If up-to-date evidence is really so important, why is the Council using recession-era studies for housing density? And, if anything, the importance of evidence would imply that the Council should be SLOWER in coming to a conclusion, and not cut corners, as it seems so keen to do at the moment.

The Strategic Housing Land Availability Assessment Main Report is dated October 2011. §3.17 in particular seems a bit out of date. Although it may have been reasonable to rule out flats as a viable development in 2011, the housing market has picked up since then, so it is no longer tenable to argue that 'in the current climate such units [flats/apartments] are not proving to be popular'. This assertion, which I consider out of date, is significant because it informs the criteria for what density of housing should be adopted. Specifically, Table 3/1 is incredibly biased against high-density housing: it effectively rules out terraced housing in 'All other villages [that is, other than Brentwood/Shenfield/Ingatestone centre/W. Horndon centre/Doddinghurst centre], including sites adjoining the edge of villages'. It also effectively rules out having flats outside of the 'Brentwood centre, Shenfield centre plus sites on the main roads coming out of these centres'.

All of these assumptions above are contrary to the evidence that flats and terraced houses ARE highly sought-after in Brentwood, even when located outside town centres. Consider the Clement's Park/former Warley Hospital site, which has many flats, yet is an incredibly popular neighbourhood, despite many of the housing units being completed during the recession (as observed by the report on Objectively Assessed Housing Needs, which points out that recent completions are bucking national trends, and thus may have given an overestimate for future need, see §5.28).

See attached.

See attached.

See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

See attached.

See attached.

See attached.

See attached.

See attached.

See attached.

See attached

See attached

See attached

See attached

See attached.

Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

I am pleased to have the opportunity to respond to the Brentwood Borough Draft Local Development Plan.
The Plan and the attachments and appendices are voluminous (hundreds of pages). Reviewing the documents had to be done on line as printing was impractical. The volume, copious use of abbreviations and jargon made reviewing it extremely difficult particularly when it came to cross referencing. I had hoped that visiting the drop in display at the Town Hall would have been of help. For example, I was unable to find details in the Plan on the future population and demographics of Brentwood. On approaching a council representative I was advised this was in an attachment however they were unable to find it. It has not been an easy task reviewing the Plan.
As a resident, in North Brentwood I have seen many changes over the years as the area's population has grown.
I particularly value the open countryside (Green Belt) and strongly support its protection. I regularly walk both Weald and Thorndon Park and use the extensive public right of ways which cross the district. Although I walk into town it is not a particularly pleasant experience due to the high volume of traffic which generate high levels of noise and pollutants. Until recently I frequently cycled, however the dangerous state of the roads ( e. g pot holes) and the high volume of traffic, which is often unsympathetic to the cyclist, has restricted this activity. As a motorist I experience the usual lengthy traffic jams and hold ups which clog up Brentwood during peak times and school term. The bus service to and from town is good however it is often late due to adverse traffic conditions.

2)Population Growth and Demographics

This whole plan is has been drafted to show how Brentwood District Council intends to cater for a 15% rise in population over an 18 year period to 2030.
The population growth primarily arises through inward migration, much of which will be from London. The Plan states that the Brentwood's present population is over 73,500 with a significant level of retires - an ageing population trend projected to continue. There are over 32000 properties 76% owner occupied, 63% being detached or semi detached; 58% being 3 or 4 bedroomed, 25% 2 bedroomed.
The only forecast I could find regarding population increases were in PBA Objectively Assessed Housing Needs, Appendix B SNPP 2012 Migration. This stated ' ---- the population of Brentwood is projected to increase from 74.0k in 2012 to 85.2k in 2030'. This is an increase of 15% (11,200 people), however 7200 dwellings are to be built giving an average occupancy rate of 1.6 people per dwelling. If this correct how does this reconcile with Figure 7.1 in the Plan?
Of the projected 7200 dwellings to be built figure 7.1, states that 65% will be 1 or 2 bedroomed. Clearly this implies a dramatic change in Brentwood's environment and demographic mix however the Plan is silent on the implications for infrastructure (e. g. highways, schools, surgeries). As stated in AECOM Sustainability report, some of these are already at capacity.
The plan is also silent on the social and economic effects of this population growth on existing and 'new' residents.







