Dear Sir or Madam
Brentwood Strategic Growth Options Consultation (January 2015)
Thank you for your letter dated 5 January consulting English Heritage on the
above document. We would like to make the following comments
Q1: Do you agree with the three broad areas for the purposes of
considering approaches to growth?
We do not have a strong view on the division of the borough into three broad
areas, which we recognise is to help consider growth options. As paragraph
2.13 notes, each of the areas should not be considered in isolation. In the
case of the historic environment, specific heritage assets might be shared
between more than one area (e.g. Thorndon Hall Registered Park and
Garden), and so could be impacted on by growth proposals in each area.
Q2: Do you agree with the issues raised for each of these three areas?
We broadly agree with the issues raised for each area in paragraphs 2.14 to
2.19. The historic environment forms an important part of the issues and
options for each area in terms of where to potentially locate new development.
This includes designated heritage assets but also non-designated assets such
as sites of archaeological interest. We would expect proper assessment of the
historic environment and potential impacts when making decisions about
where to locate development.

Q3: Do you have any comments on the appropriateness of particular
sites?
Due to time and resource constraints we have not been able to assess every
site in great detail. Our comments on the sites have been based mainly on
desk-top analysis, and we have not been able to judge the potential impacts
more accurately on the ground. Even with the strategic sites, we have only
been able to carry out rapid site visits in limited cases and have not had the
opportunity to ascertain precise impacts. We have focussed on those sites
with the potential for the greatest historic environment impact. This does not mean there are no issues with any other site and we reserve the right to
comment further on any site as and when proposals develop.
Please note that we have not considered areas of archaeological interest
beyond scheduled monuments in most cases, nor have we looked at historic
landscape issues beyond registered historic parks & gardens. However,
wider archaeological and landscape impacts are important considerations and
need to be factored into site assessment. The possible cumulative impact of
a number of site allocations in one location could cause significant harm to the
historic environment. Advice from conservation and archaeological staff at
borough and county levels should be sought, along with consultation of the
County Historic Environment Record (HER) for specific heritage assets.
In terms of site assessments in relation to heritage assets, care should be
taken to avoid merely limiting assessment of impact on a heritage asset to its
distance from, or intervisibility with, a potential site. Site allocations which
include a heritage asset (for example a site within a Conservation Area) may
offer opportunities for enhancement and tackling heritage at risk, while
conversely, an allocation at a considerable distance away from a heritage
asset may cause harm to its significance, rendering the site unsuitable.
The following broad steps might be of assistance in terms of assessing sites:
* Identify the heritage assets on or within the vicinity of the potential site
allocation at an appropriate scale
* Assess the contribution of the site to the significance of heritage assets
on or within its vicinity
* Identify the potential impacts of development upon the significance of
heritage asset
* Consider how any harm might be removed or reduced, including
reasonable alternatives sites * Consider how any enhancements could be achieved and maximised
* Consider and set out the public benefits where harm cannot be
removed or reduced
Q4: Which of the sites along the A127 Corridor is the best location for
growth?
The document notes the potential for larger growth opportunities in the A127
corridor, with a residential-led mixed used allocation at West Horndon or a
cross boundary development at Dunton (English Heritage has responded
separately to the Dunton Garden Suburb consultation). The consultation
suggests that development would only occur at either West Horndon or
Dunton, but in the event that both are pursued, we would have reservations
about the cumulative impact and extent of urbanisation along the A127
corridor, which could harm various heritage assets. We would expect in such
a scenario for an adequate buffer between West Horndon and Dunton and
important heritage assets.
Within West Horndon site 038B includes the southern limits of the Thorndon
Hall Registered Park and Garden (Grade II* listed) and Thorndon Park
Conservation Area. This southerly projection is separated from the main Park
and Garden and conservation area by the A127, but the issue of severance must have been considered at the time of designation (in 1987 and 1993
respectively). Housing development on the designated area would result in
harm to its character and appearance, and development abutting its
boundaries might also result in a degree of harm.
On site 162 at Little Warley there is a proposal for an elderly care facility. This
site abuts Little Warely Hall, which dates from the early 16th century and is
listed at Grade II*, together with the Church of St Peter, which dates from the
15th and 17th centuries and is listed at Grade I. Development of an elderly
care facility on this site is likely to adversely impact on the setting of both
these highly graded heritage assets. Sites 058A and 058B on the east side of
Little Warely Hall Lane are also in close proximity to these assets, but well
designed and appropriately scaled housing may be less harmful compared to
the current recycling and HGV operations on site 058A.
Q5: Should the A12 Corridor accommodate growth by releasing sites on
the edge of urban areas?
The report notes that brownfield land within the urban areas might be
efficiently developed in order to minimise pressure on Green Belt releases.
English Heritage broadly agrees with this approach, though we note that a
