plan Development Options - Highway Modelling' was published in draft form as part of the 2016 consultation. The draft Report set out the approach of PBA to highway modelling, the results of the modelling and junction assessments, and highlighted those worse performing junctions that may require mitigation, to enable the development sites to come forward.

4.38 ECC reviewed PBA's draft Report in 2016, and provided a significant number of comments and concerns to BBC. ECC highlighted that there were still areas of the methodology that would benefit from further clarification, and aspects of the modelling that would need to be revisited.

4.39 ECC highlighted that any further modelling work would need to consider a number of matters including:
* Rebuilding of forecast matrices to account for revisions made to development numbers contained in the Local Plan,
* Recalculation of trip rates to also account for sustainable travel,
* Consideration of background growth to incorporate fuel efficiency and income growth factors,
* Validation of base model outputs to observed conditions,
* Sensitivity testing of forecast model assignment,
* Determining how the model can be improved to provide a more accurate assessment of cross-boundary impacts,
* Remodelling of all junctions currently in scope of assessment, accounting for uneven lane usage, peak hour demand profiles and the impact of pedestrian movements.

4.40 ECC also advised that no analytical work had been undertaken on the strategic route network (A12 and M25) or in relation to the A127, which given the level of growth required, raised concerns.

4.41 The A127 is a vitally important primary route for the South Essex area which connects the M25, Brentwood, Basildon and Southend (including London Southend Airport). A major aim of ECC is to improve journey time reliability along this route. There is significant growth planned along the A127 corridor in adopted and emerging Local Development Plans along its entire route, which will need to be considered in any highway modelling in terms of capacity, key junctions and access.

4.42 The impacts of the preferred route of the LTC will need to be assessed and factored in to the further modelling in support of the Draft Plan. It is considered that the LTC would have an impact on/ and opportunities for the Brentwood Borough as well as the wider transport network across South Essex and beyond. A new LTC will fundamentally change the dynamic of strategic transport movements within and across Brentwood and Greater Essex.

4.43 ECC is clear that the further modelling work needs to clearly illustrate the local and cumulative impact on the local and strategic transport network, to demonstrate that the proposed spatial strategy is the most appropriate, and to identify any mitigation measures which would be required. Any mitigation required will need to be clearly stated in the relevant policies.

4.44 ECC, as the Highway Authority, needs to be engaged on the further modelling work, to be satisfied with the approach, assumptions and outcomes, in order to provide support to BBC in the plan preparation process and at examination. As previously requested ECC require BBC to incorporate a review process, at the end of each stage, into the modelling programme.

4.45 BBC has begun work to address the outstanding issues and ECC are engaging with BBC and PBA to progress this. However, until this appropriate highway modelling has been undertaken, and ECC has reviewed and confirmed satisfaction of the work, ECC continues to withhold support for the Draft Plan.

Employment -
ECC acknowledges the ambition to develop new key strategic employment sites but this needs to be set within the wider context of Brentwood's Spatial Strategy, and any location to be consistent with the criteria to seek to ensure future developments are located in accessible locations reducing the need to travel. ECC therefore withholds support until the appropriate highway modelling has been undertaken, to assess both the site specific and cumulative impacts of such developments on the local, and wider, highway network.

ECC raises concerns over the allocation of 57% of the new employment land on one site, Brentwood Enterprise Park (BEP). The Economic Forecast Report also highlights concerns with regard to the considerable reliance on the BEP employment allocation. It is recommended that consideration be given to the phasing and deliverability of the site, to ensure a readily available supply of employment land across the short, medium and long term.

Furthermore ECC would draw attention to the 'red line' boundary for the LTC major road scheme, which seeks to incorporate a significant part of the BEP employment allocation. Whilst it is acknowledged that one of the aims of the LTC is to be a key driver for economic activity, and if such a scheme is not to impact on the deliverability of the BEP, clarification is sought over this matter, and in respect of the deliverability of the full allocation over the Plan period, particularly given the need for the site to come forward in phases over the short, medium and long term.

ECC acknowledges the significant contribution the BEP allocation would make to meeting the employment needs of the Borough over the Plan period. However, its location, in close proximity to the M25 and A127, which is presently over capacity, provides primarily car based connections to service centres, and potential sources of employees. The location is not favourable to sustainable transport measures and at present there is limited evidence regarding any potential connectivity of the proposed development via sustainable transport measures. Additional clarification will be required regarding opportunities for such measures, and the output of any impact on the strategic junction, local road network and potential mitigation requirements to be programmed (as part of the IDP). The potential impact on the above would also depend on the mix of B1, B2 and B8 uses proposed on the site.