3)Highway Infrastructure

Looking specifically at Ongar Road; over the years traffic volumes have vastly increased as residential properties have been build both close to the town and in the outlying villages. There has been no major structural improvements to accommodate this increased volume save for the installation of mini roundabouts and bollards - which regularly get knocked over and do not get repaired for months. This situation is typical of Brentwood district; Shenfield Road, Ingrave Road, Doddinghurst Road, London Road and other highways all have similar issues.
The Highway Modelling exercise undertaken by PBA confirms that Brentwood roads have insufficient capacity to handle today's traffic volumes. (See section 11 Summary of Junction Outputs) I believe this modelling exercise understates the true size of the problem. Two periods were analysed, 0800 to 0900 and 1700 to 1800, no account has been taken of the effect of the school term when students exit between 1500 and 1600. Why not? During that time traffic in Brentwood centre comes to a stand still, even the paths have insufficient capacity to handle pedestrians. I also note no analysis was undertaken of the M25 junction 28. From experience there are frequent, long queues of vehicles waiting to gain access to the round about.
The Sustainability Appraisal by AECOM also identifies air quality/pollution issues in North Brentwood and Brentwood centre and raised concerns regarding Shenfield.
In short - the investment in public highway infrastructure, namely roads, cycle lanes and footpaths has been totally inadequate. As more dwellings get built the situation gets worse. The district has grown significantly but the highway infrastructure has largely remained as it was over 50 years ago.
The Plan states its policies regarding sustainability however it fails to identify any significant initiatives regarding highway infrastructure which address problems associated with traffic congestion and pollution, cycling or walking. Building more dwellings without properly addressing these issues first will be to the detriment of residents well being and employment prospects in Brentwood.


4)Green Travel Route

This Plan advocates adding public transport to the already congested A127 and A128.
The A128 is a very busy, narrow trunk road carrying passenger and commercial vehicles. At present, when stopping for passengers, buses cause hold ups particularly during school times and where there are no lay-bys. Adding more buses will slow traffic and create more noise and pollution for residents close to the road.
People do cycle along the A128 however it is a dangerous exercise as drivers have difficulty in overtaking and can become impatient. A cycle path would improve the situation.
Installing a 'Green Travel Route' would be a retrograde step, adding to the existing congestion and pollution and should not be actioned.


5)Public Rights of Way (PROW)

The Plan needs to actively consider the opportunity to open up access to the surrounding countryside and parks by investing in upgrading and creating footpaths and bridleways for non vehicular use. At present access routes to both Weald and Thorndon Parks encourages the use of cars at the expense of walking and cycling. Paths which cross the A12 and A127 are dangerous and recently there has been serious accidents involving pedestrians; public are reluctant to use them. The Ordnance Survey shows 6 PROWs crossing the A127 between the M25 and the Dunton intersection. Similarly there are 4 PROWs crossing the A12 between the M25 and Ingatestone.
To the North of the A127 footpaths provide access to open spaces and in particular Thorndon Park. Access to these areas from the south (Horndon and Basildon) is only practical using a vehicle. This is not satisfactory; building bridges over the A127 that connect the footpaths would enable none vehicular traffic to safely gain access to this wonderful amenity. Likewise a bridge over the A12 would enable people to move safely between Brentwood and Shenfield and outlying communities such as Pilgrims Hatch, Kelvedon Hatch and Doddinghurst. The paths would need upgrading to take cycles.
Weald Park is only 1 -2 kilometres from Brentwood centre yet walking or cycling to it using Weald Road and Weald Park Way is dangerous as the footpaths are not continuous, the traffic volumes high and the roads are narrow and winding. The paths should be upgraded and lengthened to enable pedestrians and cyclists safe access. The same could be said for Sand Pit Lane - a footpath is sorely needed.


6)Financial

Where are the financial figures that support this Plan? How can a plan be issued proposing such massive changes without some supporting financials e.g. infrastructure investment costs, impact on the tax payer.

7)Conclusion

The expansion of Brentwood District by over 20% through building 7200 new dwellings while increasing the population by over 15% (11,200 people) will have a dramatic effect on all aspects of life in Brentwood - social, environmental, commercial. It will change the nature and character of the area. Little demographic information is provided on who the new comers are and what their needs will be in addition to housing. It is hard to determine what benefit, if any, this expansion will have to present residents.
The draft plan is describes the proposed location of houses and the build schedule however I have major concerns over the need to upgrade Brentwood's infrastructure. My fear is the investment will not be forthcoming and policies relating to 'sustainability' will not be achieved. If that happens Brentwood will be a poorer place to live and work.

Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

I am pleased to have the opportunity to respond to the Brentwood Borough Draft Local Development Plan.
The Plan and the attachments and appendices are voluminous (hundreds of pages). Reviewing the documents had to be done on line as printing was impractical. The volume, copious use of abbreviations and jargon made reviewing it extremely difficult particularly when it came to cross referencing. I had hoped that visiting the drop in display at the Town Hall would have been of help. For example, I was unable to find details in the Plan on the future population and demographics of Brentwood. On approaching a council representative I was advised this was in an attachment however they were unable to find it. It has not been an easy task reviewing the Plan.
As a resident, in North Brentwood I have seen many changes over the years as the area's population has grown.
I particularly value the open countryside (Green Belt) and strongly support its protection. I regularly walk both Weald and Thorndon Park and use the extensive public right of ways which cross the district. Although I walk into town it is not a particularly pleasant experience due to the high volume of traffic which generate high levels of noise and pollutants. Until recently I frequently cycled, however the dangerous state of the roads ( e. g pot holes) and the high volume of traffic, which is often unsympathetic to the cyclist, has restricted this activity. As a motorist I experience the usual lengthy traffic jams and hold ups which clog up Brentwood during peak times and school term. The bus service to and from town is good however it is often late due to adverse traffic conditions.

2)Population Growth and Demographics

This whole plan is has been drafted to show how Brentwood District Council intends to cater for a 15% rise in population over an 18 year period to 2030.
The population growth primarily arises through inward migration, much of which will be from London. The Plan states that the Brentwood's present population is over 73,500 with a significant level of retires - an ageing population trend projected to continue. There are over 32000 properties 76% owner occupied, 63% being detached or semi detached; 58% being 3 or 4 bedroomed, 25% 2 bedroomed.
The only forecast I could find regarding population increases were in PBA Objectively Assessed Housing Needs, Appendix B SNPP 2012 Migration. This stated ' ---- the population of Brentwood is projected to increase from 74.0k in 2012 to 85.2k in 2030'. This is an increase of 15% (11,200 people), however 7200 dwellings are to be built giving an average occupancy rate of 1.6 people per dwelling. If this correct how does this reconcile with Figure 7.1 in the Plan?
Of the projected 7200 dwellings to be built figure 7.1, states that 65% will be 1 or 2 bedroomed. Clearly this implies a dramatic change in Brentwood's environment and demographic mix however the Plan is silent on the implications for infrastructure (e. g. highways, schools, surgeries). As stated in AECOM Sustainability report, some of these are already at capacity.
The plan is also silent on the social and economic effects of this population growth on existing and 'new' residents.







3)Highway Infrastructure

Looking specifically at Ongar Road; over the years traffic volumes have vastly increased as residential properties have been build both close to the town and in the outlying villages. There has been no major structural improvements to accommodate this increased volume save for the installation of mini roundabouts and bollards - which regularly get knocked over and do not get repaired for months. This situation is typical of Brentwood district; Shenfield Road, Ingrave Road, Doddinghurst Road, London Road and other highways all have similar issues.
The Highway Modelling exercise undertaken by PBA confirms that Brentwood roads have insufficient capacity to handle today's traffic volumes. (See section 11 Summary of Junction Outputs) I believe this modelling exercise understates the true size of the problem. Two periods were analysed, 0800 to 0900 and 1700 to 1800, no account has been taken of the effect of the school term when students exit between 1500 and 1600. Why not? During that time traffic in Brentwood centre comes to a stand still, even the paths have insufficient capacity to handle pedestrians. I also note no analysis was undertaken of the M25 junction 28. From experience there are frequent, long queues of vehicles waiting to gain access to the round about.
The Sustainability Appraisal by AECOM also identifies air quality/pollution issues in North Brentwood and Brentwood centre and raised concerns regarding Shenfield.
In short - the investment in public highway infrastructure, namely roads, cycle lanes and footpaths has been totally inadequate. As more dwellings get built the situation gets worse. The district has grown significantly but the highway infrastructure has largely remained as it was over 50 years ago.
The Plan states its policies regarding sustainability however it fails to identify any significant initiatives regarding highway infrastructure which address problems associated with traffic congestion and pollution, cycling or walking. Building more dwellings without properly addressing these issues first will be to the detriment of residents well being and employment prospects in Brentwood.


4)Green Travel Route

This Plan advocates adding public transport to the already congested A127 and A128.
The A128 is a very busy, narrow trunk road carrying passenger and commercial vehicles. At present, when stopping for passengers, buses cause hold ups particularly during school times and where there are no lay-bys. Adding more buses will slow traffic and create more noise and pollution for residents close to the road.
People do cycle along the A128 however it is a dangerous exercise as drivers have difficulty in overtaking and can become impatient. A cycle path would improve the situation.
Installing a 'Green Travel Route' would be a retrograde step, adding to the existing congestion and pollution and should not be actioned.


