See attached document

Havering welcomes the opportunity to comment on the above Local Plan documents.
The comments set out below have Member approval. However, Havering will be submitting further comments to the Strategic Growth Options shortly reflecting additional Member's strong concerns regarding the Green Belt and transport implications of some of the potential development sites identified in the document.
For information, Havering will also be submitting separate comments on the Dunton Garden Suburb proposals currently out for consultation (extended until 16th March 2015) in the light of the strong concerns that this proposal raises in terms of the Green Belt and for the strategic highway network.

Potential development sites (A12 Corridor)
The document identifies a number of sites in the A12 Corridor Housing Site Options section which are adjacent to the Havering borough boundary - specifically sites 175B and 175C (Land at M25, Junction 28, Brook Street) - which are identified as potential mixed-use development sites.

It is acknowledged that all sites in the document are potential development sites only at this stage, and that no detail on the type, scale and form of development is provided. However, if these sites are taken forward into the Draft Brentwood Local Development Plan then Havering will need to carefully consider any proposals for these sites. Depending on the scale and nature of development there are likely to be issues for Havering in terms of, for example, transport and the impact of development on the openness and character of the area.
Potential development sites (A127 Corridor)
The document identifies site 101A (Land at Cobham Hall, including M25 work site at A127/M25 Junction 29) as a potential new employment site - Brentwood Enterprise Park. This is in line with its identification in the 2013 Preferred Options report. As this is adjacent to the Havering borough boundary, the Council will want to see further detail on proposals for this site should it be taken forward into the Draft Brentwood Local Development Plan later in 2015.
Gypsy and traveller sites
Appendix 1 of the documents lists 19 existing gypsy and traveller sites in Brentwood, a number of which are in the Navestock area, close to the Havering borough boundary. However, only 10 of the 19 sites are identified on the maps on pages 16 to 19. Further clarification on where all 19 existing sites are located is necessary. Information on pitch numbers on each existing site should also be included.

The document notes that the Council will need to consider national policy and the conclusions of the 2014 Essex Gypsy and Traveller Assessment when preparing the Draft Brentwood Local Development Plan. This version of the plan should include current and future pitch numbers and details of new or extended existing sites for comment.

We would have serious concerns about any encroachment on Green Belt land, (as shown
to the east/southeast of Brentwood in the Ingrave/Herongate areas). The area shown consists of
significant good quality farm land, and includes areas of historical interest and natural beauty.
The area to the south and west of Brentwood also incorporates Green Belt land designated as
part of the Thames Gateway project, which is intended to create a demarcation barrier between the
urban sprawl of London and the Essex countryside, so any possible developments on these Sites should
be confined to an absolute minimum and be very small scale.
The proposals also show that the villages of Ingrave and Herongate would lose their identity as they would become part of the urban sprawl of Brentwood.
In spite of the government proposal, we are both of the opinion that new, proposed developments be
confined to 'brownfield' Sites in the Brentwood area and that any building on Green Belt should be
strongly resisted.
Such necessary building sites should contain a reasonable element of affordable housing.
In noting the so called 'need' for Traveller Sites, we believe these should be resisted as many
of these 'so called' Travellers already have homes elsewhere in either this country or abroad.
Having been plagued by Travellers who have set up illegal sites on Common land close to where
we live, and where neighbours have been physically and verbally threatened by them, should sites be required then they should not be sited near people's homes. They could be located on brownfield sites rather than any Green Belt land.

I would like to objection to the above proposed development, We may well have a thriving community, here with village hall, church, shops, play area Doctors Surgery, but I do not consider it could sustain another 50 houses in the village. Only today, I have had to ring the surgery, for my repeat prescriptions,to be told, these have to be reviewed, and the earliest appt is the 2nd of March, so I will be out of my medications before then, and there is nothing else on offer, other than trying every morning to ring at 8.30 for cancellations. There is certainly not enough parking for the shops as it stands, or the school times in the morning and afternoons, are absolutely horrendous, without adding extra people living in the village, needing doctors, schools, etc. That is without the extra cars on the roads, which is madness as it is.

