Object

Preferred Site Allocations 2018

Representation ID: 18619

Received: 12/03/2018

Respondent: Mr Chris Puddefoot

Representation Summary:

SA Report is incomplete as not all the required evidence was completed at the time the assessment was completed. Therefore the SA can not be replied upon as evidence. It is unclear as to the criteria which has allowed Site 022 to be included in the plan given the score 8/17. Currently the Green Belt is uninterrupted from Brentwood Town Centre, and building on Site 022 would create a wedge which I believe would be unacceptable. Building on Green Belt to meet housing need is not considered very special circumstances as defined in the NPPF.

Full text:

I understand that any comments made in previous consultations will be carried forward to this current consultation. With regard to the latest documentation, the Interim SA Report of Jan 2018, I note that the criteria of the "Traffic light" system Appendix 3 has changed. More interestingly regarding Site 022 in 8 out of 17 of the current criteria the site "performs badly". Information is not provided regarding what would be required for the site to be deemed unsuitable for housing. At the last consultation I provided details of where the previous SA report was incorrect and Site 022 should have had a worse result than provided. It seems that part of this has been rectified by the Consultants specifying that distances for schools and GP surgeries are now provided by road, although they do not specify where they have made a starting point. As the site is over 10 hectares it seems to show a lack of detail. For example, it is now suggested that walking distance to a Primary school is between 800m and 1.5k, but I would suggest whatever starting point is used that distance is only feasible if using roads which have the national speed limit and no footpaths. If using roads with footpaths the minimum distance is 2.1k to St Peter's using the last house in Honeypot Lane as the starting point. It seems to me that there has not been any "local knowledge" applied by those who have prepared the SA. I have measured to St Peter's as it is the school which is allocated to Site 022 according to the documentation. I trust that the Consultants have not measured to Holly Trees Primary which has been allocated to several other sites, but not Site 022. In view of the above, and the errors which occurred in the previous SA, I find it difficult to believe that Appendix 3 of the SA would stand up to serious scrutiny, it is misleading and surely can only be used sparingly as evidence. One of the constraints mentioned is the proximity of the A12, but no comment has been made in the report that it is proposed to increase the A12 to three lanes which will add increased environmental factors on to Site 022. Currently the Green Belt is uninterrupted from Brentwood Town Centre, and building on Site 022 would create a wedge which I believe would be unacceptable. Within the National Planning Framework it implies that exceptional circumstances must exist to justify loss of Green Belt, and the Government has clarified that housing demand is unlikely to constitute exceptional circumstances. I would also highlight that although there have been several consultations and many questions which have been previously raised have not been answered. Very little evidence has been revealed as to why Site 022 was chosen, especially as it is Green Belt, other than the assumption that developers and their consultants have placed undue pressure on Brentwood Council, in the developers own financial interest. This aspect seems to be implied from the website of Chilmark Consulting. (link to on-line article provided). I also note that a C2 facility of 40 beds is now included for Site 022. What impact assessment has been made for this facility on this site, and additionally what effect will this have on the surrounding infrastructure?