5)Public Rights of Way (PROW)

The Plan needs to actively consider the opportunity to open up access to the surrounding countryside and parks by investing in upgrading and creating footpaths and bridleways for non vehicular use. At present access routes to both Weald and Thorndon Parks encourages the use of cars at the expense of walking and cycling. Paths which cross the A12 and A127 are dangerous and recently there has been serious accidents involving pedestrians; public are reluctant to use them. The Ordnance Survey shows 6 PROWs crossing the A127 between the M25 and the Dunton intersection. Similarly there are 4 PROWs crossing the A12 between the M25 and Ingatestone.
To the North of the A127 footpaths provide access to open spaces and in particular Thorndon Park. Access to these areas from the south (Horndon and Basildon) is only practical using a vehicle. This is not satisfactory; building bridges over the A127 that connect the footpaths would enable none vehicular traffic to safely gain access to this wonderful amenity. Likewise a bridge over the A12 would enable people to move safely between Brentwood and Shenfield and outlying communities such as Pilgrims Hatch, Kelvedon Hatch and Doddinghurst. The paths would need upgrading to take cycles.
Weald Park is only 1 -2 kilometres from Brentwood centre yet walking or cycling to it using Weald Road and Weald Park Way is dangerous as the footpaths are not continuous, the traffic volumes high and the roads are narrow and winding. The paths should be upgraded and lengthened to enable pedestrians and cyclists safe access. The same could be said for Sand Pit Lane - a footpath is sorely needed.


6)Financial

Where are the financial figures that support this Plan? How can a plan be issued proposing such massive changes without some supporting financials e.g. infrastructure investment costs, impact on the tax payer.

7)Conclusion

The expansion of Brentwood District by over 20% through building 7200 new dwellings while increasing the population by over 15% (11,200 people) will have a dramatic effect on all aspects of life in Brentwood - social, environmental, commercial. It will change the nature and character of the area. Little demographic information is provided on who the new comers are and what their needs will be in addition to housing. It is hard to determine what benefit, if any, this expansion will have to present residents.
The draft plan is describes the proposed location of houses and the build schedule however I have major concerns over the need to upgrade Brentwood's infrastructure. My fear is the investment will not be forthcoming and policies relating to 'sustainability' will not be achieved. If that happens Brentwood will be a poorer place to live and work.

Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

I am pleased to have the opportunity to respond to the Brentwood Borough Draft Local Development Plan.
The Plan and the attachments and appendices are voluminous (hundreds of pages). Reviewing the documents had to be done on line as printing was impractical. The volume, copious use of abbreviations and jargon made reviewing it extremely difficult particularly when it came to cross referencing. I had hoped that visiting the drop in display at the Town Hall would have been of help. For example, I was unable to find details in the Plan on the future population and demographics of Brentwood. On approaching a council representative I was advised this was in an attachment however they were unable to find it. It has not been an easy task reviewing the Plan.
As a resident, in North Brentwood I have seen many changes over the years as the area's population has grown.
I particularly value the open countryside (Green Belt) and strongly support its protection. I regularly walk both Weald and Thorndon Park and use the extensive public right of ways which cross the district. Although I walk into town it is not a particularly pleasant experience due to the high volume of traffic which generate high levels of noise and pollutants. Until recently I frequently cycled, however the dangerous state of the roads ( e. g pot holes) and the high volume of traffic, which is often unsympathetic to the cyclist, has restricted this activity. As a motorist I experience the usual lengthy traffic jams and hold ups which clog up Brentwood during peak times and school term. The bus service to and from town is good however it is often late due to adverse traffic conditions.

2)Population Growth and Demographics

This whole plan is has been drafted to show how Brentwood District Council intends to cater for a 15% rise in population over an 18 year period to 2030.
The population growth primarily arises through inward migration, much of which will be from London. The Plan states that the Brentwood's present population is over 73,500 with a significant level of retires - an ageing population trend projected to continue. There are over 32000 properties 76% owner occupied, 63% being detached or semi detached; 58% being 3 or 4 bedroomed, 25% 2 bedroomed.
The only forecast I could find regarding population increases were in PBA Objectively Assessed Housing Needs, Appendix B SNPP 2012 Migration. This stated ' ---- the population of Brentwood is projected to increase from 74.0k in 2012 to 85.2k in 2030'. This is an increase of 15% (11,200 people), however 7200 dwellings are to be built giving an average occupancy rate of 1.6 people per dwelling. If this correct how does this reconcile with Figure 7.1 in the Plan?
Of the projected 7200 dwellings to be built figure 7.1, states that 65% will be 1 or 2 bedroomed. Clearly this implies a dramatic change in Brentwood's environment and demographic mix however the Plan is silent on the implications for infrastructure (e. g. highways, schools, surgeries). As stated in AECOM Sustainability report, some of these are already at capacity.
The plan is also silent on the social and economic effects of this population growth on existing and 'new' residents.







