My principle concern with this proposal is with the additional strains on infrastructure, which to be frank, I fail to see being addressed other than in the most ridiculous spin.
Over the past 10 years I have see our infrastructure deteriorate as it overloads. This will only get worse as the poplulation increases. As such, please respond to the following:
* Please confirm exactly how public transport will improve to accommodate the needs of commuters - e.g. will the platforms at Brentood station be extended so as to accommodate longer trains? You mention "more frequent" trains. Such services are already frequent, but they are overcrowded.
* I recently had to wait 3 weeks for a doctor's appointment, whereas 10 years ago I could see a doctor in a couple of days or so. What specific consideration is being afforded to new surgeries, A&E and other appropriate heathcare facilities? What is the Political Risk to any such healthcare investment given the forthcoming General Election?
* Given the problems that Basildon Council had with the Crays Hill Travellers Site, why does Brentwood Council feel obliged to establish a similar site within our borough?
* Why is the Council is being seemingly bullied into accepting the addition of 5,500 homes, which could mean >20,000 citizens arriving in the Borough, when there are large brownfield sites in the immediate surrounds of London (e.g. the Dagenham Ford site) that can easily be developed.
* What is the cost benefit for existing residents, especially with regard to Council Tax?
* Has consideration been afforded to the fact that we may actually like wide open spaces (including Greenbelt land), and believe it MUST be protected?
I will be objecting to all aspects of this proposal, unless a satisfactory explanation is given to my points above.

Thank you for your swift response. In addition, I have certain other observations:

The addition of so many homes will require additional investment in the emergency services, i.e. Police, Fire and Ambulance. What provision is being made to ensure that such a dramatic increase in population (perhaps 25-30% based on the current population estimated at 71,000) can be policed and served adequately? Crime would be a particular concern especially with the proposal for Gypsy/Travellers sites within the Borough. What steps will be taken to ensure that such Gypsies/Travellers pay Council Tax?

With regard to the problem of parking in the town centre, what provision is being made to ensure that an additional proportion of cars can actually park in what is an already inadequately provisioned town centre? The council has a poor track record with regard to road repairs (e.g. pot holes). How will roads structurally cope with such an influx of vehicles?

Please note that these and my previous points / observations apply to all aspects of this planning process including, but not limited to, the Dunton Garden Suburb plan.

Mountnessing Parish Council (MPC) would like to make the following comments for consideration by Brentwood Borough Council:

MPC prefers to consider and comment on actual planning applications when they are made. It believes that it would not be appropriate to nominate development sites and opportunities in the parish as it could well be imposing decisions on future members of MPC during the lifetime of the LDP. In this way it is felt that no advance recommendation or commitment will be made for any development so that careful consideration can be made at the appropriate time so as to weigh the needs and requirements prevailing at the point in time.

MPC recognises the importance of the Parish in respect of the A12 corridor and the limited opportunities for key developments that can make use of the village facilities, bus routes and transport links (including Cross Rail) within the village envelope. Whilst coalescence is an issue for consideration the A12 creates an obvious division between Mountnessing and Ingatestone that prevents them from ever being linked. With this in mind the challenge of coalescence for MPC is seen as the development of the green corridor that separates the urban area of Shenfield from the semi rural areas that surround it. Even though the A12 would still create a break it is felt that developing Officers Meadows would bring Mountnessing into a continuum of building with very little separation from the urban area.

MPC does have concerns about one specific site. This relates to the possibility of Ingatestone Garden Centre becoming a residential development. This would add a dense area of dwellings to what is seen more as outer areas of Ingatestone. Such a development would not be close schools, public transport or medical facilities and should not therefore be considered suitable for housing.

MPC would like to ensure that building density, building styles and street scene are considerations that are given a high level of importance in any potential development. MPC will always want to preserve the 'village feel' of Mountnessing and will always strive to make the right recommendations to ensure that we keep the village how residents would like it to be.

