Healthcare - General Practice -
BBC should be advised that Public Health is the responsibility of ECC, in addition to the roles of the CCG.

ECC considers the information provided in paragraph's 97 to 105 and figure 17 of the consultation document provides a good general overview of the up to date evidence relating to GP's in the borough; however there is no consideration of the wider health implications that need to be addressed as part of the plan making process.

Supporting the design and creation of healthy communities is fundamental to the NPPF. ECC is supportive of the general objectives around health within the plan, but consider that these could be greatly enhanced. ECC therefore question if the Draft Plan, at present, ensures that the inclusion of health and wellbeing can be fully assured. This is due to the lack of specific policy on health and wellbeing or associated requirements for the submission of Health Impact Assessments (HIA) with planning applications.

ECC considers that without such policies, the opportunities to support the positive impacts that development can have on health, wellbeing and the wider determinants may be missed. In addition, any negative impacts on health could be more difficult to remove or be mitigated against. The allocation of Section 106 monies to health and wellbeing may also be challenged without the appropriate policy background.

The Essex Planning Officers Association (EPOA) support the use of HIA and have guidance notes on thresholds. HIA, as a material consideration, ensures health and wellbeing is addressed. ECC recommends that HIA is undertaken to inform the preparation of the Local Plan.

Priorities for public health within spatial planning include reducing health inequalities, by supporting access to quality open and green/blue space, healthy diets including improving access to local and fresh food, improving community cohesion and reducing social isolation, supporting air quality through active travel, increasing physical activity opportunities through increasing movement and play across all ages and supporting good quality housing design across the life course. EEC recommends that such matters should be considered as the plan progresses towards submission.

ECC Public Health has been engaged with the Town and Country Planning Association (TCPA) on work around Garden Communities. In addition, Health and Wellbeing has been incorporated into the Essex Design Guide refresh and addresses Garden Community developments. ECC strongly encourage BBC to engage early with the ECC Director of Public Health and team for advice on healthy urban planning for this development.

In addition, ECC works closely with various health partners to support their healthcare estates including NHS England East and Community Health Partnership, on access of healthcare infrastructure and would be happy to be part of conversations with our partners to ensure that the whole health system is considered as part of the plan making process.

With regards to food retailers and premises, ECC would signpost BBC to the tool developed by the Centre for Diet and Activity Research (CEDAR) on food geography. This enables local authorities to see the types of food outlets in their areas. It includes A5 premises (under a wider scope of fast food). ECC advises that the management of A5 premises should be considered as part of the plans overall health and wellbeing approach, together with some emerging evidence base on overconcentration of fast food outlets and obesity. There are a number of authorities developing and adopting specific A5 policies, and ECC would be happy to support BBC on building on these principles.

ECC Public Health is engaged with planning teams for many Essex Garden Community proposals. This is to ensure that healthy urban design principles are incorporated into the design and planning of these strategic sites. ECC wish to be engaged in any HIA process that would be part of the development planning for DHGV. The refresh of the Essex Design Guide (EDG) provides references/advice on garden principles, and Sport England provide guidance on active design principles and health.

ECC Public Health is supportive of lifetimes, adaptable homes. This would include housing design for older people. ECC encourages design to be inclusive and allow for accessibility. These aspects have been raised as part of the Essex Design Guide refresh. ECC also promotes dementia friendly community principles, such as those set out in the RTPI dementia friendly practice guidance.

On key worker homes and affordable housing for NHS key staff, ECC advise that discussions on workforce planning with NHS providers should be considered to support the development of their workforce strategies. This would support the health and wellbeing of communities and also access to healthcare infrastructure to which the workforce should be considered as an integral part (as per the NPPF).

With regard to specialist housing, ECC Public Health advise that the social care team at ECC should be engaged on this matter. The relevant CCG should also be engaged to ensure GP provision is available to support these specialist homes.

ECC support the inclusion of an air quality policy, as part of the overall health and wellbeing agenda. ECC recommend that this can be further supported by active travel encouragement.

Other references that may be of assistance are PHE health profiles and PHE guidance on planning and PH.