3)Highway Infrastructure

Looking specifically at Ongar Road; over the years traffic volumes have vastly increased as residential properties have been build both close to the town and in the outlying villages. There has been no major structural improvements to accommodate this increased volume save for the installation of mini roundabouts and bollards - which regularly get knocked over and do not get repaired for months. This situation is typical of Brentwood district; Shenfield Road, Ingrave Road, Doddinghurst Road, London Road and other highways all have similar issues.
The Highway Modelling exercise undertaken by PBA confirms that Brentwood roads have insufficient capacity to handle today's traffic volumes. (See section 11 Summary of Junction Outputs) I believe this modelling exercise understates the true size of the problem. Two periods were analysed, 0800 to 0900 and 1700 to 1800, no account has been taken of the effect of the school term when students exit between 1500 and 1600. Why not? During that time traffic in Brentwood centre comes to a stand still, even the paths have insufficient capacity to handle pedestrians. I also note no analysis was undertaken of the M25 junction 28. From experience there are frequent, long queues of vehicles waiting to gain access to the round about.
The Sustainability Appraisal by AECOM also identifies air quality/pollution issues in North Brentwood and Brentwood centre and raised concerns regarding Shenfield.
In short - the investment in public highway infrastructure, namely roads, cycle lanes and footpaths has been totally inadequate. As more dwellings get built the situation gets worse. The district has grown significantly but the highway infrastructure has largely remained as it was over 50 years ago.
The Plan states its policies regarding sustainability however it fails to identify any significant initiatives regarding highway infrastructure which address problems associated with traffic congestion and pollution, cycling or walking. Building more dwellings without properly addressing these issues first will be to the detriment of residents well being and employment prospects in Brentwood.


4)Green Travel Route

This Plan advocates adding public transport to the already congested A127 and A128.
The A128 is a very busy, narrow trunk road carrying passenger and commercial vehicles. At present, when stopping for passengers, buses cause hold ups particularly during school times and where there are no lay-bys. Adding more buses will slow traffic and create more noise and pollution for residents close to the road.
People do cycle along the A128 however it is a dangerous exercise as drivers have difficulty in overtaking and can become impatient. A cycle path would improve the situation.
Installing a 'Green Travel Route' would be a retrograde step, adding to the existing congestion and pollution and should not be actioned.


5)Public Rights of Way (PROW)

The Plan needs to actively consider the opportunity to open up access to the surrounding countryside and parks by investing in upgrading and creating footpaths and bridleways for non vehicular use. At present access routes to both Weald and Thorndon Parks encourages the use of cars at the expense of walking and cycling. Paths which cross the A12 and A127 are dangerous and recently there has been serious accidents involving pedestrians; public are reluctant to use them. The Ordnance Survey shows 6 PROWs crossing the A127 between the M25 and the Dunton intersection. Similarly there are 4 PROWs crossing the A12 between the M25 and Ingatestone.
To the North of the A127 footpaths provide access to open spaces and in particular Thorndon Park. Access to these areas from the south (Horndon and Basildon) is only practical using a vehicle. This is not satisfactory; building bridges over the A127 that connect the footpaths would enable none vehicular traffic to safely gain access to this wonderful amenity. Likewise a bridge over the A12 would enable people to move safely between Brentwood and Shenfield and outlying communities such as Pilgrims Hatch, Kelvedon Hatch and Doddinghurst. The paths would need upgrading to take cycles.
Weald Park is only 1 -2 kilometres from Brentwood centre yet walking or cycling to it using Weald Road and Weald Park Way is dangerous as the footpaths are not continuous, the traffic volumes high and the roads are narrow and winding. The paths should be upgraded and lengthened to enable pedestrians and cyclists safe access. The same could be said for Sand Pit Lane - a footpath is sorely needed.


6)Financial

Where are the financial figures that support this Plan? How can a plan be issued proposing such massive changes without some supporting financials e.g. infrastructure investment costs, impact on the tax payer.

7)Conclusion

The expansion of Brentwood District by over 20% through building 7200 new dwellings while increasing the population by over 15% (11,200 people) will have a dramatic effect on all aspects of life in Brentwood - social, environmental, commercial. It will change the nature and character of the area. Little demographic information is provided on who the new comers are and what their needs will be in addition to housing. It is hard to determine what benefit, if any, this expansion will have to present residents.
The draft plan is describes the proposed location of houses and the build schedule however I have major concerns over the need to upgrade Brentwood's infrastructure. My fear is the investment will not be forthcoming and policies relating to 'sustainability' will not be achieved. If that happens Brentwood will be a poorer place to live and work.

Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

I am pleased to have the opportunity to respond to the Brentwood Borough Draft Local Development Plan.
The Plan and the attachments and appendices are voluminous (hundreds of pages). Reviewing the documents had to be done on line as printing was impractical. The volume, copious use of abbreviations and jargon made reviewing it extremely difficult particularly when it came to cross referencing. I had hoped that visiting the drop in display at the Town Hall would have been of help. For example, I was unable to find details in the Plan on the future population and demographics of Brentwood. On approaching a council representative I was advised this was in an attachment however they were unable to find it. It has not been an easy task reviewing the Plan.
As a resident, in North Brentwood I have seen many changes over the years as the area's population has grown.
I particularly value the open countryside (Green Belt) and strongly support its protection. I regularly walk both Weald and Thorndon Park and use the extensive public right of ways which cross the district. Although I walk into town it is not a particularly pleasant experience due to the high volume of traffic which generate high levels of noise and pollutants. Until recently I frequently cycled, however the dangerous state of the roads ( e. g pot holes) and the high volume of traffic, which is often unsympathetic to the cyclist, has restricted this activity. As a motorist I experience the usual lengthy traffic jams and hold ups which clog up Brentwood during peak times and school term. The bus service to and from town is good however it is often late due to adverse traffic conditions.

2)Population Growth and Demographics

This whole plan is has been drafted to show how Brentwood District Council intends to cater for a 15% rise in population over an 18 year period to 2030.
The population growth primarily arises through inward migration, much of which will be from London. The Plan states that the Brentwood's present population is over 73,500 with a significant level of retires - an ageing population trend projected to continue. There are over 32000 properties 76% owner occupied, 63% being detached or semi detached; 58% being 3 or 4 bedroomed, 25% 2 bedroomed.
The only forecast I could find regarding population increases were in PBA Objectively Assessed Housing Needs, Appendix B SNPP 2012 Migration. This stated ' ---- the population of Brentwood is projected to increase from 74.0k in 2012 to 85.2k in 2030'. This is an increase of 15% (11,200 people), however 7200 dwellings are to be built giving an average occupancy rate of 1.6 people per dwelling. If this correct how does this reconcile with Figure 7.1 in the Plan?
Of the projected 7200 dwellings to be built figure 7.1, states that 65% will be 1 or 2 bedroomed. Clearly this implies a dramatic change in Brentwood's environment and demographic mix however the Plan is silent on the implications for infrastructure (e. g. highways, schools, surgeries). As stated in AECOM Sustainability report, some of these are already at capacity.
The plan is also silent on the social and economic effects of this population growth on existing and 'new' residents.







3)Highway Infrastructure

Looking specifically at Ongar Road; over the years traffic volumes have vastly increased as residential properties have been build both close to the town and in the outlying villages. There has been no major structural improvements to accommodate this increased volume save for the installation of mini roundabouts and bollards - which regularly get knocked over and do not get repaired for months. This situation is typical of Brentwood district; Shenfield Road, Ingrave Road, Doddinghurst Road, London Road and other highways all have similar issues.
The Highway Modelling exercise undertaken by PBA confirms that Brentwood roads have insufficient capacity to handle today's traffic volumes. (See section 11 Summary of Junction Outputs) I believe this modelling exercise understates the true size of the problem. Two periods were analysed, 0800 to 0900 and 1700 to 1800, no account has been taken of the effect of the school term when students exit between 1500 and 1600. Why not? During that time traffic in Brentwood centre comes to a stand still, even the paths have insufficient capacity to handle pedestrians. I also note no analysis was undertaken of the M25 junction 28. From experience there are frequent, long queues of vehicles waiting to gain access to the round about.
The Sustainability Appraisal by AECOM also identifies air quality/pollution issues in North Brentwood and Brentwood centre and raised concerns regarding Shenfield.
In short - the investment in public highway infrastructure, namely roads, cycle lanes and footpaths has been totally inadequate. As more dwellings get built the situation gets worse. The district has grown significantly but the highway infrastructure has largely remained as it was over 50 years ago.
The Plan states its policies regarding sustainability however it fails to identify any significant initiatives regarding highway infrastructure which address problems associated with traffic congestion and pollution, cycling or walking. Building more dwellings without properly addressing these issues first will be to the detriment of residents well being and employment prospects in Brentwood.