The Parish Council request that the following proposals be given serious consideration by the Borough Council:

- Addressing the need for one bedroom social dwellings to allow existing, and mainly, elderly residents to downsize.
-The use of shared ownership/first time buyer initiatives to help young people to get on to the housing ladder.
- Providing for an increase in the number of bungalows which are in demand by the population in general and also by the projected rise in the number of elderly residents.

MPC has very serious concerns over developments proceeding with little regard to the impacts they will have on the existing infrastructure. MPC would want to see that the fresh water supply can provide sufficient pressure to all properties and also that sewerage can be properly drained and processed even in times of high demand such as heavy rainfall. Additionally the Education Authority should ensure that there are sufficient school places for all children that move into the area and that there are additional healthcare facilities provided to cover all residents.

The Parish Council would like to give consideration to the desirability of reclassifying the parish boundary within the Brentwood Local Development Plan. The present boundary does not accurately represent the village's entrance and egress and the Parish Council will arrange to discuss the issues involved with the Borough's Planning Team.

see attached. (OFFICER RESPONSE ONLY, OFFICIAL RESPONSE TBC)

I have tired to complete the consultation questionnaire via your website, however, I could not find the on-line word format only the PDF version. As you know you cannot overtype on PDF. I contacted your Planning Office and the person I spoke to could not find the on-line Word format either! She suggested I email you and assured me my comments would be taken into consideration and reported in the same way as submitting my response via your website.

I would be grateful therefore if you could acknowledge receipt of this email and confirm my concerns will be relayed in an appropriate manner.

I viewed a property in October 2014 and consequently moved to Peartree Lane in January 2014. Our Solicitors searches showed no suggestion of any plans for development for an additional 50 dwellings at the end of Peartree Lane, and obviously had we have known this we would have had to re-think our plans to move the area.

My concerns are as follows:-

Consideration of this site seems premature with a lack of a Green Belt review, as other more suitable land could be available elsewhere within Brentwood that could be taken out of the Green Belt to deliver the housing required.

There is no secondary school provision within the village, many local secondary schools are reaching capacity. An additional 50 family homes will place added pressure on the local secondary school, which is primarily accessed by car, and potentially displace other village needs.

Buses are not as readily available as the consultation document suggests. The only service is the No. 261 which runs every hour mon-fri with no service before 6.45am or after 6.15pm, with the latest bus back to the village being 6.35pm from Brentwood Railway station. On a Saturday it is worse with no bus prior to 8am or after 5.15pm and the last bus back in the evening is 5.30pm. There is no service on Sundays or public/bank holidays. Thus providing poor connectivity to Brentwood for employment purposes, looking at the times of travel available and normal working hours. This constrains a shift worker, or someone working on a Saturday/Sunday in Brentwood and certainly hinders the night time economy within Brentwood from these outlying settlements. The nature and timings of this service do not promote sustainable development or enable this site to be categorised as sustainable in the terms set out within the NPPF 'golden thread' of social, economic and environmental, in fact this site runs contrary to the three sustainability objectives.

Does the junior school have provisions for the impact of the growth of 50 family homes?

The consideration of site allocations within the Green Belt seems premature prior to a comprehensive Green Belt review being undertaken to identify land within the Green Belt that's loss would have a lesser impact on the wider function of the Metropolitan Green Belt.

The National Policy Framework (para 83) stipulates that the Green Belt boundaries, once established should only be altered in exceptional circumstances, this section of the NPPF goes on to look at the nature of a review of the Green Belt and ensure that when reviewing the Green Belt that it should not need to be further reviewed following the Development Plan period. Whilst accepting that Brentwood needs to deliver a large amount of new houses and that this cannot be accommodated on Previously Developed Land in its entirety, it is considered that the proposition of such Green Belts for residential development is premature.

There is strong support, as can be seen from the Issues and Options Consultation Analysis 2010, for the retention and protection of the Green Belt from the local community. If the Green Belt is to be altered, it should be approached holistically, via a comprehensive review that assesses the quality and quantity of the Green Belt available and only once this is undertaken can a realistic assessment of available sites for residential development then be undertaken.