number of brownfield sites are in close proximity to designated heritage
assets and the design of any developments would need to have special
regard to the setting of these assets.
In terms of releasing sites on the edge of urban areas, this again depends on
the exact location in terms of impact on the historic environment. Very
significant areas of green belt land to the east and southeast of Hutton/east of
Ingrave and Herongate is included in the report and much of this land has
implications for a large number of heritage assets. The Sustainability
Appraisal seems to underplay the impact of this location on the historic
environment, ranking it third out of five potential options for strategic growth.
We would argue that it ranks lower than that. On the extreme eastern edge of Hutton is the Hutton village conservation
area. This conservation area has an open rural setting apart from where it
abuts existing housing on the northern half of its western boundary, and
includes Hutton Hall (Grade II* listed) and the 14th century Church of All Saints
(Grade II* listed) plus a number of other buildings listed at Grade II. The
conservation area also includes areas of open land that make a positive
contribution to its character and appearance. Development sites 033, 211
and 219 all lie within the conservation area and English Heritage cannot see
how they could come forward for development without resulting in significant
harm to the character or appearance of the conservation area, as well as
adversely impacting on the setting of some of listed buildings. Sites 008,
008B and 008C are all likely to adversely impact on wider setting of the
conservation area and the more immediate setting of Hutton House, along
with its walled garden and stables (all listed at Grade II). Site 028C is a large
site that abuts the south east and southwest boundaries of the conservation
area, where development is likely to result in harm to the rural character and
appearance of the conservation area and would also have the potential to
adversely impact on the setting of the Church of All Saints and Hutton Hall (both Grade II* listed). The western boundary of Site 028C also abuts the
boundary of Heatleys, a 16th century Grade II house, and development in this
area would have implications for the setting of this house.
Sites 028A and 028B abut the southeast built edge of Hutton. Development
in this area would have implications for the setting of a number of listed
buildings including Hare Hall (Grade II listed) Heatleys (Grade II) listed and
Kennel House (Grade II listed). It may also have implications for the wider
setting of the Thorndon Park Conservation Area and Thorndon Hall
Registered Park and Garden (Grade II*), as well as longer views out from
Thorndon Hall (Grade I listed).
Site 192 is another large site which adjoins the south of site 028C and is
located to the east of Ingrave and Herongate. This site completely enclosed a
scheduled moated site at Heron Hall, together with the 17th century Grade II
listed Hall and stables and the Grade II* listed granary. This complex of
heritage assets currently enjoys a remote rural setting, and historically the
medieval house sited within the moat would have commanded all this
surrounding land. Development of the land around these heritage assets
would therefore result in significant change to their setting and harm to their
significance.
Site 212 is located to the southwest of the Great Warley conservation area
and, while this site is unlikely to have an impact on the conservation area, it
has the potential to adversely impact on the setting of the Thatched Cottage
and The Squirrels (both dating from the 19th century and listed at Grade II).
This site currently comprises Coombe Wood, which would appear to be of
some landscape and ecological value. Northwest of Great Warley is site 167.
Again this site is sufficiently remote from the conservation area and
Registered Park and Garden, but abuts the northern boundary of Hill Cottage
(Grade II listed) and is in relatively close proximity to Great Ropers, an 18th
century house listed at Grade II*.
Site 218 on the edge of Shenfield lies close to a cluster of listed buildings at
Shenfield Hall, including the Grade II hall and Grade II* Church of St Mary.
There should be assessment of potential impacts. Q6: In the North of the Borough, is it preferable to release greenfield or
brownfield sites?
As noted in the document, the North of the Borough is made up of a collection
of villages set amidst attractive landscape (although it is wrong to simply
consider the landscape as 'natural', as it will contain many historic elements).
In terms of specific sites:
Blackmore
The village includes a designated conservation area that contains a number of
listed buildings forming this historic core of the settlement and some open
land of historic interest that also makes a positive contribution to the character
and appearance of the conservation area. Site 052 is located in the conservation area on land to the rear of Little
Jericho. Little Jericho is a grade II listed house dating from c1600 and the
vacant barn/farm buildings to its rear may be curtilage listed. They may also
make a positive contribution to the character and appearance of the
conservation area. Whilst a scheme for the careful adaptation of the farm
buildings into residential use may be acceptable, their demolition and
wholesale redevelopment of the site could well result in harm to the historic
environment.
Site 202 is located immediately adjacent to the western boundary of the
conservation area and the loss of open rural views out of the conservation
area (especially from the path that defines this boundary of the conservation
area) is likely to be harmful to the character and appearance of the
conservation area. Site 199 is to the northeast of the conservation area and
would be less likely to impact on its setting, especially if the southern edge of
the development was given a soft and green boundary.
Sites 076 and 077 are both further away from the conservation area, but both