Highways and transportation -

The infrastructure section of the consultation document contains no information on highway and transportation matters. As referred to earlier in this Appendix, this is a fundamental gap, especially in the wider South Essex context and on regional issues such as the A127. ECC is clear that 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 infrastructure and/or mitigation measures which would be required.

BBC will need to engage with ECC on this work, and allow for review mechanisms to be put in place, to allow ECC to be satisfied with the modelling approach, assumptions, and outcomes. Until this appropriate work has been undertaken, and ECC has reviewed and confirmed satisfaction of the work, it is recommended that ECC continues to withhold support for the Draft Plan.

ECC supports the aspiration to improve the public realm and circulation arrangements around Brentwood and Shenfield stations given the impact from Crossrail. ECC advises that similar improvements may be necessary at Ingatestone and West Horndon stations to encourage sustainable travel and mitigate the potential growth. For all stations, park and walk, or park and ride sites, are potential tools that could form part of an overall parking and access strategy.

BBC should ensure policy requirements stipulating that a high quality digital infrastructure is installed from the outset of any new developments (residential and non-residential).

ECC advise that BBC should give consideration to enhanced infrastructure to serve strategic locations such as Brentwood Enterprise Park and Dunton Garden Village.

Early Years and Childcare (EYCC) -

The consultation document makes no reference to the requirements for EYCC provision arising from the planned growth in the Plan period. ECC is responsible for meeting certain statutory responsibilities relating to the provision of EYCC services within BBC. This includes supporting EYCC providers with information, advice, guidance, training and a duty under the Childcare Act 2006 to ensure there is sufficient and accessible high quality early years and childcare provision. The Essex Early Years and Childcare Strategy 2015-2018 sets out ECC's strategic objectives and priorities relating to early years and childcare services across Essex.

An assessment of EYCC requirements will need to take place and those requirements will need to be included in appropriate policy and site allocations (both housing and employment) where growth generates need. Once ECC has received this information and completed an assessment, a realistic IDP for EYCC 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.

ECC also recommend that paragraphs 18a and 76 of the consultation document make specific reference to EYCC provision.

A high level assessment of the preferred housing site allocations detailed in the consultation document using the most up to date sufficiency data (summer 2017) has identified the need for the following: (see attached table)

Employment sites will be affected by the number of employees, and the amount of floorspace on each site. ECC therefore seeks further information in relation to proposed employee numbers and floorspace in order to provide comment in relation to the employment sites.

It is also important to note that the existing capacity has been considered by ward rather than settlement, and hence the available capacity by setting has not been translated into the number of dwellings that each settlement can accommodate. Until BBC provides ECC with a further breakdown as to exact numbers and locations, the figures could be subject to change.

It should also be noted that from September 2017 the Extended Funding Entitlement Offer (EFE) was introduced, which could also affect the calculations of the requirement figures.

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 childcare requirements, to inform the pre submission Plan, and its supporting IDP.

Post 16 Education / Skills -

ECC advises that there is a requirement for students to stay in a form of education and training until they are at least 18 years old. The consultation document makes no reference to such provision, and ECC recommends that BBC have consideration to the full range of opportunities for the provision of such education, including apprenticeships, in the Plan making process.

The consultation document makes no references to how the Local Plan will address the issue of improving the skills base in the Borough. The Essex Employment and Skills Board identifies 7 priority sectors which are set for growth in Essex and are suffering skills shortages in advanced manufacturing and engineering, care, construction, financial and related services, health, IT, digital and creative, and logistics. ECC recommends that BBC consider how the Plan can address this matter.

ECC also recommends the plan makes reference to the importance of the use of employment and skills plans, particularly in relation to the large scale developments proposed, such as DHGV.

Minerals and Waste -

ECC is the Mineral and Waste Planning Authority for Essex. The Mineral Local Plan (2014) and Waste Local Plan (2017) form part of the development plan in Brentwood and therefore should be referenced as such within the opening pages of the Draft Plan.

ECC's response to the draft Local Plan in 2016 remains relevant and is attached as Appendix 2.
 
Minerals -

The Essex Minerals Local Plan (2014) (MLP) provides up-to-date planning policy for minerals development in Essex until 2029. In particular, it gives certainty as to the location of future minerals development by identifying sites and locations for the extraction of mineral deposits. There are also procedures to reduce the demand for primary mineral use, recycle more aggregate and safeguard mineral resources, reserves and important facilities.