Infrastructure -
ECC agrees that the Local Plan will be critical for making sure BBC has the right infrastructure, at the right time, to accommodate the new jobs and homes proposed within the Plan period. ECC considers that large scale housing developments will need to include appropriate infrastructure such as education provision, community and health facilities, flood mitigation through SUDs, and improvements to transport infrastructure. Small scale development should also fund improvements to existing services and facilities. ECC note that infrastructure provision is likely to have a major impact on the phasing and deliverability of development.

ECC consider the phasing of development and funding of infrastructure will be crucial for effective delivery and this will need to be reflected in the evidence base as Local Plan preparation progresses. Currently ECC consider that this is unclear.

ECC therefore consider it essential that all sites are assessed together as part of Plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. It is imperative that the costs of providing infrastructure as a direct result of development proposals, particularly those related to early years and childcare, primary and secondary schools, and highways, for which ECC has a statutory responsibility, are included in the viability assessment from the outset, to ensure provision is guaranteed. ECC seeks clarity on how this process has been undertaken.

ECC would draw BBC's attention to the ECC Full Council Motion in October 2014, reaffirmed in July 2017, which states that 'Essex County Council will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life'. In accordance with this Motion, it is recommended that ECC continues to withhold support for the Draft Plan, until the appropriate work in relation to ensuring the provision of all suitable infrastructure has been undertaken, and ECC has reviewed and confirmed its satisfaction with the work.

The Local Plan spatial strategy is of particular importance to ECC as it will need to be satisfied that the impact of any planned scale and distribution of growth can be accommodated by ECC areas of responsibility, or identify what additional facilities or mitigation are required to make the strategy sustainable in social, economic and environmental terms.

An IDP will need to be prepared to support the Local Plan, and identify infrastructure required. The Local Plan should make clear, for at least the first five years, what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development. For the later stages of the Plan period less detail may be provided as the position regarding the provision of infrastructure is likely to be less certain. As a provider of key services and subject to statutory responsibilities, for example minerals and waste; highways, education, early years and childcare; and public health, ECC is keen to assist BBC in the preparation of the IDP, and welcomes the opportunity for engagement with BBC to assist in the preparation of the Local Plan towards pre-submission. However, as stated above, until this appropriate work has been undertaken, and ECC has reviewed and confirmed its satisfaction with the work, it is recommended that ECC continues to withhold support for the Draft Plan.

Metropolitan Green Belt -
ECC is committed to working closely with its local authorities to meet the increasing demand for housing and infrastructure that meets the needs of residents, drives economic prosperity and protects and enhances the local environment. Paragraph 83 - 85 of the NPPF identifies that Local Planning Authorities should establish Green Belt boundaries that ensure consistency with the Local Plan strategy for meeting identified housing requirements in sustainable locations, and any Green Belt review should be undertaken as part of the Local Plan preparation.

The Draft Plan Spatial Strategy seeks to maximise development on brownfield sites within existing urban areas, including the redevelopment/allocation of employment sites for residential use. The commentary provided in the consultation document states that given the finite availability of these sites in the Brentwood/Shenfield urban area, and lack of such sites to meet the objectively assessed need, significant growth will be (required on green belt sites.

The Draft Local Plan contains two 'strategic objectives' (SO15 and SO16), which seek to safeguard the Green Belt from inappropriate development and to protect and enhance valuable landscapes, and the natural/historic environment. The Borough is covered by 89% Green Belt, along with a wide range of other environmental constraints including distinct landscape types of relatively high sensitivity to change; and two large Country Parks at Thorndon Park and Weald Park. Other designations include SSSI's, Local Nature Reserves, biodiversity habitats, and Thames Chase Community Forest.

ECC acknowledges the sensitive nature of the Borough and the need to balance growth with retaining local character. The Borough Council will need to be satisfied that it has identified its preferred spatial strategy, which includes significant Green Belt release, based on a range of proportionate evidence. In so doing, BBC will need to demonstrate that it has considered all reasonable locations for future growth against the relevant criteria, and demonstrate that the most appropriate sites have been identified for allocation.

Spatial Strategy General -
ECC welcomes reference in Paragraph 37 of the consultation document to BBC working jointly with the South Essex LPA's to secure infrastructure investment and consider wider growth opportunities. ECC recommends that more detailed reference is made to this work, including the Memorandum of Understanding that has been signed by the South Essex Authorities to work together on strategic cross boundary matters, the establishment of the Association of South Essex Local Authorities (ASELA), the work that has taken place on a South Essex 2050 Vision, and the work underway to progress a South Essex Joint Spatial Plan.