have Grade II listed buildings in close proximity, and development could
adversely impact on the setting of these listed buildings. It might be possible
to bring forward development on both sites that successfully addresses the
issue of setting for these listed building, but it would be necessary to first
understand how setting contributes to their significance.
Hook End
While there is not conservation area in Hook End, there are a number of
Grade II listed buildings that might be affected by development proposals. A
number of these listed buildings are farmhouses that would historically have
been linked to the adjacent open farmland. Loss of this open farmland could
therefore impact on their signficance. In particular site 174 is immediately to
the west of a collection of three Grade II buildings comprising Hook End
Poultry Farmhouse, brewhouse and barn, while Site 183 is to the south west
of Barfield Farmhouse and south east of Deal Tree Farmhouse. Other sites
that may have implications for the setting of designated heritage assets
include 209 (impacting on the Soap House, Grade II), 056A & 056B
(impacting on The Cottage, Grade II) and 196 (impacting on a cluster of
Grade II listed assets comprising a pump, cartlodge, granary and Wyatts
Farmhouse). Thoby Priory
Site 018 incorporates the ruins of Thoby Priory, which is a Scheduled
Monument and listed Grade II. The priory ruins are also on the English
Heritage 'at risk' list. The priory would have been sited in a remote location
suitably for the contemplative life, but that setting has been compromised in
recent years. English Heritage accepts that a development with housing
located to the west and north of the designated assets, whilst retaining an
open aspect to the south and east, could be acceptable, especially if it also
provided for the improved management of the heritage assets.
Kelvedon Hatch A number of possible sites are identified around the periphery of Kelvedon
Hatch. Those on the east side of the settlement have minimal implications for
the historic environment. There are a number of designated heritage assets
(both listed and scheduled) on the west side of the settlement, but most of
these are to the west of A128 and are therefore likely to be adequately
buffered from developments on sites 217 and 194, which are located on the
east side of the A road. There is a smaller site at 074 which may have
implications for the setting of St Nicholas's Church (Grade II). This church is
currently sited on the edge of the settlement and enclosing its open aspect to
the south might result in a degree of harm.
Q7: Do you agree that the most sustainable approach to employment
need is to allocation new sites close to the strategic highway network?
The map on page 22 of the document identifies a number of potential
employment sites. These sites are generally located in close proximity to
existing transport corridors and/or adjacent to current employment sites, and
the majority will have little adverse impact on designated heritage assets. The
exceptions are sites 109 and 187, which are adjacent to East Hordon Hall
(16th and 18th century and Grade II listed). While the setting of the Hall has
already been compromised by the A127 (which passes immediately to the
north) and the existing employment land to the east of the Hall, further
employment buildings in close proximity would exacerbate the existing harm.
Q8: Do you agree that a town centre first approach should be taken to
retail development?
We broadly agree with this approach as it is should help to maintain the vitality
of town centres which in turn can benefit heritage assets within these
locations. It will depend on specific proposals and their impact, but there are
opportunities in places like Brentwood Town Centre to secure enhancements.
In terms of retail site options for Brentwood Town Centre, our 2013 comments
have highlighted specific heritage assets for some of the sites shown in this
consultation. In many respects, Site 100 (Baytree Centre) is the most
important in terms of opportunities to enhance the historic environment, given
its access off the High Street from within the conservation area, and the
proximity of several listed buildings plus a scheduled monument (the chapel).
We would welcome further discussions regarding this site.
Q9: No comments
Q10: Landscape value
Section 5 of this consultation puts heritage into a separate category detached
from other environmental considerations, rather than include it as part of the
overall environmental picture. Figure 15 should include designated heritage
assets, particularly conservation areas, scheduled monuments and registered
parks and gardens. We note the intention to produce further assessment of
landscape capacity surrounding urban areas in paragraph 5.6. We strongly
recommend that this assessment includes the historic environment as a key
component of landscape capacity. Our comments on specific sites reveal the
extent of heritage assets surrounding the urban areas, and this should be
considered in any decisions on suitable sites. The Local Plan evidence base does not appear to contain any specific references to the historic environment,
and we recommend this is addressed.
Q11: No comments
Q12: Infrastructure Issues
The provision of new or improved infrastructure such as transport can have
implications for the historic environment in terms of impact on specific heritage
assets. The Infrastructure Delivery Plan and related work should consider
such issues. In addition, the historic environment can form part of different
types of infrastructure, from community facilities to historic transport
structures. It also contributes to green infrastructure, which is more than just
the natural environment. Publicly accessible parks and gardens,
archaeological sites and spaces within conservation areas and listed buildings
can all form part of existing and proposed green infrastructure networks, with
opportunities to conserve and enhance such elements.
Q13: No comments
We hope that the above comments are of assistance. If you have any queries
or would like to discuss specific points, please do not hesitate to contact me.