There are deposits of sand and gravel within Brentwood Borough which are subject to Policy S8 Safeguarding Mineral Resources of the MLP. In line with national planning policy, Policy S8 identifies a Mineral Safeguarding Area (MSA) which covers large areas of the County where surface development will be resisted unless evidence can be provided to confirm that the resources are not viable/suitable for prior extraction.

There are areas around the urban area of Brentwood that are covered by a MSA for sand and gravel. In 2016, a high level assessment concluded that some proposed allocations in the Draft Local Plan fell within MSAs for sand and gravel. Now that new site allocations are proposed, it is necessary for mineral safeguarding matters to be thoroughly considered prior to inclusion in the Pre Submission Plan. ECC has provided assistance to all other Essex LPA's in relation to their Local Plans in this respect, by running a GIS based assessment process and identifying text for inclusion in site allocation policies where necessary.

It is essential that the preferred site allocations included in the Draft Local Plan are considered in respect of their mineral safeguarding implications. A GIS layer of the preferred sites should be provided to the ECC Minerals and Waste team as soon as possible to enable this assessment to take place.

Waste -

ECC is the waste planning authority for the Borough, and is responsible for preparing planning policies, and also for assessing applications for waste management development. The Essex and Southend-on-Sea Waste Local Plan (2017) (WLP) is a statutory Development Plan which should be read alongside the Draft Local Plan. It sets out where and how waste management developments can occur, and is the planning policy against which waste management development planning applications are assessed. The WLP does not allocate any strategic waste management allocations in the Borough. The WLP also identifies Areas of Search to meet the need for additional small scale waste management facilities. It identifies two Areas of Search within Brentwood Borough. These Areas of Search are existing industrial estates at Childerditch Industrial Estate and West Horndon and are located away from residential and other uses sensitive to amenity impacts such as schools, retail, leisure and office development. The WLP seeks to focus any new proposals for waste management facilities, which support the local housing and economic growth, within these Areas of Search.

The Brentwood Local Plan should refer to ECC's role as the Waste Planning Authority and to the adopted WLP. The draft Local Plan 2016 contained limited reference to waste management facilities, and in particular advice for their provision in the proposed Development Management Policies. Some advice is provided in line with European, National and Planning Practice Guidance, which seeks the promotion of the waste management hierarchy within sustainable development. In particular, ECC recommends reference is made in appropriate policies in the Draft Local Plan to enabling the provision of waste management facilities in employment areas, by referring to 'any associated employment generating sui generis uses', given that the WLP does not allocate any strategic waste management allocations in Brentwood Borough. ECC continues to support references to renewable energy schemes and sustainable construction.

Infrastructure Planning - Water -

BBC should note that both the Strategic Flood Risk Assessment (SFRA) and Water Cycle Studies (WCS) for Brentwood are now out of date.

There have been a significant number of changes in relation to flood risk, including revised climate change allowances and updates to the surface water mapping since Brentwood last updated their SFRA. As a minimum ECC recommends the production of an addendum to the SFRA to consider the impact these changes would have on the proposed sites within the Draft Plan. This should be followed up by a more detailed review of the document that can be used as an additional assessment when dealing with development that is submitted outside the local plan processes. Similarly ECC recommends that a review of the WCS is undertaken to ensure that issues relating to water supply and demand as well as the processing of waste water are fully considered as part of the Local Plan process.

ECC advise that the Surface Water Management Plans (SWMPs) are being reviewed and an addendum to the SWMPs will be published shortly. The review of the SWMP has taken place following updates to the criteria used to assess properties at risk of flooding. Key changes to the SWMP include revised Critical Drainage Areas (CDAs) and some changes to flood extents.