4)Green Travel Route

This Plan advocates adding public transport to the already congested A127 and A128.
The A128 is a very busy, narrow trunk road carrying passenger and commercial vehicles. At present, when stopping for passengers, buses cause hold ups particularly during school times and where there are no lay-bys. Adding more buses will slow traffic and create more noise and pollution for residents close to the road.
People do cycle along the A128 however it is a dangerous exercise as drivers have difficulty in overtaking and can become impatient. A cycle path would improve the situation.
Installing a 'Green Travel Route' would be a retrograde step, adding to the existing congestion and pollution and should not be actioned.


5)Public Rights of Way (PROW)

The Plan needs to actively consider the opportunity to open up access to the surrounding countryside and parks by investing in upgrading and creating footpaths and bridleways for non vehicular use. At present access routes to both Weald and Thorndon Parks encourages the use of cars at the expense of walking and cycling. Paths which cross the A12 and A127 are dangerous and recently there has been serious accidents involving pedestrians; public are reluctant to use them. The Ordnance Survey shows 6 PROWs crossing the A127 between the M25 and the Dunton intersection. Similarly there are 4 PROWs crossing the A12 between the M25 and Ingatestone.
To the North of the A127 footpaths provide access to open spaces and in particular Thorndon Park. Access to these areas from the south (Horndon and Basildon) is only practical using a vehicle. This is not satisfactory; building bridges over the A127 that connect the footpaths would enable none vehicular traffic to safely gain access to this wonderful amenity. Likewise a bridge over the A12 would enable people to move safely between Brentwood and Shenfield and outlying communities such as Pilgrims Hatch, Kelvedon Hatch and Doddinghurst. The paths would need upgrading to take cycles.
Weald Park is only 1 -2 kilometres from Brentwood centre yet walking or cycling to it using Weald Road and Weald Park Way is dangerous as the footpaths are not continuous, the traffic volumes high and the roads are narrow and winding. The paths should be upgraded and lengthened to enable pedestrians and cyclists safe access. The same could be said for Sand Pit Lane - a footpath is sorely needed.


6)Financial

Where are the financial figures that support this Plan? How can a plan be issued proposing such massive changes without some supporting financials e.g. infrastructure investment costs, impact on the tax payer.

7)Conclusion

The expansion of Brentwood District by over 20% through building 7200 new dwellings while increasing the population by over 15% (11,200 people) will have a dramatic effect on all aspects of life in Brentwood - social, environmental, commercial. It will change the nature and character of the area. Little demographic information is provided on who the new comers are and what their needs will be in addition to housing. It is hard to determine what benefit, if any, this expansion will have to present residents.
The draft plan is describes the proposed location of houses and the build schedule however I have major concerns over the need to upgrade Brentwood's infrastructure. My fear is the investment will not be forthcoming and policies relating to 'sustainability' will not be achieved. If that happens Brentwood will be a poorer place to live and work.

1. Essex Fire Service HQ Rayleigh Rd
.I submit that the allocation of 50 units to this site cannot be justified for the following reasons:

1.1 Para 5.42 of the Plan states that you have applied densities in a realistic manner taking in surrounding development and general form of an area
The only basis on which the site could accommodate 50 dwellings would be for even more flats, possibly with more floors, than the present outline application for 44 dwellings. This would not take into account "surrounding development and general form of an area" as the site is surrounded by detached houses and is bordered on Rayleigh Rd mainly by large detached houses.

1.2 Appendix 2 - "Housing and Employment Delivery" shows that you have applied a density of 40 dwellings per hectare to this site and used the site area of 1.26 hectares to arrive at the estimate of 50 I would challenge the use of 40 per hectare as it would conflict directly with several of the policies in the Plan as follows:

a) Policy 7.3 states:
"Proposals for new residential development should take a design led approach to density which ensures schemes are sympathetic to local character and make efficient use of land.
Residential densities will be expected to be 30 dwellings per hectare net or higher unless the special character of the surrounding area suggests that such densities would be inappropriate; or where other site constraints make such densities unachievable."
It would be inappropriate to apply even 30 because the site has a very large number of trees which make anything higher "unachievable", particularly to meet the first para of 7.3 in terms of "sympathy to local character"

b) This number of dwellings could not be accommodated within the terms of Policy 6.3 a) "have no unacceptable effect on visual amenity, the character or appearance of the surrounding area;" and e). "cause no unacceptable effects on adjoining sites,by overlooking or visual intrusion; harm to or loss of outlook, privacy
c) It would be in direct contradiction of point 6.16 under General Development Planning in particular overlooking neighbouring properties and being sympathetic to the character and form of neighbouring properties." New development should be sympathetic to the character and form of neighbouring properties and surroundings
d) This is repeated again in Policy 6.4 d "safeguard the amenities of occupiers or any nearby properties by ensuring that their character and appearance is sensitive to the context and surroundings."