I fully understand there needs to be new housing, particularly for first time buyers, as it is getting to the point, when trying to get on the property ladder, is almost out of the question in Brentwood and surrounding areas. The Brentwood Surgeries, and Dentists, are full to Brim and also you have a wait of nearly 2 weeks for an appt. Parking is horrendous, especially now with the intake of people who come from all over, following the series 'The ony way is Essex'., Our highstreet, has no decent shops, its especially full of pubs eateries, banks and building society and charity shops, There is absolutely nothing for the teenagers to do at weekends. I have lived in Brentwood all my life, bringing up my family who also live in Hutton. Back in those days we had a choice of two cinemas in the High Street, and different clubs to go to in the surrounding areas, for teenagers, now there is nothing. I understand there is also the possibility of restaurants, at the end of the High Street, on the Charles Napier Pub Site, Already there are flats being built in Crown Street, and also now the Post Office to become another restaurant, and also Clement Joycelyn premises. This is all very well, but with the financial situation for families as it is now most people cannot afford to eat out regularly anyway, I appreciate 'Travellers@ need designated areas to rest, with facilities such as showers and toilets, and I agree with this, as they would then have to pay some form of rent as such for the use of. After All, they are only a different 'race' of people, and should be given the courtesy of somewhere to stop and rest for a while, rather than having to stay on farmers fields, and the side of the roads, unlawfully. Every race, or type of person, has the right to good and fit for purpose living facilities. Our own Highstreet is a danger zone, to walk on where the bricks are lifting and moving, and that should never have happened, considering what it cost to be done. In the village of Doddinghurst where I live, there has been new equipment for the children in the play area, and according to the Gazette, it cost £80000, This is horrendous, there is not way, new play equipment, being installed, can be justified to the cost of £80000,. so I also think that more time and consideration should be taken to spending public money at exorbitant prices, when I am sure they can be completed for much less money and there is not even a bench for mums/nans/grandads, to sit on, while watching the children play.
Well rant and objection duly sent, from not just this email address, but on behalf of a lot of other villagers, who are concerned about what is to become of our lovely country village. Having seen the changes of the 60 odd years I have lived here, I have to say we are really concerned about the outcome of the localplan for the area

I refer to the above consultation, which runs until the 17th February 2015. Please accept this letter of representation as a formal response to the consultation.

Having spoken with Ms. Camilla James (Planning Policy Officer), I understand the current consultation is in response to a number of key issues which have arisen since the time of the draft Local Plan 2015-2030 'Preferred Options' consultation (July 2013), and the Borough Council is not abandoning 2013 'Preferred Options' document altogether. The current consultation is thus to be viewed in tandem with the Preferred Options document.

The reason for this letter is that we wish to comment on the Council's approach to identifying suitable travellers' sites.

Emerging Brentwood Borough Council Traveller policy

One of the issues requiring reconsideration in this consultation relates to 'planning for Gypsies and Travellers' (G&T), following production of a G&T accommodation assessment for all of the Essex local authorities (Page 6). The consultation goes on to state that "the Council will need to consider the conclusions of this in preparation of the next version of the Draft Local Plan".

Draft Policy DM28 of the 'Preferred Options' document sets out the Council's proposed strategy for identifying suitable sites for Gypsies and Travellers within the borough. The policy proposes to "meet the need for 44 permanent Gypsy and Traveller Pitches to 2030...the Council will identify Gypsy and Traveller sites to meet this provision, through a combination of allocations to ensure a five year land supply is maintained throughout the plan period, and the grant of planning permissions in accordance with the following criteria:

a) The site does not give rise to unacceptable harm to the Green Belt,
b) The site is well related to existing communities and accessible to local services and facilities, such as shops, primary and secondary schools, healthcare and public transport,
c) The site is serviced by a suitable access road,
d) The location would not result in unacceptable living conditions for its occupants,
e) The proposed accommodation would not harm the character and/or appearance of the area and/or result in unacceptable visual impact,
f) The site is located, designed and landscaped to minimise any impact on the environment".

Under the policy, the Council proposes to meet its entire need through the permanent allocation of some existing temporary sites and by providing the remainder as part of mixed-use development at one or more new strategic allocations.

We are concerned that the Council is only considering the housing needs of Gypsies and Travellers, not Travelling Showpeople. Page 8 of the document 'Planning Policy for Traveller Sites' (PPTS, March 2012) specifically excludes Travelling Showpeople from the definition of 'gypsies and travellers', so it is our assumption that the Council is not including Travelling Showpeople in the policy. This is further emphasised by the fact that draft policy DM28 only discusses the provision of Gypsy and Traveller 'pitches', which are by definition separate and distinct from Travelling Showpeople's 'plots' (again see PPTS, page 8). As it stands, where the draft Local Plan appears to us to be 'silent' on the provision of Travelling Showpeople's accommodation, the Council is vulnerable to the presumption in favour of sustainable development, as set out in Paragraph 14 of the NPPF, which confirms that where a plan is silent planning permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits.