I wish to register my objections to any proposed housing or commercial/industrial development at the following locations in the Strategic Growth Options consultation document:
Woodlands School Warley Street (ref 016A and 016B)
Land fronting at Warley Street - Dickinsons Farm (ref 082)
Land at Warley Road adj Hill Cottage (ref 167)
Coombe Woods Beredens Lane (ref 212)
Chep Pallets (Peri site) Warley Street (ref 228)
Land adjacent Carmel, Mascalls Lane (ref 027)

see attached

The proposed Strategic Growth Local Plan was discussed in full at a recent meeting of the committee of the Great Warley Conservation Society. The following decisions were reached:

1. The purpose of our Society, which has been active since 1972, is to help the residents of Great Warley to protect the Green Belt and the open environment of our village. We therefore vigorously object to the sites listed below, which have been put forward for future development.

2. It is our opinion that building on these sites would be both visually poor for the approaches to the villages and to Brentwood town, and also remote and lacking in the services and facilities which are required for substantial development.

3. It is fully appreciated that any future development will still require detailed planning permission. However, future planners at Brentwood Council would be in a very difficult position when considering applications if these sites have already been allocated for development in the Local Plan.

The following suggested sites are of most concern to the Conservation Society:

a) Coombe Woods, Beredens Lane, No. 212. This is a woodland area of special natural landscape interest. Building here would involve losing a large number of trees, plants and wildlife, as well as detrimentally affecting the vistas of the periphery of Brentwood. This would have a negative impact on the quality of life.

b) Land adjacent to Hill Cottage, Warley Road, No. 167, and extending down to Mascalls Lane to Mill House, and

c) Land adjoining Carmel, Mascalls Lane, No.027

Both of these sites, as well as being in the Green Belt, provide a pleasing outlook on the edge of existing buildings. The inevitable resultant requirements for amendments to the road layouts would further urbanise one of the few remaining landscapes which make Brentwood so appealing.

d) Woodlands School, Warley Street, No. 16 A and B and

e) Land at Dickensons Farm fronting Warley Street, No. 082.

Both of these sites are too remote from any reasonable transport links and other facilities, and housing construction is incompatible with the surrounding Green Belt area.

We therefore wish to register our formal objection to these sites being included in the proposed Strategic Growth Options Plan.

I am writing to you with regard to your strategic growth options consultation.
As you can see I live in Harold Park which borders Brentwood and I do all my shopping etc in the Brentwood area and spend a good deal of time there. I very much enjoy travelling to Brentwood usually on public transport, and seeing the countryside and areas of green belt which surrounds both Harold Park and Brentwood. This is one of Brentwood's greatest assets, it is what draws people to live here and makes it a pleasant place to live. As such I was extremely upset to think that you would consider building on the green belt. Even this week the Standard newspaper quoted Thurrock and Epping Forest as the two top places that people wish to live in and gave the reason as "because it is surrounded by green belt land" (See Evening Standard Tuesday 3 February 2015, page 13). I believe this emphasises how important green belt land is and why it should not be built upon.

I list my reasons and comments below:
* Your document does not seem to have been approached on a sensible and even basis. Especially concerning the bias running through the document leading towards development to the south of the Borough. For example, the obvious and severe traffic existing problems on the A127 are not stated in the discussion, with development being seen as a possible solution to an inferred need, (3.12) whereas such growth in the A12 corridor 'could have similar negative impacts on infrastructure and services' (3.13) and in the even more so in (2.10) where development in the Brentwood urban area and north of the Borough creates problems whereas in the A127 corridor and West Horndon development "creates opportunities" according to your document.

* For the reason states above the consultation is not objective in terms of presentation and environmental and financial cost.

Q1: Do you agree with the three broad areas, for the purpose of considering approaches to growth?

No for the following reasons:

It is arguable whether the Borough needs subdividing at all for growth purposes.
In the absence of evidence relating to transport it is far from certain that this is the key matter to base decisions upon.

Even in the most rural parts of the Borough transport is not particularly poor compared with many parts of Essex let alone the country.

The subdivision is based ostensibly on transport but the north / middle / south land subdivisions is just too coarse a reflection of transport availability, this being predominantly linear in nature.

Even accepting transport led subdivisions in principle, this quickly needs to be refined by considering the questions of available capacity and financial and environmental cost to upgrade to accommodate growth. Without these considerations the basis of the study is unsupported.

Q2: Do you agree with the issues raised for each of these three areas?

Partially although the brief analysis 2.14 - 2.19 should be consistent. 2.19 is particularly biased whereby it makes an unsupported link between the character and availability of land for growth being potentially greater (surely this is the ultimate conclusion of considering all aspects of land use) and that the A127 has more scope for improvements than the A12 (and I would add, the A128, B roads and local road network).

To reiterate the point under Q1 if transport really is the key issue then a link is required between problems and solutions before judgements can be suggested.
Issues for the three areas should also concentrate on environmental impacts of the various options.

Q3: Do you have any comments on the appropriateness of particular sites?
I believe it is totally inappropriate to use Green Belt land for such purposes. I agree with the aim to maximise the use of brownfield areas both within urban and rural localities.