An impact analysis of the proposed new CDA boundaries on the preferred site allocations proposed in the current consultation has been undertaken, which indicates that, of the 47 sites (housing and employment) 14 are not within a CDA, and 1 site is only within an old CDA. 14 sites are within both the old and new CDA's, and there are 18 of the sites which now fall within the new CDA's. Details are set out below:

* Childerditch Industrial Estate (ref. 112A) - Not In CDA
* William Hunter Way car park, Brentwood (ref. 102) - In New Only
* Land at Alexander Lane, Shenfield (ref. 87) - In Both
* Wates Way Industrial Estate, Ongar Road, Brentwood (ref. 3) - In New Only
* Horndon Industrial Estate, Station Road, West Horndon (ref. 21) - In Both
* Westbury Road Car Park, Westbury Road, Brentwood (ref. 39) - In New Only
* Chatham Way/Crown Street Car Park, Brentwood (ref. 40 ) - In New Only
* Land at Hunter House, Western Road, Brentwood (ref. 41) - In New Only
* Council Depot, The Drive, Warley (ref. 81) - In New Only
* Land west of Warley Hill, Pastoral Way, Warley (ref. 83) - In New Only
* Land adjacent to Tipps Cross Community Hall, Blackmore Road, Tipps Cross (ref.085B) - Not In CDA
* Brentwood railway station car park (ref. 2) - In Both
* Sow & Grow Nursery, Ongar Road, Pilgrims Hatch (ref. 10) - In New Only
* Land adjacent to Ingatestone by-pass (part bounded by Roman Road, south of flyover) (ref.079A) - In Both
* Land south of Redrose Lane, north of Woollard Way, Blackmore (ref. 77) - Not In CDA
* Land south of Redrose Lane, north of Orchard Piece, Blackmore (ref. 76) - Not In CDA
* West Horndon Industrial Estate, Childerditch Lane, West Horndon (ref. 20) - In Both
* Land at Honeypot Lane, Brentwood (ref. 22) - In New Only
* Land off Doddinghurst Road, either side of A12, Brentwood (ref. 023A) - In New Only
* Land east of Nags Head Lane, Brentwood (ref. 32) - In New Only
* Officer's Meadow, land off Alexander Lane, Shenfield (ref. 34) - In Both
* Land at Priests Lane (west), Brentwood (ref. 44) - In Both
* Land adjacent to Carmel, Mascalls Lane, Warley (ref. 27) - In New Only
* Land adjacent to Ingatestone by-pass (part bounded by Roman Road) (ref. 079C) - In Both
* Ingatestone Garden Centre, Roman Road, Ingatestone (ref. 128) - In New Only
* Land East of Horndon Industrial Estate (ref. 152) - In New Only
* Land North of A1023 Chelmsford Road, Shenfield (ref. 158) - In Both
* Land at Priests Lane (east) adjacent Bishops Walk, Brentwood (ref.178) - In Both
* Land at Crescent Drive, Brentwood (ref. 186) - In Both
* Land south of East Horndon Hall (ref. 187) - Not In CDA
* Childerditch Industrial Estate (ref. 112D) - Not In CDA
* Brizes Corner Field, Blackmore Road, Kelvedon Hatch (ref. 194) - Not In CDA
* Site adjacent to Ingatestone Garden Centre (former A12 works site) (ref. 106) - In New Only
* Land to the north of Alexander Lane, Shenfield (ref. 235) - In Both
* Land east of Chelmsford Road, Shenfield (ref. 263) - In Both
* Oak Hurst, Chelmsford Road, Shenfield (ref. 276) - In New Only
* Chestnut Field, Backmore Road, Hook End (ref. 294) - Not In CDA
* The Eagle and Child Public House, Chelmsford Road, Shenfield (ref. 311) - In Both
* Ford Warley - Northern Site (ref. 117B) - In New Only
* Ford Warley - Southern Site (ref. 117A) - Not In CDA
* Land off Stocks Lane, Kelvedon Hatch (ref. 075B) - Not In CDA
* Childerditch Industrial Estate (ref. 112E) - Not In CDA
* Brentwood Enterprise Park (M25 Works Site at A127/M25 junction 29) (ref. 101A) - Not In CDA
* Land off Doddinghurst Road, either side of A12, Brentwood (ref. 023B) - In New Only
* Codham Hall Farm (ref. 101C) - Not In CDA
* Codham Hall Farm (ref. 101D) - Not In CDA
* Dunton Hills Garden Village (ref. 200) - In Old Only

As a result ECC recommends that any changes arising from the SWMP review will need to be taken into account and inform the preparation of the pre-submission plan.

