Housing Need and Supply -
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 Borough'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.

Following its response to the 2016 consultation, ECC continues to seeks 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.

Housing Need and Supply -
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 Borough'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.

Following its response to the 2016 consultation, ECC continues to seeks 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

Specialist Accommodation Needs and Supply - Registered Care

ECC acknowledges BBC is seeking to meet its identified needs for registered care provision, (424 spaces between 2013 and 2033) as identified in the SHMA. However ECC seeks clarification on the suitability of the proposed sites for the provision of specific registered care accommodation (424 spaces across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

ECC seeks careful consideration of locations of developments with specific allocations of homes for older people. Easy access to primary care services including GP, local facilities including pharmacists and shops and also public transport links are vital. This would also be applicable for permission given for conversions of buildings of previous use to residential care homes for older and vulnerable people.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required Gypsy and Traveller pitches, which are proposed on 3 of the 4 same large housing sites (see comments below).

In order to meet its statutory obligations as the provider of adult social care, control the costs of adult social care and improve the lives of residents, ECC is committed to influencing the provision of a range of housing options for the older population. Consequently, ECC is keen to support and enable older people to live independently.

At present a gap exists in the provision of Independent Living housing across Essex. There are not sufficient numbers of Independent Living units to relieve pressure for residential care placements. A target of 2,825 Independent Living units (available as rental or ownership units) has been set by ECC to be delivered by 2020 in the County. Not including units either in development or completed to date, there are 2,178 units remaining to be delivered across Essex. Within Brentwood, by 2020, 153 units are required; 26 units are already provided, which leaves 127 still to be provided by 2020.

A programme has been developed by ECC to increase the supply of Independent Living units across Essex. It is therefore recommended that reference to the ECC Independent Living programme and its role in housing delivery should be made in progressing the Plan.

Specialist Accommodation Needs and Supply - Registered Care

ECC acknowledges BBC is seeking to meet its identified needs for registered care provision, (424 spaces between 2013 and 2033) as identified in the SHMA. However ECC seeks clarification on the suitability of the proposed sites for the provision of specific registered care accommodation (424 spaces across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

ECC seeks careful consideration of locations of developments with specific allocations of homes for older people. Easy access to primary care services including GP, local facilities including pharmacists and shops and also public transport links are vital. This would also be applicable for permission given for conversions of buildings of previous use to residential care homes for older and vulnerable people.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required Gypsy and Traveller pitches, which are proposed on 3 of the 4 same large housing sites (see comments below).

In order to meet its statutory obligations as the provider of adult social care, control the costs of adult social care and improve the lives of residents, ECC is committed to influencing the provision of a range of housing options for the older population. Consequently, ECC is keen to support and enable older people to live independently.

At present a gap exists in the provision of Independent Living housing across Essex. There are not sufficient numbers of Independent Living units to relieve pressure for residential care placements. A target of 2,825 Independent Living units (available as rental or ownership units) has been set by ECC to be delivered by 2020 in the County. Not including units either in development or completed to date, there are 2,178 units remaining to be delivered across Essex. Within Brentwood, by 2020, 153 units are required; 26 units are already provided, which leaves 127 still to be provided by 2020.

A programme has been developed by ECC to increase the supply of Independent Living units across Essex. It is therefore recommended that reference to the ECC Independent Living programme and its role in housing delivery should be made in progressing the Plan.

Specialist Accommodation Needs and Supply - Gypsy & Traveller

ECC notes that BBC has been working in partnership with Essex local authorities, through jointly commissioning the Gypsy and Traveller Accommodation Assessment (GTAA) (2017) to provide a robust assessment of current and future need for Gypsy and Traveller and Travelling Showpeople families and has used this data to inform how it addresses this in its Draft Local Plan.

ECC acknowledges BBC is seeking to meet its identified needs (78 pitches between 2016 and 2033), as identified in the Brentwood GTAA Need Summary Report October 2017, and is seeking to follow a sequential approach to site identification. ECC recommends that reference should be made to the most up to date position which is from the Greater Essex GTAA for 2016-2033 which was endorsed by EPOA on 25th January 2018 and published in February 2018.

ECC also seeks clarification on the suitability of the proposed sites for the provision of specific Gypsy and Traveller accommodation (58 pitches across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required registered care facilities, which are proposed on three of the four same large housing sites (see ECC comments above).