Even taking this into account should additional sites be required these should generally be of an infill nature or otherwise to create compact communities. This should apply to both urban and rural areas in order to create built up areas that minimise impact on landscape and facilitate the creation of a focus. The extent to which this principle should be applied would be based on minimising impact vs growth.

In terms of the sites illustrated:

3.12 - The completely new town 'Dunton Garden Suburb' would in my view have disproportionate impacts on the Green Belt in addition to creating a new urban centre which I feel would be detrimental to Brentwood Town centre and the road network. In addition the growth suggested for West Horndon is clearly disproportionate to the suggested aims above. Some smaller growth to West Horndon though could be accommodated whilst keeping the existing community compact and focused.

3.13 - In general both these option should be pursued within the aims I mention above. I would oppose the large scale areas shown south east of Hutton as per my comments on the 'Dunton Garden Suburb'. Further linear expansion at Brook Street termed 'Development options at M25' are also highly detrimental to the Green Belt by eroding this already narrow strip between Brentwood and the edge of the Green Belt in Havering, and that at Coombe Woods, Bereden Lane would be a planning travesty. Some smaller growth opportunities to Pilgrims Hatch, Shenfield and Honeypot Lane would perhaps have the least affect on the Green Belt and be close enough to existing built up areas to keep the built up area as compact as possible and focus activity towards existing urban centres. Small extensions to Mountnessing and Ingatestone that are within the confines of the existing road / rail corridor could also be considered.

The idea of an additional junction with the A12 to intercept the A128 is so obvious that I'm surprised that this wasn't incorporated back in the 1960s. It is this sort of link to the interrelationship between growth and transport that I was referring above although in this case it would have a significant added benefit to the community rather than just accommodating additional pressure created by growth.

3.14 - Isolated sites should not in general be considered for housing development such as Clapgate Estate and Thoby Priory. Some smaller growth to each of the main communities shown on the plan (except Navestock) could be accommodated whilst keeping the existing community compact and focused.

Q4: Given the greater capacity for growth along the A127 Corridor, which of the sites put forward do you think is the best location for growth?

This is a strange leading statement as the assumption regarding greater capacity for growth along the A127 Corridor remains undemonstrated. On the face of it the same phrase could be used to open a question about any other part of the Borough. For example, if necessary local road improvements could be considered for the area of the 'five villages' in the northern subdivision.

As discussed above in relation to the A127 Corridor limited growth at West Horndon is the only reasonable option for this sub area.

Q5: Should the A12 Corridor accommodate growth by releasing sites in the edge of urban area?

I assume that this is referring to Green Belt land and therefore my answer is no.

Q6: In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt)?

It is in general much more preferable for brownfield sites to be developed over greenfield sites however the impacts and implications of this do need to be taken into consideration. In some cases brownfield sites are best left in employment use and / or are not in a town or village context and in such cases creation of new housing in the countryside should be avoided.

Q7: To enable future employment need to be met do you agree that the most sustainable approach is to allocate new sites close to the strategic highway Network?

I think the link between employment use and the strategic highway network is likely to be sweeping and in cases the opposite is true.

I also believe that we should be looking at sustainable transport such as the railways and not adding to road traffic and pollution.

I would say that future employment need should be met by considering the full range of planning matters including impacts on the landscape and the green environment.

Q8: In order to ensure that the Town Centre remains economically sustainable, do you agree that a "Town Centre First" approach should be taken to retail development?

Definitely. Retail lends itself well to densification of existing land use and I do not feel that release of any green belt land should be necessary to accommodate such growth.

Q9: Are there opportunities for more open space provision in the area where you live?

Not so much provision of open space as the need for better recreational linkages between open spaces.

It would be helpful if the Council were more proactive in terms of the environment and, for example, provided public transport to the parks such as South Weald and Thorndon, or at least provide free parking for the first 2 hours. It is important to replace trees on the edge of roads etc to keep Brentwood feeling rural and not urban. To this end it is important to avoid advertising creep on business premises. I think it is important to not have neon signs for e.g. the Holiday Inn and other businesses. It is important not to allow planning creep, a poor example of this and one which the Council could have prevented is the large Sainsbury store which when it was first built was built away from the main road in quite a laid back position with trees and landscaping. Not long after it was allowed to build the monstrous car park which as well as being an eye sore has meant those arriving on foot have to walk much further to get to the entrance.
The A127 represents a severe block to north - south recreational routes. Effectively there is no sympathetic crossing for the 6.5km from Great Warley Road to Dunton outside of the Borough. This is very regrettable matter as it limits the value of Thorndon Park to residents of West Horndon and any recreational users coming from the south to the Park.

Q10: Please rate the level to which you value the landscape near where you live. (see page 29)

In Harold Park and living very near to the borders of Brentwood the following areas are very important to me.

Being able to see the countryside and not feeling like I live in a town, being able to see wildlife, the need for woods and trees to provide oxygen, to counteract pollution and to act as a sound barrier to prevent noise from the road and the railway. I would therefore rank the following as of equal importance.