The village is modest in size, who's character is a compromise between residential development and pockets of green space giving a rural feel to the area. The loss of this section of Green Belt to development would fundamentally change the character of this part of Doddinghurst to its detriment resulting in an ad hoc play space and residential development hiding the wider countryside from the established community, to its detriment.

In conclusion, it is considered that Brentwood have failed to look holistically at this matter to ensure that the sites identified are in fact deliverable and sustainable and will pass the tests set by Inspector's as part of the Examination in Public of any proposed Local Development Framework. This is endorsed by representations made by Thurrock Council, who also emphasise the need for a Green Belt Review to take place.

It is noted that a proportion of the evidence base has not been made available as part of this consultation exercise, therefore the consultation is considered to be flawed.

see attached

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.

see attached

Thank you for your email of 8 January 2015 consulting the Mayor of London on your Local Plan Strategic Growth Options consultation and Dunton Garden Suburb consultation.

At this stage in the plan preparation process I wish to note only that in seeking to reconcile housing supply and need in the terms of the NPPF the Council may wish to reassure itself that its needs assessment takes into account uncertainty over future levels of out-migration from London and the way this may bear on household growth as well as any backlog of need. We are pleased to note, however that the Borough Council has taken account of 2008 as well as 2012 demographic data, a point raised at a meeting between Brentwood Borough Council and GLA officers on 20 March 2014. The issue is discussed in the Objectively Assessed Housing Needs for Brentwood - Final Report, Feb 2015.

It is also noted that the Strategic Housing Land Availability Assessment dates back to October 2011 and the Council may wish to consider updating it.

With regards to logistics and industrial land the council may wish to note that London Plan paragraph 2.81 indicates that the Mayor will work with authorities in the Wider South East to ensure efficient logistics provision throughout the whole area. The Mayor's Land for Industry Supplementary Planning Guidance (SPG) (see specifically paragraphs 5.10 and 5.16) builds on this indicating that 'close cooperation with planning authorities in the wider metropolitan area to address the spatial distribution of logistics serving London and the south east region is essential. The Mayor will work with relevant authorities to explore ways in which this can be carried forward for the benefit of the wider region as a whole'. You may therefore wish to consider the scope to accommodate demand for logistics serving both London and the wider south east region in your employment land policies and proposals.

With regards to retail we would support a town centre first approach.

Thank you for your email of 8 January 2015 consulting the Mayor of London on your Local Plan Strategic Growth Options consultation and Dunton Garden Suburb consultation.

At this stage in the plan preparation process I wish to note only that in seeking to reconcile housing supply and need in the terms of the NPPF the Council may wish to reassure itself that its needs assessment takes into account uncertainty over future levels of out-migration from London and the way this may bear on household growth as well as any backlog of need. We are pleased to note, however that the Borough Council has taken account of 2008 as well as 2012 demographic data, a point raised at a meeting between Brentwood Borough Council and GLA officers on 20 March 2014. The issue is discussed in the Objectively Assessed Housing Needs for Brentwood - Final Report, Feb 2015.

It is also noted that the Strategic Housing Land Availability Assessment dates back to October 2011 and the Council may wish to consider updating it.

With regards to logistics and industrial land the council may wish to note that London Plan paragraph 2.81 indicates that the Mayor will work with authorities in the Wider South East to ensure efficient logistics provision throughout the whole area. The Mayor's Land for Industry Supplementary Planning Guidance (SPG) (see specifically paragraphs 5.10 and 5.16) builds on this indicating that 'close cooperation with planning authorities in the wider metropolitan area to address the spatial distribution of logistics serving London and the south east region is essential. The Mayor will work with relevant authorities to explore ways in which this can be carried forward for the benefit of the wider region as a whole'. You may therefore wish to consider the scope to accommodate demand for logistics serving both London and the wider south east region in your employment land policies and proposals.