ECC notes and welcomes reference to the GTAA recommendations for BBC to engage with other Essex authorities to establish whether there is a need for investment in more formal transit sites or emergency stopping places.

ECC recommends that BBC should reference the transit recommendations as set out in the published Greater Essex GTAA (2018), which recognises and seeks to address the strategic cross boundary matters at a larger 'Greater Essex' level, incorporating data from local authorities; the Essex Countywide Traveller Unit (ECTU) and other sources. There are a range of site options available to address enforcement and unauthorised encampment issues (ie not just Transit sites), but also emergency stopping places, temporary stop and stopping places and negotiated stopping places. There is a need for further investigation and analysis to provide a more robust appraisal of current and future transit needs, to be undertaken.

ECC recommends that as part of the Plan preparation process any policy provision and supporting text should be flexible enough to allow the outcomes of the further work to be incorporated.

Specialist Accommodation Needs and Supply - Gypsy & Traveller

ECC notes that BBC has been working in partnership with Essex local authorities, through jointly commissioning the Gypsy and Traveller Accommodation Assessment (GTAA) (2017) to provide a robust assessment of current and future need for Gypsy and Traveller and Travelling Showpeople families and has used this data to inform how it addresses this in its Draft Local Plan.

ECC acknowledges BBC is seeking to meet its identified needs (78 pitches between 2016 and 2033), as identified in the Brentwood GTAA Need Summary Report October 2017, and is seeking to follow a sequential approach to site identification. ECC recommends that reference should be made to the most up to date position which is from the Greater Essex GTAA for 2016-2033 which was endorsed by EPOA on 25th January 2018 and published in February 2018.

ECC also seeks clarification on the suitability of the proposed sites for the provision of specific Gypsy and Traveller accommodation (58 pitches across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required registered care facilities, which are proposed on three of the four same large housing sites (see ECC comments above).

ECC notes and welcomes reference to the GTAA recommendations for BBC to engage with other Essex authorities to establish whether there is a need for investment in more formal transit sites or emergency stopping places.

ECC recommends that BBC should reference the transit recommendations as set out in the published Greater Essex GTAA (2018), which recognises and seeks to address the strategic cross boundary matters at a larger 'Greater Essex' level, incorporating data from local authorities; the Essex Countywide Traveller Unit (ECTU) and other sources. There are a range of site options available to address enforcement and unauthorised encampment issues (ie not just Transit sites), but also emergency stopping places, temporary stop and stopping places and negotiated stopping places. There is a need for further investigation and analysis to provide a more robust appraisal of current and future transit needs, to be undertaken.

ECC recommends that as part of the Plan preparation process any policy provision and supporting text should be flexible enough to allow the outcomes of the further work to be incorporated.

Infrastructure Planning -
General education comments -
Page 7: paragraph 19 - As recognised in this paragraph, sufficient work has yet to be undertaken to accurately assess the impact of growth on education infrastructure. It is critical that this takes place whilst the Regulation 19 plan is prepared. A full scenario test identifying the location of and likely unit mix of all allocation sites and permitted development is needed. BBC will need to provide ECC with this information in line with section 3.4 of our 'Planners' Guide to School Organisation'. Once ECC has received this information and completed the assessment, a realistic IDP for education can be prepared and agreed. Discussions with ECC are therefore vitally important to ensure that this growth is planned, phased, properly funded and delivered in an efficient and coherent manner. For information relevant sections of the ECC response to the 2016 Draft Local Plan are included below.

Where growth is to be located it will be essential to ensure the delivery of education facilities is undertaken in a timely and phased manner. Additional school places can be provided either by the expansion of existing schools/ academies or the opening of new "free schools" or academies. Existing schools and academies can only be expanded if they have sufficient site area to do so. In many cases existing school/ academy sites are restricted and cannot, therefore, be expanded easily without the provision of additional land. This is often impracticable in urban areas as schools are located within the existing built up area. In many rural areas schools are on restricted sites but there may be land adjacent to the existing school/ academy site that could be utilised to enable expansion.

Whilst faith schools and academies may have sufficient site area to expand this would need the agreement of the Anglican Diocese of Chelmsford/Roman Catholic Diocese of Brentwood/ the academy trusts responsible for these schools/ academies. This is particularly relevant as a significant proportion of schools/ academies located within the borough are faith schools.