Scenic Beauty / Outdoor Recreation / Wildlife interest / Historical interest / Tranquillity

Other - a key aspect omitted is views. As mentioned in my first paragraph it is very important to me to be able to see green fields, deer roaming, etc and I think that Brentwood Council should be doing more to prevent the urbanisation of the area. For example limit the advertising signage and changes which are more in link with an urban area than a semi rural one.

Q11: To what extent do you think the following is present in the landscape near where you live?

Houses - all the houses are in tree lined roads and surrounded by gardens and the estates are green with fields all around.

Commercial buildings - there are very few apart from a small number of local retail.

Nature Reserves - I can get to Thames Chase / South Weald / Thorndon Park in a matter of minutes.

Farmland - several farms although Oak Farm has never been seen as a proper farm.

Woodland - Many woods which act as a sound barrier, provide oxygen and look pleasant

Wasteland - none

Infrastructure - A12, A127, M25 nearby but not so near as to disturb the peace, railway nearby Leisure Facilities - sufficient, especially as I enjoy walking and cycling and there is a cycle path and several areas to walk in without needing a car.

Q12: Have we considered the main infrastructure issues? Are there other important issues to consider?

I do not believe that green belt should be built on at all. Instead the borough should be not allowing the building of large accommodation, for example most recent estates are for 3 or 4 bedroom detached houses where there is clearly a need for 1, 2 and 3 bedroom houses to meet the need especially factoring in the change in families, more single people etc.

Q13: What do you think the priorities for infrastructure spending should be?

This requires a study in itself and I note that this is being looked into (6.3). As stated throughout this response though I feel that Strategic Growth options need to come out of the conclusions from the infrastructure study (and studies into other such high level matters) rather than being in a response to a more arbitrarily suggested steer.

As discussed above I believe there are many opportunities for the council to be more pro-active in terms of infrastructure and caring about the environment and restoring and maintaining a sense of community. For example, including sustainable transport in any plans concerning infrastructure, for example, sensible and safe cycle lanes which don't encroach on the pavement. Free parking and transport to local parks. Maintenance of footpaths and public bridleways to encourage people to make use of the fields around. Support for local shops and local post offices. Encouragement for people to shop locally, for shops to sell local produce. Subsidies for milkmen, paper deliveries etc so that the elderly and vulnerable are included in any plans. Creating a community whereby the elderly and vulnerable are not isolated, for example encouraging businesses, banks and libraries to use people and not replace people with systems, e.g. banks in Brentwood high street, Brentwood library etc. This also has the added benefit of creating employment.

I look forward to hearing from you regarding the above in due course.

I write in respect of your Strategic Growth Options Consultation

A general comment is that the document needs to be much more evidence based an even handed. There is a bias running through the document resulting in a leading towards development the south of the Borough. I cannot cite all of these, but as examples:

The obvious and severe traffic existing problems on the A127 are not states in the discussion, with development being seen as a possible solution to an inferred need, (3.12) whereas such growth in the A12 corridor 'could have similar negative impacts on infrastructure and services' (3.13) and in the even more so in (2.10) where development in the Brentwood urban area and north of the Borough creates problems whereas in the A127 corridor and West Horndon development creates opportunities.

To prevent such a bias developing the whole consultation needs to be supported by an objective presentation of localities under 'stress' and the costs (both financial and environmental) to deal with these.

Q1: Do you agree with the three broad areas, for the purpose of considering approaches to growth?

No for the following reasons:

It is arguable whether the Borough needs subdividing at all for growth purposes and the approach to growth needs to be based primarily around Green Belt considerations. I believe that to accommodate growth all steps possible should be taken to limit the release of Green Belt and that this course of action should only be followed in extenuating circumstances where there is no other realistic possibility.

Other models for growth should be considered and I believe that to accommodate growth all steps should be taken to minimize the release of Green Belt. Means of doing this include:

* Maximising the use of derelict or underused urban space;
* Increasing densities within already built up areas;
* Developing brownfield areas both within urban and rural localities

Should any release of Greenfield land be absolutely essential these should be considered through
* Release of infill sites
* Release of many smaller sites on the edge of urban areas
* Application of suitably high densities to any greenfield land released.

Further comments on the broad divisions are:

In the absence of evidence relating to transport I think it unlikely that this is the only or most important matter on which to base decisions. Even in the most rural parts of the Borough transport is not particularly poor compared with many parts of Essex let alone the country. The subdivision is based ostensibly on transport but the north / middle / south land subdivisions is just too coarse a reflection of transport availability, this being predominantly linear in nature.

Even accepting transport led subdivisions in principle, this quickly needs to be refined by considering the questions of available capacity and financial and environmental cost to upgrade to accommodate growth. Without these considerations the basis of the study is unsupported.

Q2: Do you agree with the issues raised for each of these three areas?

