brentwood.gov.uk

I make the following representations in respect of the Focussed Change to R18 and the Addendum to the SA Report. My personal details are the same as the representations in March 2019 regarding the original iteration of Policy R18.
1. Focussed change reducing dwellings to "around 35 homes". This will keep an area of on site public open space. I consider that this change has not been positively prepared and not consistent with policies in the NPPF requiring an integrated approach to housing and community facilities. The woodland open space should be a priority and an opportunity to enhance a community asset in an area of open space deprivation is foregone.
2. The addendum of focussed change to Policy R18 is not effective and not justified.

Reasons:
(i) Paragraph 3 of the Focussed Changes Consultation states that a significant number of representations were received, and a summary of key concerns raised "include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitats impacts; and flooding."
(ii) No site appraisal justifying the proposed change appears to have been prepared. The character of the area was established by the Glanthams Park Estate Development scheme and layout with some statutory and charitable modifications before the redevelopment of the main hospital site in 2011 with the transfer of land for a public woodland opens space, and a footpath between the hospital and the Regional Blood Transfusion site (R18). In addition to the footpath the R18 site benefits from an easement for a right of way connecting to Worrin Road.
(iii) The proposed focussed change to R18 does not relate to the objectives of the Hospital redevelopment scheme and transfer of public woodland open space.
(iv) These objections are supported by a serious caveat in the Addendum to the SA Report prepared by AECOM Infrastructure, and a conclusion which is couched in evasive language.
(v) The Addendum is qualified by being in accordance with the established budget, and also states that information provided by third parties has not been checked. At paragraph 2.5.3 of the Addendum there is a caveat that costly "costly access and transport infrastructure upgrades will be required in order to ensure a good flow of traffic and support safe access by walking and cycling...... There is a need to question whether scheme viability could be adversely affected as a result in the reduction in the number of homes". In other words, the work has not been carried out to justify the soundness of the change
(vi) The conclusion to the Addendum at paragraph 2.5.6 is equivocal. It makes the highly dubious assertion that a response to (some but not all) concerns has positive implications for community objectives while highlighting an unquantified degree of uncertainty concerning infrastructure, including community infrastructure at DHGV.
(vii). It is open to the Council to make an order under the Highways Act creating a byway for all traffic over its easement. This would open up the public open space transferred in 2011, which has been the subject since then of encroachments and trespass. There are other options. However, the focussed change proposed seeks to take a line of minimum development with some onsite open space to avoid grasping the nettle of integrated planned development. This is unsound, unjustified and inimical to national planning policy objectives and not in the public interest.
Philip Cunliffe-Jones