As indicated, ECC can identify those locations, particularly in rural areas, where scope exists to expand existing schools/ academies without the provision of additional land. In those areas where expansion opportunities are limited, sites for new schools should be identified within or close to the proposed developments. If existing schools cannot be expanded or growth is insufficient to provide a new school, it will be necessary for ECC to seek contributions from developers towards meeting the cost of providing transport between homes and schools.

The scale of expansion of existing schools/academies is also important. The majority of primary schools are organised in classes of 30 pupils to comply with infant class size limits. It is easier, more cost effective and better from an organisational perspective to expand primary schools by a full form of entry (30 pupils per year group) or half a form of entry (15 pupils per year group) than it is to accommodate a smaller number of pupils. On this basis it is often easier and more cost effective to ensure that there is a sufficient supply of school places for larger scale housing developments than it is for relatively small scale developments, particularly in rural areas. Sustainable home-to-school travel and transport and the location of development sites to ensure viability to fund schools will need further consideration.

Primary Schools -
Pages 39 - 42: Figure 15 and supporting text - Pupil planning takes place across school groups agreed with the DfE. It is unhelpful to show potential deficits against individual schools as admissions patterns may need to change in response to development proposals. Fewer larger projects will be required than might be assumed from Fig 15 and reading the supporting text. The figures in this and the following section have not been checked by ECC, as they do not form a full breakdown of the likely unit mix of all allocation sites (including DHGV), or of the already permitted and/or committed development.

Page 41: Paragraph 83a - New schools should normally be located on new developments rather than 'within close proximity'. Where this is not possible the viability of suitable nearby land for acquisition, and recovering the cost from developers, must be ensured. The Local Plan must include D1 Use Class allocations of land for new schools, agreed by ECC, which meet the criteria set out in ECC's Developers' Guide (section 4). 2.1ha of suitable land will be needed to establish each new school alluded to in this paragraph. Specific numbers of forms of entry should not be quoted in the Plan to retain sufficient flexibility.

Page 41: Paragraph 83b - ECC will be commissioning a viability study to look at expanding Mountnessing CE Primary School.

Page 42: Paragraph 83c - Expansion of West Horndon Primary School is already in ECC's 'Ten Year Plan' (page 28) to meet the demand for school places, adding half a form of entry for September 2019.

Page 42: Paragraph 85 and 86 - ECC's School Organisation team would welcome inclusion in the continued dialogue relating to the master planning of DHGV. The first new primary school site should be a minimum of 2.9ha and made available as early as possible within the development of the Garden Village Suburb. If 4,000 homes are built longer term then the preferred model will be three primary schools, with a minimum of 2.1ha sites sufficient for each of the latter two. Fewer larger schools would not be congruent with the Garden Village aim of sustainable travel patterns.

Secondary Schools -
Page 43: Paragraph 91 - Attention must be paid to the longer term forecasts, based on current primary school cohorts, which are published in the Ten Year Plan (page 29). This is to ensure that the full Plan period is accounted for, as the ECC forecasting plan is for a period up to 2020/21, but the BBC draft Local Plan is up to 2033.

Page 43: Paragraph 92 - As set out in ECC's 'Planners' Guide to School Organisation' (section 2.2), a school that will grow to 6fe is the smallest that can be supported and would require a minimum of 7.9ha of suitable land. The growth within the Plan period should make this viable if the school is planned to meet some wider demand. Although the site promotor for DHGV has alluded to an 'all-through' school, the type of school has yet to be determined, and this model may not fit with the spatial distribution of primary school places that will be required elsewhere in the borough. The school's role in meeting wider demand and the potential need for future expansion must be agreed with ECC prior to the commencement of any master planning work. If the garden village is to grow to circa 4,000 dwellings a minimum of 10ha secondary school site should be reserved.

Para 92 - ECC is very supportive of a joined up Basildon/Thurrock approach to the identification of education needs in relation to Dunton Hills and adjacent developments in these other LPA areas.

Special Education Needs (SEN) -
The consultation document provides some commentary on SEN in Brentwood borough, and advises that BBC will seek to support further development, in the form of sixth form facilities, at one of the two SEN schools located within the Borough.

Local Authorities should seek to provide a flexible range of provision and support that can respond to individuals' SEN and parents' and carers' preferences. This should cover the full range of ages. ECC seeks clarification as to how the requirements have been calculated and the evidence that supports this approach.

BCC will need to provide ECC with all the relevant information in order that ECC can undertake a further assessment of the potential delivery and resource requirements, for accommodating anticipated SEN requirements, to inform the pre submission plan, and its supporting IDP.