2. Housing Types
The Strategic Housing Market Assessment lacks the credibility to determine such an important aspect of housing policy, namely that 65% of future dwellings should be 1 or 2 bedroom flats, for the following reasons:
a)It is based on responses from only 3% of all properties in Brentwood.
b)It is based on an old survey in June 2013 where people were asked, among other things, whether they wanted to move and when.
No attempt has been made to get actual data to compare with intentions from people who said they aimed to move in the three years from mid 2013. 51% of them at least should have moved by now so we really need to know whether they did or did not and where they moved to.
c) Much of the demand for flats comes from "Concealed Householders" i.e. those living with parents/family at present. Their main reasons for wanting to buy a flat in the borough were either that they wanted to live near family and friends, or that they have always lived in the area.
Whilst it would be nice to be able to satisfy these wishes for everybody, many people who now own their own houses accepted that they might have to move away from their home turf to possibly cheaper areas to gain their independence.
The survey makes it clear(Table 6-2) that local prices for one bed flats are out of reach of the incomes of over 80% of concealed households yet the strategy states that the main areas people want live are Brentwood and Shenfield, which are the most expensive areas. It seems illogical therefore to plan to build so many flats in these areas
One possible outcome is that there will be insufficient demand for all of these flats and that developers will therefore not be interested in investing in such developments unless a more balanced approach to housing types is adopted.

1. Essex Fire Service HQ Rayleigh Rd
.I submit that the allocation of 50 units to this site cannot be justified for the following reasons:

1.1 Para 5.42 of the Plan states that you have applied densities in a realistic manner taking in surrounding development and general form of an area
The only basis on which the site could accommodate 50 dwellings would be for even more flats, possibly with more floors, than the present outline application for 44 dwellings. This would not take into account "surrounding development and general form of an area" as the site is surrounded by detached houses and is bordered on Rayleigh Rd mainly by large detached houses.

1.2 Appendix 2 - "Housing and Employment Delivery" shows that you have applied a density of 40 dwellings per hectare to this site and used the site area of 1.26 hectares to arrive at the estimate of 50 I would challenge the use of 40 per hectare as it would conflict directly with several of the policies in the Plan as follows:

a) Policy 7.3 states:
"Proposals for new residential development should take a design led approach to density which ensures schemes are sympathetic to local character and make efficient use of land.
Residential densities will be expected to be 30 dwellings per hectare net or higher unless the special character of the surrounding area suggests that such densities would be inappropriate; or where other site constraints make such densities unachievable."
It would be inappropriate to apply even 30 because the site has a very large number of trees which make anything higher "unachievable", particularly to meet the first para of 7.3 in terms of "sympathy to local character"

b) This number of dwellings could not be accommodated within the terms of Policy 6.3 a) "have no unacceptable effect on visual amenity, the character or appearance of the surrounding area;" and e). "cause no unacceptable effects on adjoining sites,by overlooking or visual intrusion; harm to or loss of outlook, privacy
c) It would be in direct contradiction of point 6.16 under General Development Planning in particular overlooking neighbouring properties and being sympathetic to the character and form of neighbouring properties." New development should be sympathetic to the character and form of neighbouring properties and surroundings
d) This is repeated again in Policy 6.4 d "safeguard the amenities of occupiers or any nearby properties by ensuring that their character and appearance is sensitive to the context and surroundings."

2. Housing Types
The Strategic Housing Market Assessment lacks the credibility to determine such an important aspect of housing policy, namely that 65% of future dwellings should be 1 or 2 bedroom flats, for the following reasons:
a)It is based on responses from only 3% of all properties in Brentwood.
b)It is based on an old survey in June 2013 where people were asked, among other things, whether they wanted to move and when.
No attempt has been made to get actual data to compare with intentions from people who said they aimed to move in the three years from mid 2013. 51% of them at least should have moved by now so we really need to know whether they did or did not and where they moved to.
c) Much of the demand for flats comes from "Concealed Householders" i.e. those living with parents/family at present. Their main reasons for wanting to buy a flat in the borough were either that they wanted to live near family and friends, or that they have always lived in the area.
Whilst it would be nice to be able to satisfy these wishes for everybody, many people who now own their own houses accepted that they might have to move away from their home turf to possibly cheaper areas to gain their independence.
The survey makes it clear(Table 6-2) that local prices for one bed flats are out of reach of the incomes of over 80% of concealed households yet the strategy states that the main areas people want live are Brentwood and Shenfield, which are the most expensive areas. It seems illogical therefore to plan to build so many flats in these areas
One possible outcome is that there will be insufficient demand for all of these flats and that developers will therefore not be interested in investing in such developments unless a more balanced approach to housing types is adopted.

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