Whilst we accept that the Essex Gypsy and Traveller and Travelling Showpeople
Accommodation Assessment (EGTTSAA) undertaken on behalf of the Essex Planning Officers Association by Opinion Research Services (ORS) in July 2014 suggests there is no identified 'need' for plots for Travelling Showpeople's accommodation within Brentwood Borough, PPTS is clear that Local Plans should include criteria-based policies, as a basis for decisions for any such application, should a proposal come forward nonetheless. This is in order to provide a fair and equal method of facilitating the traditional way of life of Travelling Showpeople.

We note that the EGTTSAA has identified a need to provide 183 additional plots, across Essex, in the period from 2013 to 2031. Both the NPPF and PPTS place a clear duty to cooperate on local planning authorities in both identifying and delivering Travelling Showpeople's accommodation to meet with this identified need. It may be that Brentwood Borough Council is required to provide accommodation which has been identified in one of the adjoining Boroughs. The Local Plan needs to provide a suitable policy framework for Travelling Showpeople as well as gypsies and travellers.

Furthermore, we are concerned that the draft policy, as currently worded, suggests that the Council will only support applications on suitable sites up to the point where a total of 44 pitches are provided. This approach is contrary to PPTS, for the same reason.

National Traveller Policy

PPTS provides Government policies for traveller sites (noting that the definition of 'traveller' in PPTS includes 'Gypsies and Travellers' and 'Travelling Showpeople'). The aim of this document is to "ensure fair and equal treatment for travellers, in a way that facilitates the traditional...way of life of travellers, whilst respecting the interests of the settled community".

Local planning authorities should ensure that their traveller policies, amongst other things, "promote peaceful and integrated co-existence between the site and the local community" and "reflect the extent to which traditional lifestyles (whereby some travellers live and work from the same location thereby omitting many travel to work journeys) can contribute to sustainability".

Suggested amendments to the Council's draft policy

Criterion (b) of draft Policy DM28 states that suitable sites will be "well-related to existing communities and accessible to local services and facilities". If our understanding is correct, and the Council is suggesting that only urban-edge sites will be considered suitable, this is inconsistent with PPTS.

Travellers' traditional way of life often involves living in rural areas. Indeed, we note the following from the EGTTSAA: "the majority of sites in Brentwood are in remote Green Belt areas...some of these Gypsy and Traveller residents have been situated in the Green Belt for many years and show a preference to live there rather than being located near towns and villages".

We would suggest the Council adopts a more holistic view of the requirements of travellers when considering the suitability of individual sites. PPTS confirms that it is perfectly acceptable to allocate/grant planning permission on rural sites for travellers, provided they do not dominate the nearest settled community (Paragraph 23). Indeed, when one considers the important requirement for local planning authorities to promote peaceful and integrated co-existence between a travellers' site and the settled community (Paragraph 11a), it could be the case that a rural location provides the most sustainable option for accommodating
travellers.

Referring specifically to Travelling Showpeople's sites, we consider an urban or urban edge site allocated for this purpose would also be an inefficient use of land, particularly given the difficulty the Council faces of providing 5,500 new homes over the plan period. Showmen's Guild Model (site layout) Standards (2007) confirm that a plot of over 0.5 acres (0.22ha) is normally required, when one accounts for the need for storage space of equipment, vehicles and machinery within individual plots. It is unlikely that Travelling Showpeople's accommodation could secure the values that would be necessary to acquire such land, unless this was provided by a developer through a planning obligation. Furthermore on the
point of the Council's suggested delivery mechanism as part of a strategic allocation, we see no policy basis on which the Council could reasonably justify requiring a developer to provide land for the purposes of travellers' accommodation, as part of any planning application for bricks and mortar housing, since it would be difficult to see how it would be required in order to make a proposed residential development acceptable in planning terms. It is therefore extremely risky to rely on this approach as a source of land for travellers' sites.

We would suggest that the Council should consider an additional category of land that could also form an appropriate supply of sites for gypsies and travellers. Previously developed sites in rural areas, including suitable sites within the Green Belt, may be an appropriate alternative option for allocation / granting of planning permission for the purposes of Travelling Showpeople's accommodation. Such sites would provide an efficient re-use of previously developed land, supported by both the NPPF and PPTS, and would meet with the above-stated requirements of promoting peaceful co-existence between traveller and settled communities and also reflecting the contribution of these sites to sustainable
development these sites make, by reason of the fact that residents often live and work on the same site. Clearly such policy would need to make it clear that such use of previously-developed land in the Green Belt must comply with other Green Belt policies.

We would be happy to discuss the matter further, should you have any queries in relation to my representation.

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