With regards to retail we would support a town centre first approach.

see attached

see attached

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

see attached

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1. Managing Growth

Q1 Do you agree with the three broad areas, for the purpose of considering
approaches to growth.
Q2 Do you agree with the issues raised for each of these three areas.

The whole Borough should be looked at as a whole when considering a coordinated approach to growth. To split the Borough into three broad areas does not achieve the primary objective, which is growth to enable the Borough to grow as a whole. The approach taken by the Council allows it to weight significant growth in the area it wishes, which is predominantly the A127 Corridor and to limit growth elsewhere in the Borough.

In the last consultation document, West Horndon was strongly pushed by the Council as an area that could take significant growth. There was strong objection to this plan, so the Council have decided to move the area slightly eastwards but still achieving its objective of siting the majority of the required housing as far away from the main conurbations of the Borough as possible and calling it Dunton Garden Suburb. The word garden is designed to make the area sound prettier than it really is. Again the Council have ignored the need to spread development throughout the Borough.

The wording of the three areas is misleading and highlights areas of concern for development in the north of the Borough and the A12 Corridor whilst glossing over any issues with development within the A127 Corridor. Why does the Council believe that "although the A127 suffers from congestion problems it has more scope for improvements than the A12 ". The A127 has significant problems and is beset with traffic issues. The amount of money needed and infrastructure changes required to sort either the A127 or the A12 out to handle a new town will/would be massive. The damage caused to the environment whilst the work was being undertaken and the resulting damage to the landscape would be irreparable.

As previously mentioned the issues for the three broad areas are significantly weighted against Option A (North of the Borough) and Option B (A 12 Corridor) in favour of Option C (A127 Corridor). It is accepted that land will have to be released from the Green Belt to allow the Borough to reach its housing target and provide the necessary employment land.

If the Borough is considered as a whole instead of splitting it into areas then development on the outskirt of sustainable villages such as Ingatestone, Hutton, Kelvedon Hatch etc along with larger developments on the outskirts of Brentwood and Shenfield would allow the impact on the Green Belt to be minimised. To erect 4000 plus houses along with employment land along the A127 Corridor would create more damage to the Green Belt. The Council seek to minimise the effect by describing the land as of different landscape character and making this a reason for encouraging development. First and foremost it is Green Belt and its different character should be the reason for encouraging its preservation and not destroying it.

In the Council`s latest Sustainability Appraisal it states: "Sites which make up Option 5 would be dispersed around the periphery of towns and villages. While this would lead to adverse landscape effects, it is considered that the smaller scale of developments would reduce the adverse effects compared to the other four options. There would be greater scope to avoid development in areas or particular landscape sensitivity and/or Green Belt value." The preservation of the Green Belt, according to one of the Council`s previous questionnaires, is the primary concern of the residents of the Borough. The potential for development throughout the Borough not just on a few large sites and one in particular would more accurately achieve this concern.

2. Sustainable Communities

Q3 Do you have any comments on the appropriateness of particular sites
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.
Q5 Should the A12 Corridor accommodate growth by releasing sites on the edge of urban areas.
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).

The Appropriateness or not of sites was looked at during the SHLAA Consultation. With over 230 sites put forward during this process it is not possible to comment on the appropriateness of every site. It is considered that a new more up-to-date Consultation should take place due to the time lag and new Government Policy since the original Consultation in 2009.

Site ref no 220 - Collins Farm, Goodwood Avenue, Hutton is a greenfield site that lies on the edge of Hutton. In the original SHLAA assessment it stated; "Availability dependant on the farm tenancy. The site is under option by a developer. The site offers good location for the extension to Goodwood Avenue and Hutton. There is good access to the road network, adjacent to an area of nature conservation to the North and West. The site however is a large extension into open countryside and as such has been discounted".