Partially although the brief analysis 2.14 - 2.19 should be consistent. 2.19 is particularly biased whereby it makes an unsupported link between the character and availability of land for growth being potentially greater (surely this is the ultimate conclusion of considering all aspects of land use) and that the A127 has more scope for improvements than the A12 (and I would add, the A128, B roads and local road network).

To reiterate the point under Q1 if transport really is the key issue then a link is required between problems and solutions before judgements can be suggested.
Issues for the three areas should also concentrate on environmental impacts of the various options.

Q3: Do you have any comments on the appropriateness of particular sites?

I believe that principles regarding the release of Green Belt should be foremost and in principle all steps should be taken to minimize such release. I agree with the aim to maximize the use of brownfield areas both within urban and rural localities. I also feel that release of Green Belt could be further minimized by appropriately increasing the density of existing settlements.

Even taking this into account should additional sites be required these should generally be of an infill nature or otherwise to create compact communities. This should apply to both urban and rural areas in order to create built up areas that minimise impact on landscape and facilitate the creation of a focus. The extent to which this principle should be applied would be based on minimising impact vs growth.

In terms of the sites illustrated:

3.12 - The completely new town 'Dunton Garden Suburb' would in my view have disproportionate impacts on the Green Belt in addition to creating a new urban centre which I feel would be detrimental to Brentwood Town centre and the road network. In addition the growth suggested for West Horndon is clearly disproportionate to the suggested aims above. Some smaller growth to West Horndon though could be accommodated whilst keeping the existing community compact and focused.

3.13 - In general both these option should be pursued within the aims I mention above. I would oppose the large scale areas shown south east of Hutton as per my comments on the 'Dunton Garden Suburb'. Further linear expansion at Brook Street termed 'Development options at M25' are also highly detrimental to the Green Belt by eroding this already narrow strip between Brentwood and the edge of the Green Belt in Havering, and that at Coombe Woods, Bereden Lane would be a planning travesty. Some smaller growth opportunities to Pilgrims Hatch, Shenfield and Honeypot Lane would perhaps have the least affect on the Green Belt and be close enough to existing built up areas to keep the built up area as compact as possible and focus activity towards existing urban centres. Small extensions to Mountnessing and Ingatestone that are within the confines of the existing road / rail corridor could also be considered.

The idea of an additional junction with the A12 to intercept the A128 is so obvious that I'm surprised that this wasn't incorporated back in the 1960s. It is this sort of link to the interrelationship between growth and transport that I was referring above although in this case it would have a significant added benefit to the community rather than just accommodating additional pressure created by growth.

3.14 - Isolated sites should not in general be considered for housing development such as Clapgate Estate and Thoby Priory. Some smaller growth to each of the main communities shown on the plan (except Navestock) could be accommodated whilst keeping the existing community compact and focused.

Q4: Given the greater capacity for growth along the A127 Corridor, which of the sites put forward do you think is the best location for growth?

This is a strange leading statement as the assumption regarding greater capacity for growth along the A127 Corridor remains undemonstrated. On the face of it the same phrase could be used to open a question about any other part of the Borough. For example, if necessary local road improvements could be considered for the area of the 'five villages' in the northern subdivision.
As discussed above in relation to the A127 Corridor limited growth at West Horndon is the only reasonable option for this sub area.

Q5: Should the A12 Corridor accommodate growth by releasing sites in the edge of urban area?

The same general comment applies in that if so this needs to be based on environmental impacts in addition to a more thorough examination of local constraints and the costs / benefits of satisfactorily resolving these. On the face of it though the five main urban area in this subdivision are likely to offer the most from release of Greenfield land because there is

* A greater perimeter to the built up area and urban and semi urban landscape
* A number of existing town facilities
* A closer proximity of brownfield land and areas requiring regeneration in these areas
* A greater choice that investment from growth will go into Brentwood Borough
* In addition transport links this broad area are good

Q6: In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt)?

It is in general much more preferable for brownfield sites to be developed over greenfield sites however the impacts and implications of this do need to be taken into consideration. In some cases brownfield sites are best left in employment use and / or are not in a town or village context and in such cases creation of new housing in the countryside should be avoided.

Q7: To enable future employment need to be met do you agree that the most sustainable approach is to allocate new sites close to the strategic highway Network?

I think the link between employment use and the strategic highway network is likely to be sweeping and in cases the opposite is true. Certain employment uses can be advantageous in creating a positive mixture of land uses and communities. However as stated in the text some employment uses create a number of adverse impacts on communities. I do not think good strategic highway network per se is so important for many employment uses nor for modern business needs' however it may be that such a pattern develops by consequence of considering other aspects of planning. I would say that future employment need should be met by considering the full range of planning matters including impacts on the landscape and the green environment.

Q8: In order to ensure that the Town Centre remains economically sustainable, do you agree that a "Town Centre First" approach should be taken to retail development?

Definitely. Retail lends itself well to densification of existing land use and I do not feel that release of any green belt land should be necessary to accommodate such growth.

Q9: Are there opportunities for more open space provision in the area where you live?

