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.

Q1: No - I do not agree with the North of the Borough Option. Substantial building would not be sustainable. Country lanes have to be used to access A414 and M11, causing much erosion. The bus service is poor and doesn't run after early evening and is infrequent with regard to Kelvedon Hatch. Although there is a newly built Doctors Surgery, there are only 4 doctors, and an increase in the population would mean even longer waiting times. The local primary school is only small and I would imagine it would have trouble accommodating a significant number of new pupils. It is also important for the villages to maintain their own identity and not merge into an urban sprawl, which could happen if Green Belt on the edge of villages is used for housing.

Q2: Yes

Q3: Yes - 201. Environmentally this would cause noise and light pollution. Various wildlife live and feed in this field including bats, owls and other birdlife i.e. sparrow hawks, green woodpeckers and thrushes and starlings, all in decline. The corridor of land is important for wildlife and I believe on this agricultural greenbelt would be detrimental. If this site were to be developed it would increase the size of the village by almost half again, which would be unsustainable.
204. I believe this site would also be detrimental to the village, as again a large development would be unsustainable and change the character of the village.
217. This is an area used by villagers for dog walking, picnics and general recreation. If this were developed it would deprive the village of a much needed amenity.

Q4: I think the Dunton Garden Suburb would be a good option especially as it could provide funding for A127 improvements.

Q5: Yes

Q6: It would be better to develop brownfield sites.

Q7: Yes

Q8: Yes

Q10:
Scenic Beauty Attractiveness: 5
Outdoor Recreation / Leisure Use: 5
Wildlife Interest: 5
Historic Interest: 3
Tranquility: 5

Q11:
Houses: 2
Commercial / Industrial Buildings: 2
Nature Reserves / Wildlife: 3
Farmland: 4
Woodland: 3
Degraded / Derelict / Waste Land : 2
Infrastructure: 2
Leisure / Recreation Facilities: 2

Q12: Yes

Q13: Green infrastructure should be as important as all the others, to maintain a healthy society both physically and psychologically.

see attached

The Kelvedon Hatch Parish Council discussed the Local Plan at both our January and February Council Meetings held on the 8th and 12th respectively. We have a series of observations to make.

In general we accept that more residential and employment sites are required over the next few decades, but would still prefer to protect the Green Belt where ever possible in line with the new NPPF guidance. We would favour development within "brown field" sites where previously green or agricultural activities have not been carried out for some time. We felt that of the four options given on page 11 of the Consultation Document either Nos. 3 or 4 would be preferable in order that "the pain was to be shared out more equally".

With particular reference to our parish of Kelvedon Hatch we realise that "brown field" development opportunities are very limited and nearly all the suggested sites given within the appendix on page 43 lie within the Green Belt. In general we felt that the preferable sites should be limited to the "in-fill" sites round the ragged development curtilege of the village itself. The most acceptable sites being those with three sides of attachment, reducing to two sides as less acceptable and with only one side or totally separated as least acceptable. We prefer infill sites as this is in agreement with the new NPPF guidance on Green Belt considerations.

Without going into consideration of each individual suggested site for our parish some examples would illustrate. The number of each site is as given in your appendix 2 for the Brizes and Doddinghurst Ward. Examples of more acceptable in-fill sites are 066, 168, 182, 194, 075 and 217. Although site 182, land adjacent to Heathlands, School Road, has recently been refused permission by the Borough Council, but it is still at appeal with the Inspectorate. Land to the rear of the Spinney, School Road (site 139) has been refused permission by the Borough Council and the subsequent appeal was dismissed by the Inspectorate. We would also like to point out that Woodlands, School Road (site 009) is privately owned, within the development envelope of the village and was the subject of an uproar within the village at the presentation of the earlier consultation in 2013. This was due to the fact that the first the owners had heard about their "redevelopment" was from the Brentwood Gazette. At the meeting the owners were reassured by the Borough Council Officers stating that no compulsory purchases were to be made.

Least acceptable sites are those such as 201, GT004, GT013 and those isolated areas to the south of the village such as 191, 221 and 210. A possible site that has yet to be included, which has more of an appropriate in-fill aspect is land to the west of Ongar Road between the Whitehouse (already granted planning permission, but with stringent conditions attached with regard to land decontamination) and Fairview. Ownership of this land would have to be established, but the land is in a neglected condition and has been so for many decades. Whilst the above examples are by no means a definitive list they give a flavour of the Parish Councils deliberations. In the fullness of time we would appreciate being consulted on each individual site that the Authority chooses to recommend if any at all.

The Consultation also requested our views on the proposed Dunton Garden Suburb. Much was made of the fact that we should not deign to comment on someone else's patch, however, it was noted that much of the area was brown field and also that the relevant Parish Council has been reported in the local press as having reluctantly agreed to the proposal after reassurances were made about suitable infrastructures considerations and improvements. It was also observed that such a large development would relieve pressure on the rest of the borough. It was felt that the Parish Council should be in favour of the Garden Suburb. In all these discussions mention was made of the need to properly assess and provide upgrades to the required infrastructure for any developments within the Borough. This would include all services such as sewerage, electricity, gas, internet as well as roads, cycle paths and pavements. Considerations should also be made with regard to schools and medical service provision. Such upgrades would of course be part of the developer's conditions in order not to overload, any further, the existing services.

The Parish Council hopes that these views will be helpful to the consultation and we would appreciate receiving the results and any further decisions by the Borough Council on the Local Plan.

Consultation Questionnaire see attached.

Email: Strategic Growth Options Consultation - incorrectly structured question

Hi

I am in the process of completing the Strategic Growth Options consultation questionnaire and an unable to proceed because of what I consider a serious structural flaw in Q6.

Q6 reads: In order to provide for local needs is in preferable to greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within the green belt)?

A Yes or No answer is required (with the option to comment).

However if the answers to Q6 are to be interpreted statistically, it is clearly not possible to answer a multiple choice question with a yes/no answer. Any qualification in the comment box renders analysis impossible.

This elementary error renders one of the most important questions raised in the consultation meaningless. I cannot believe that such a fundamental mistake in questionnaire construction can have been made on a key issue.

I would regard any answer to this question as invalid.

I would be interested to hear your comments as a matter of urgency.

See attached

See attached

See attached