Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 23163

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is unclear why the employment sites at Brentwood Enterprise Park (Site ref E11), Land at East Horndon Hall (site E13) and at Dunton Hills Garden Village (Site ref RO1) are proposed in the pre-submission Local Plan. It is not always the case that employment land should be located at busy junctions or along the A127 corridor where it would add to traffic flows on a road at current capacity. The sites are not located close to existing centres and are without easy access for workers other than by car. Alternative locations and options should be investigated including the A12 corridor possibly as part of edge of settlement expansion and in mixed use schemes; in principle objection due to Green Belt impact; impact of this combined with the Lower Thames Crossing.

Change suggested by respondent:

It is considered that site E11 should be deleted from the plan.

Notwithstanding our principle objection on greenbelt and sustainability issues if the site is proposed for development an alternative use that capitalize on its M25 location (i.e. a service station) could be considered.

It is considered the Brentwood Draft Local Plan and supporting evidence base will require further major revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Brentwood Local Plan should be reviewed to take account of the outcome of testing of other spatial options being considered including the evidence by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

Further work is required to develop the evidence base including the justification for the selection of the spatial options and dismissal of reasonable alternatives, housing capacity and supply further transport evidence and other infrastructure.

Due to the issues highlighted in this response and to the earlier documents it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production. It is recommended that the Brentwood Plan with its current spatial strategy and site allocations should not be submitted for Examination.

Full text:

The Brentwood Plan and supporting evidence identifies the requirement for additional employment land. However it is unclear why the employment sites at Brentwood Enterprise Park (Site ref E11), Land at East Horndon Hall (site E13) and at Dunton Hills Garden Village (Site ref RO1) are proposed in the pre-submission Local Plan. It is not always the case that employment land should be located at busy junctions or along the A127 corridor where it would add to traffic flows on a road at current capacity. The sites are not located close to existing centres and are without easy access for workers other than by car. Alternative locations and options should be investigated including the A12 corridor possibly as part of edge of settlement expansion and in mixed use schemes.

The A127/M25 Junction Enterprise Park (policy E11) is considered unsustainable and an inappropriate location for Brentwood's job growth. Notwithstanding our principle objection on greenbelt and sustainability issues if the site is proposed for development an alternative use that capitalize on its M25 location (i.e. a service station) could be considered.

However it is considered that development at this site would harm the openness of this part of the Green Belt and result in urban sprawl along the A127 by spreading the extent of built development further into the Green Belt. The form and scale of the site would also cause significant harm to the other purposes of the Green Belt and would result in major encroachment into the countryside whilst also causing harm to the purpose of preventing the merging of neighbouring towns. It is noted that the location scores overall a Moderate in terms of meeting the purposes of the Green Belt in the Brentwood draft Green Belt Review.

Any Green belt release here together with any Green Belt release east of the existing West Horndon urban boundary would also result in potential coalescence and urbanisation of the A127 corridor resulting in significant loss to the openness and strategic function of the Green Belt

It is unclear how access to this site will be achieved from junction 29 of the M25 under the latest option for the proposed Lower Thames Crossing.