There was confusion in the original submission hence why the whole farm was shown outlined on the plan submitted. In March 2010 further information was submitted showing the area for development being reduced by approximately 70% of the total area and allowing for an extension of the conservation area onto land adjoining the site. With the increase in housing numbers required by the Borough, this site allows for sustainable growth whilst increasing the area of green open space. There is no farm tenancy affecting the land so the site can meet the existing demand for houses in the Borough.

Question 4 regarding growth along the A127 Corridor is a leading question that assumes that development should take place along the A127. As previously mentioned, it is considered that development can be accommodated throughout the Borough with a proportion of this development along the A127. West Horndon would be considered the most appropriate viable option to take limited development along the A127 Corridor due to existing infrastructure.

Any residential development along the A127 Corridor is likely to have minimal impact on the long term sustainability and stability of Brentwood Town Centre and village communities spread throughout the Borough. The proposed Dunton Garden Suburb may benefit Basildon Town Centre but will not benefit Brentwood. The sustainability of initially the West Horndon Scheme and now Dunton Garden Suburb scheme must be called into question. The infrastructure will need substantial investment and the area of Green Belt lost would not fit in with Council policies.

As part of an integrated scheme sites should be released along the A12 Corridor to encourage the long term prosperity of Brentwood, Shenfield and Ingatestone. This option should be joined with the other options to enable the Borough to grow in a sustainable way. The strategic growth options should enable the Borough to have a long term plan, this will not be achieved by building the majority of houses required at the furthest South Eastern tip of the Borough.

Brentwood Borough, as shown by the recent Strategic Housing Market Assessment (SHMA), is a Borough where people want to live. There is a proven need for more houses throughout the Borough, not just for those wishing to commute into London but for those wishing to work within the Borough. The SHMA described Brentwood as an affluent area with higher than average employment, low unemployment and average pay higher than benchmark
averages.

The question that needs to be asked by the Council is why do people wish to move into the Borough and where do they wish to live and not just where can we build thousands of homes to meet our housing target.

In relation to question 6, it has previously been mentioned that an integrated approach is required to meet the housing demand within the Borough. It is interesting to note that as this option is clearly the least favoured by the Council it mentions land lost within the Green Belt whereas Questions 4 and 5 both fail to mention that development for these options will predominantly be within the Green Belt.

The Borough`s population is expanding and is expected to grow by approximately 10% between 2011-2021, this is in fact lower than the average for Essex as a whole. The number of households is expected to grow by a similar figure over the same period, these figures are well below the Boroughs of Colchester and Braintree. This equates to at least 3000 new homes in this period. Migration into the Borough is growing according to the SHMA and this is expected to continue. Migration helps the Borough`s economy through houses built and
sold, new businesses and support for existing businesses within Brentwood and surrounding villages. Development throughout the Borough will provide the necessary diverse housing required by its existing and future residents. Diverse housing is also required by the government.

An extract from the latest government guidance states; ".... Address the need for all types of housing, including affordable housing and the needs of different groups in the community and caters for housing demand and the scale of housing supply necessary to meet demand." By providing new homes throughout the Borough, including on the edge of villages, the Council will be meeting the criteria as set down by the government. It will be providing a variety of houses/sites to meet the varied demand of the population, this will not be met by building thousands of houses in Dunton which lies distant from the heart of the Borough.

Building on the edge of villages will not just be meeting local need, as the question infers, it will be meeting the need of existing residents and those wishing to move into the Borough. In the Council`s own literature it is accepted that the least harm to the Green Belt will be to build on the outskirts of villages, on smallish sites spread throughout the Borough. Within the recent SHMA it recognises the clear need for more houses within the Borough and that one of the main reasons for moving house, for existing householders, is the quality of the neighbourhood. For concealed householders the two main reasons for moving house was to be near family and they had always live here. Whilst the Council is set on building thousands of houses along the A127 Corridor, it is difficult to see how this meets the criteria of existing and concealed householders. An integrated housing policy, with development throughout the Borough would meet the main criteria for people wanting to move.