ECC recommends site specific policies relating to each of the sites that are now within CDA areas. Some suggested working is set out below:

The site is located within a Critical Drainage Area (CDA). This development may have the potential to impact on the CDA in respect of surface water flooding. As a result of this the site is likely to require an individually designed mitigation scheme to address this issue.

ECC advises that it is not clear whether the flood extents within the original SWMP documents have been used for determining surface water flood risk on the preferred site allocations or whether BBC have used the Environment Agency's Risk of Flooding from Surface Water Flood map. If the original SWMP extents have been used then further analysis will be necessary to understand the impact that this will have on the proposed housing and employment allocations.

ECC as Lead Local Flood Authority has provided comments throughout the Draft Local Plan process to ensure the delivery of Sustainable Drainage Systems to provide water quality, amenity and ecological benefits. ECC seeks further discussions with BBC to ensure its Local Plan policies comply with ECC requirements.

The adopted ECC Sustainable Urban Drainage Systems (SuDs) Design Guide should form part of the Plan making process, both in terms of policy formation and supporting evidence base work.

Delivery of proposed development -

Paragraph 162 of the NPPF states that LPAs should work with other authorities and providers to assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk, and its ability to meet forecast demands. An IDP will need to be prepared to support the BBC 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 it might be acceptable for less detail to be provided as the position regarding the provision of infrastructure is likely to be less certain. If it is known that a development is unlikely to come forward until after the Plan period due, for example, to uncertainty over deliverability of key infrastructure, then this should be clearly stated in the Draft Plan. As stated earlier, until appropriate work on infrastructure provision 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.

Alongside the provision of infrastructure such as improved roads and public transport and the provision of schools to support and accommodate future growth, ECC would strongly advise that the provision of flood and drainage infrastructure is included within the IDP. This would be to alleviate any existing drainage and flood risk concerns and accommodate and support future development. ECC would also strongly advise the inclusion of details on the costing of such infrastructure.

ECC recommend the inclusion of a specific overarching section 106 and CIL policy to ensure a consistent approach and framework for the delivery of relevant infrastructure from developers. This approach would bring together the individual policy requirements and support the provision of further supplementary planning documents and/or CIL Regulation 123 Charging Schedule.

The new policy should consider covering the following:
* Specify when developers are required to either make direct provision or to contribute towards development for the provision of local and strategic infrastructure required by the development (including land for new schools);
* Requirements for all new development to be supported by, and have good access to all necessary infrastructure;
* Requirement to demonstrate that there is or will be sufficient infrastructure capacity to support and meet all the necessary requirements arising from the proposed implications of a scheme (i.e. not just those on the site or its immediate vicinity) and regardless of whether the proposal is a local plan allocation or a windfall site;
* When conditions and/or planning obligations will be appropriate - as part of a package or combination of infrastructure delivery measures - likely to be required to ensure new developments meets this principle; and
* Consideration of likely timing of infrastructure provision - phased spatially or to ensure provision of infrastructure in a timely manner.

Recommended wording for an 'Infrastructure delivery and impact mitigation' policy is provided below.

Policy X: Infrastructure delivery and impact mitigation

Permission will only be granted if it can be demonstrated that there is sufficient appropriate infrastructure capacity to support the development or that such capacity will be delivered by the proposal. It must further be demonstrated that such capacity as is required will prove sustainable over time both in physical and financial terms.

Where a development proposal requires additional infrastructure capacity, to be deemed acceptable, mitigation measures must be agreed with the Council and the appropriate infrastructure provider Such measures may include (not exclusively):
* financial contributions towards new or expanded facilities and the maintenance thereof;
* on-site construction of new provision;
* off-site capacity improvement works; and/or
* the provision of land.

Developers and land owners must work positively with the Council, neighbouring authorities and other infrastructure providers throughout the planning process to ensure that the cumulative impact of development is considered and then mitigated, at the appropriate time, in line with their published policies and guidance.