Not so much provision of open space as the need for better recreational linkages between open spaces.

It would be helpful if the Council were more proactive in terms of the environment and, for example, provided public transport to the parks such as South Weald and Thorndon, or at least provide free parking for the first 2 hours. It is important to replace trees on the edge of roads etc to keep Brentwood feeling rural and not urban. To this end it is important to avoid advertising creep on business premises. I think it is important to not have neon signs for e.g. the Holiday Inn and other businesses.

The A127 represents a severe block to north - south recreational routes. Effectively there is no sympathetic crossing for the 6.5km from Great Warley Road to Dunton outside of the Borough. This is very regrettable matter as it limits the value of Thorndon Park to residents of West Horndon and any recreational users coming from the south to the Park.

Q10: Please rate the level to which you value the landscape near where you live. (see page 29)

Q11: To what extent do you think the following is present in the landscape near where you live?

I think it misleading to ask for a comparison between other areas in Brentwood Borough in Q10. The real aim should be to discover what impacts release of any Greenfield land would have. Intrinsic value of the landscape being considered for development is one of these, but the impacts would be a combination of both the nature of the proposed developments (including indirect effects) and aspects related to wider values relating to those areas impacted. The first part needs at least some definition. The second part needs to be judged not just on the parameters listed but also on other factors such as:

Views - this being more about the vistas that can be gained of and from the area under consideration.
Value in providing 'green lungs' to surrounding developed areas
Value in providing green continuity for the purposes of nature conservation recreation
Ability to be viewed and used

To take an example, an urban park may score v low on most of the aspects of question 10 but would suggest that the impacts of developing this space could be huge. My views on impact on landscape are largely answered under question 3.

Q12: Have we considered the main infrastructure issues? Are there other important issues to consider?

I'm not sure that green infrastructure covers the point I wish to make as green infrastructure sounds like a local provision to create a desirable community. The main issues for me surrounds the pattern of any release of Green Belt land to accommodate growth. I firmly believe that even if growth on one or two large scale land releases could be accommodated this model would seriously make Brentwood a poorer Borough compared with a more dispersed growth model. This is because the 'pain' of smaller Green Belt losses can be more easily absorbed and the gain more directly and perhaps fairly directed to the relevant community. With a few large scale developments the 'pain' of growth simply has to be swallowed - no one can ignore the detriment to the Green Belt that would be created by developments the size of that at West Horndon and the Dunton Garden Suburb but the gain is likely to be only too readily swallowed up in dealing with the obvious capacity issues that would be created by such a concentration of living and associated activity.

To restate, a more dispersed growth model can be used to efficiently use existing infrastructure capacity possibly with little intervention whereas large developments will inevitably require greater use of investment into the Borough in solving problems created by the development.

Q13: What do you think the priorities for infrastructure spending should be?

This requires a study in itself and I note that this is being looked into (6.3). As stated throughout this response though I feel that Strategic Growth options need to come out of the conclusions from the infrastructure study (and studies into other such high level matters) rather than being in a response to a more arbitrarily suggested steer.

This consultation contains infringements of the Green Belt and developments which are too remote from essential service such as at Woodlands School #16A/B and Dickenson Farm #082. In addition to Green Belt and remoteness concerns, Coombe Woods (Breedens Lane) #212 and land adjoining Carmel #027 on Marscalls Lane involve loosing unacceptable numbers of trees and plants.
Also development of the Ford's Warley site should be strongly resisted as this puts many high quality local jobs at risk with the additional risk to the Ford Dunton site in Basildon. Also considerable upgrade to health, schooling, transport etc would be necessary before this could be considered.

See attached.

I realise that my contribution to the policy team may be late for the first consideration, but I have only just been made aware of the proposals and the location map of the areas being assessed for domestic development. I also note that the Coombe Wood patch is adjacent to my property and indeed includes a large part of my garden!!

I have been a resident of Great Warley since 1952 and have some comments to make on the proposals for additional residential development within the village.

1) The village is within the area designated as Metropolitan Green Belt for many decades and this must be recognised as a priority...

2) The area is enclosed by the M25, A12 and the A127 and thus is a haven for animal and plant wildlife. The amenity woodland goes back two to four centuries and the extent of natural English bluebells is very important as the woodland needs 2 centuries to develop such a growth! The farmland involved in this area is sensitively cropped with wide margins and wild flowers in the meadow areas specified in the applications.

I have counted over thirty species of birds from my garden with special reference to woodland birds such as owls and woodpeckers. Mammals include foxes and badgers and their dens and setts. Also there are fallow deer are wide spread over the area.

3) Local services are limited around the village. Telephone and electrical supplies are mostly above ground and therefore restricted in supply and reliability. More importantly there is little or no main sewage supply in the areas proposed and therefore extended domestic development would require local authority investment.

I hope that these comments will be noted when the applications for development from the three proposers are considered, as we would oppose them for those reasons indicated.