In the SHMA it was identified that 56.5% of residents travel to work by car, this is lower than all other benchmarks. With development throughout the Borough, increased public transport and a greater reliance on working from home this figure could be reduced further. There has been little/no mention of live/work units, these could be created to encourage people to work from home on a regular basis. With increased technology there is a trend for people to go into the office less and instead work from home. When live/work units were originally introduced they were for craftsmen to have workshops adjacent to their homes, this has progressed to a person having a fully functioning office above their garage or within their house - they are fully connected to their office but do not need to travel in every day. This reduces car usage and encourages the use of local facilities.

3. Economic Prosperity

Q7 To enable future development need to be met do you agree that the most
sustainable approach is to allocate new sites close to the strategic highway network.

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.


Constructing new employment sites near/adjoining the strategic highway network,
throughout the Borough (not just along the A127) will attract multi-national firms to the area whilst providing employment to local residents. To be sustainable it will be necessary to improve/provide public transport to the sites. There must be consideration for local businesses to expand and to encourage new businesses within residential areas providing they are compatible ie office use, shops etc. By providing an integrated approach it will encourage new sites to be developed and for businesses to grow within villages, thereby providing local employment and reducing car usage.

To ensure that the Town Centre remains economically sustainable it is essential that housing development is not solely situated as far from the Town Centre as possible in Dunton. Public transport needs to be improved to enable access to the Town Centre and parking provisions need to be appropriate for those wishing to drive. The Council could consider the approach taken by Chelmsford Council of providing a park and ride scheme, to avoid congestion in and around the City Centre and to encourage shoppers into the City. A coordinated approach that considers the motorist is essential to enable the town to survive and thrive in the long term. There has to be greater access to the Town otherwise residents will drive to Lakeside/Bluewater where there is plentiful parking. The residents of the Borough should be encouraged to see the Town Centre as their main destination whilst using local shops where possible.


4. Environmental Protection and Enhancement

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

Q10 Please rate the level to which you value the landscape near where you live.

Q11 To what extent do you think the following is present in the landscape near
where you live; Houses, Commercial buildings, Nature Reserves, Farmland, Woodland, Wasteland, Infrastructure, Leisure Facilities, Other?


The Borough is well supplied with footpaths and open spaces, there are always
opportunities for more open spaces but are they needed or necessary. Opportunities could arise through more development throughout the Borough with developers providing money for the Parish they are building in. This would go directly to the Parish Council, not the Borough, and spent within the Parish, to provide improved/new local facilities.

The Borough is predominantly Green Belt and therefore small scale development
throughout the Borough will have the least effect on the existing Landscape, as confirmed in the Council`s latest report. The landscape throughout the Borough is valued and offers opportunities to be enjoyed by all. There are Houses, Commercial buildings, Woodland, Farmland and Roads (including Bus stops) all are within 100 metres of the property, there are also footpaths and areas to walk.



5. Quality of Life & Community Infrastructure

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

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

The main infrastructure issues have been considered however it is important that the money is directed in the right way. The priorities should be new schools, health facilities and improved road network including public transport. It is important for the Council to remember that the majority of the population still drive to work and therefore the roads in the Borough must be maintained to a high standard. The Borough is well served by its Green infrastructure and this should be at the low end of its priorities. The level of money spent on the infrastructure of the Borough must be kept at a level commensurate with an expanding population.

See attached letter and supporting documents.

See attached letter and supporting documents.

See attached letter and supporting documents.

See attached letter and supporting documents.

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dunton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.

LAND SOUTH OF EAST HORNDON HALL
Concern is raised at the prospect of the West Horndon strategic allocations, particularly in regard to the development on employment sites. Whilst the development of those sites is supported, the Council must ensure that sufficient employment land is brought forward alongside the allocation of these sites to ensure that employment is not lost in the Borough. The existing, undesignated, land at East Horndon Hall is ideally suited to provide additional employment land to accommodate those lost through brownfield redevelopment.