The Council will consider introducing a Community Infrastructure Levy (CIL) and will implement such for areas and/or development types where a viable charging schedule would best mitigate the impacts of growth. Section 106 will remain the appropriate mechanism for securing land and works along with financial contributions where a sum for the necessary infrastructure is not secured via CIL.  
For the purposes of this policy the widest reasonable definition of infrastructure and infrastructure providers will be applied. Exemplar types of infrastructure are provided in the glossary appended to this plan.

Exceptions to this policy will only be considered where:
* it is proven that the benefit of the development proceeding without full mitigation outweighs the collective harm;
* a fully transparent open book viability assessment has proven that full mitigation cannot be afforded, allowing only for the minimum level of developer profit and land owner receipt necessary for the development to proceed;
* full and thorough investigation has been undertaken to find innovative solutions to issues and all possible steps have been taken to minimise the residual level of unmitigated impacts; and
* obligations are entered into by the developer that provide for appropriate additional mitigation in the event that viability improves prior to completion of the development.

EPOA is preparing a Viability Protocol by working with development interests to ensure the correct level of development related infrastructure is provided as well as a means to assist the LPAs unlock financial barriers that may hold up the development of housing.

Reference should also be made to the adopted ECC Developers' Guide to Infrastructure Contributions (2016), in relation to the level of contributions required from new development for the provision of essential infrastructure by ECC.

ECC would also recommend that there is a need to ensure that local facilities are in place to coincide with the completions of different phases of development. This will need to be progressed through the IDP to support the pre submission plan.

ECC recommends that BBC should seek to produce a Development Plan Document (DPD) to support the planning policy position for DHGV, and provide clarity of the deliverability of the allocation. This will ensure that the development can be delivered with the appropriate infrastructure and phasing. This is an approach that has been taken by the three North Essex LPA's in their part 1 Local Plans.

Employment Land - Need and Supply -

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 needs 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 supports the proposed strategy of providing a range of employment and business development, through new employment (B use) land and existing employment sites, and their redevelopment where appropriate. However ECC considers uses should not be restricted to B use classes on allocated employment sites, other sectors, such as retail, hotel and leisure also need be provided for. Furthermore consideration should be given to the need for providing businesses with sufficient flexibility for them to function which reflects requirements for 'Grow-On Space'. ECC welcome the opportunity to engage with BBC in considering which interventions are the most appropriate and viable to ensure the Draft Plan provides flexible local employment space (such as flexible tenure) to meet the employment and economic needs of the Borough.

ECC welcomes and supports the ambition for economic growth in Brentwood Borough, seeking to deliver the upper range of employment land requirements, and notes the additional evidence base produced since the Draft Local Plan (2016) consultation, including the Economic Futures 2013-2033 (November 2017), and the Brentwood Economic Strategy (2017-2020).

As ECC advised under the Spatial Strategy section of this Appendix, concerns are raised 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 Lower Thames Crossing major road scheme, which seeks to incorporate a significant part of the BEP employment allocation. Clarification is sought over the deliverability of the full allocation over the Plan period, particularly given the need for the site to come forward in 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. The potential impact on the above would also depend on the mix of B1, B2 and B8 uses proposed on the site.

Dunton Hills Garden Village (DHGV) -

ECC advise that if the DHGV allocation is being proposed as a 'Garden Village' it is recommended that the Garden City principles as outlined in the NPPF (paragraph 52) and the 2013 TCPA's publication "Creating garden cities and suburbs today" are incorporated into the Draft Plan policy to ensure delivery.

Paragraph 67 - This paragraph implies that, at some stage, the Dunton Hills Development is expected to increase from 2500 homes to 3500 homes. It will be important therefore in considering the initial design layout for this development to ensure that sufficient and appropriate access is provided for sustainable modes, to enable it to be served both in the initial and extended scenarios. This will likely mean safeguarding corridors for sustainable modes to traverse between the two phases. However paragraph 84 refers to pupil numbers based on the site accommodating 4000 dwellings as does the narrative for the site on P91.

Highways & Transportation Comment -
One of the constraints listed is the fact that car parking (station users) will need to be considered as part of redevelopment proposals. Reference should be made to other station users, such as pedestrians, cyclists and those who use public transport to access the site.
Development for this site needs to ensure that monies are secured to improve the sustainable transport facilities at the rail station including both layover bays and departure stands.