FAIRVIEW, MAGPIE LANE
We would like as part of this submission to confirm support for the allocation of a parcel of land at Fairview, Magpie Lane, Brentwood. (see attached Site Location Plan). The site would fall within criteria 2 of the above approach to identifying land. The site is a brownfield site and is harmful to character and visual amenity in its locality. It is predominantly used as a waste transfer station and generates excessive heavy goods vehicle traffic on the local rural road network. The allocation of the site for residential use possibly with a small element of appropriate employment space would improve local amenity and provide resources to relocate the business.

A preliminary assessment indicates that up to 25 dwellings of range of sizes and tenures could be accommodated on the site, helping meet local housing need and improving the character and appearance of the area.

CHITRAL, SWALLOWS CROSS
We would like as part of this submission to confirm support for the allocation of a parcel of land at Chitral, Swallows Cross, Brentwood (see attached Site Location Plan). The site would fall within criteria 2 of the above approach to identifying land. The site is a brownfield site and is harmful to character and visual amenity in its locality

Our client has prepared a masterplan study including an indicative layout, indicative elevations and perspectives to demonstrate an appropriate formof development that can be achieved on this site. The proposals also show the provision of some employment space for local rural businesses The site delivers a range of planning benefits including providing towards housing need, making efficient use of a brownfield site and improving visual amenity . The preliminary proposals indicates approximately 20 houses and 2 commercial units.



Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period.

Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.

Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is appropriate to consider brownfield sites within villages, on the edge of villages and within smaller hamlets for development to meet housing need. Whilst less sustainable than town centre development such schemes can contribute to housing supply for local rural needs and affordable housing. Greenfield sites in sustainable locations are likely to need to be considered for development even after appropriate brownfield sites are developed.

It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - It is a logical decision to seek to allocated employment sites close to the strategic highway network and away from the higher populated areas of residential development. The site to the south of East Horndon Hall meets those requirements, being located on the junction of the A127 and A128. The land is currently partly used for industrial purposes, however there is potential for the land to the south to also be considered for employment use.

An Indicative Masterplan has been prepared together with a Highway Feasibility Summary (both attached), demonstrating that a mixed employment development of up to approximately 21 acres and potentially 34,000 sq m of new employment floorspace can be accommodated within the constraints of imposed by the highway and junction capacities.

The range of uses suggested is predominantly B1 light industrial uses, with elements of B2 and B8 use incorporated.

The proposals provide an opportunity to regulate the existing industrial uses and, whilst the site is heavily screened from the west and north, further landscaping and planting can be provided to create a buffer between the site and the A128.

The site is in a highly sustainable location in terms of highway networks, being located adjacent to the roundabout with the A127 and A128, with direct links to the M25, Brentwood, Thurrock and east Essex.

Furthermore, with the potential proposed allocation for housing within West Horndon, replacing the existing employment land, this site is ideally located for an increase in employment numbers resulting from the additional housing.

Given the lawful uses of the northern element of the site, the condition of the land, the containment around primary roads and the existing screening, the site currently makes only a minor contribution to the purposes of the Green Belt as set out in paragraph 80 of the NPPF.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the area to the north of Brentwood and it is considered that the issues raised in regard to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.
We would like as part of this submission to confirm support for the allocation of the Joy Fook Restaurant, which sits adjacent to Bentley Golf Club, in Kelvedon Hatch (see attached Site Location Plan). The site would fall within criteria 2 of the above approach to identifying land.

Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period. Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.

Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - No further comment.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the area to the north of Brentwood and it is considered that the issues raised in regard to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.
We would like as part of this submission to confirm support for the allocation of the land to the south of #, Mascalls Lane, Great Warley (see attached Site Location Plan). The site would fall within criteria 3 of the above approach to identifying land.

Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period. Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.

Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - No further comment.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the area to the north of Brentwood and it is considered that the issues raised in regard to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.
We would like as part of this submission to confirm support for the allocation of land adjacent to 365 Roman Road, Mountnessing (see attached site location plan), which would fall within criteria 3 of the above approach to identifying land.

Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period. Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.
Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - No further comment.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.