Object

Representation ID: 15360

Received: 06/05/2016

Respondent: Maylands Green Estate Co. Ltd

Agent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15377

Received: 06/05/2016

Respondent: Maylands Green Estate Co. Ltd

Agent: JTS Partnership LLP

It is evident 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.

Object

Representation ID: 15380

Received: 06/05/2016

Respondent: Robert Mulholland & Co Ltd

Agent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15396

Received: 06/05/2016

Respondent: Robert Mulholland & Co Ltd

Agent: JTS Partnership LLP

It is evident 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.

Object

Representation ID: 15408

Received: 06/05/2016

Respondent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15425

Received: 06/05/2016

Respondent: JTS Partnership LLP

It is evident 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.

Object

Representation ID: 15469

Received: 09/05/2016

Respondent: Mr Martin Morecroft

Agent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Object

Representation ID: 15485

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15534

Received: 24/03/2016

Respondent: Greater London Authority

The Council's most recent evidence is focusing on the tightly defined area of the Borough despite significant interrelationships with its neighbours including London. These are demonstrated in particular through the significant proportion of commuting into the capital (almost 15,000 per day). This underscores the importance of collaboration and the Duty to Co-operate.

Object

Representation ID: 15563

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15592

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

It is evident 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.

Object

Representation ID: 15609

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

Comment

Representation ID: 15618

Received: 10/05/2016

Respondent: Basildon Borough Council

Brentwood Borough intends to meet its objectively assessed housing need (OAN) inline with the 2014 OAN document within the Brentwood Borough boundary. We supports this approach to housing growth. However, the OAN report was produced prior to the release of the 2012 sub national population projections (2012 SNPP), or the more recently published 2012 based CLG Household Projections. The Planning Practice Guidance is clear that these more recent projections should form the starting point for calculating the OAN for housing in an area. Additionally, the calculations of OAN has not given consideration to changing patterns of out-migration from London, which could reasonably be expected to be considered in any sensitivity testing of demographic forecasts, in those areas surrounding London. Changing migration patterns could seriously impact on the need for housing within Brentwood Borough going forward. Brentwood Borough Council should carry out further work to re-assess the OAN to include these projections, and should the need for housing change in light of this, Brentwood Borough Council should seek to revise the target accordingly and to continue to fully meet their OAN.

Object

Representation ID: 15624

Received: 10/05/2016

Respondent: Basildon Borough Council

The recently published evidence (Assessment of Potential Housing, Employment and Mixed Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation - March 2016) states that 'An update to the 2014 SHMA is currently being undertaken by the Council in light of subsequent amendments in national policy guidance'. This suggests that Brentwood Borough Council recognise the deficiencies in their evidence regarding the objectively assessed need for housing in their borough, and it is therefore expected that the matters raised above will be resolved prior to the Brentwood Local Plan being progressed to submission. Basildon Borough Council would be pleased to be engaged and kept informed of the progress with this work as it is progressed.

Object

Representation ID: 15625

Received: 10/05/2016

Respondent: Basildon Borough Council

Work on the South Essex Strategic Housing Market Assessment has included a re-assessment of the South Essex Housing Market Area to ensure it is still appropriately defined. In defining Brentwood as a single housing market area, the current Brentwood SHMA does state that 'data suggests that Brentwood shares a housing market area with Chelmsford and Basildon and to a smaller extent Epping'. It therefore recognises that overlaps with surrounding housing market areas exist. As the proposals within the Brentwood Draft Local Plan propose a strategic housing site for 2,500 homes within close proximity of the Borough boundary shared with Basildon Borough Council, there may be implications for the future definitions of the Brentwood and South Essex housing market areas, which need to be given further consideration as the Brentwood Local Plan is progressed towards submission. Basildon Borough Council would be pleased to be engaged in such work in order to understand the implications this proposal would have for both the Brentwood and South Essex housing markets, and the extent to which development in this location would meet the needs arising from both housing market areas.

Comment

Representation ID: 15626

Received: 10/05/2016

Respondent: Basildon Borough Council

Past windfall trends for Brentwood Borough Council has accounted for 77 homes pa. Brentwood Borough Council have stated within their Draft Local Plan that this level of supply will continue into the future providing 928 homes over the plan period. However, there is no evidence that supports the ongoing supply of homes at this rate from windfall sites. In line with Government guidance, Brentwood Borough Council must provide compelling evidence that such windfall sites have consistently become available in the local area, and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens. Supply from windfall sites should also be split down into categories to identify where the provision could arise from.

Object

Representation ID: 15627

Received: 10/05/2016

Respondent: Basildon Borough Council

In relation to identified housing land supply, it would appear from the evidence base that Brentwood Borough Council has not carried out a Strategic Housing Land Availability Assessment (SHLAA) since 2011. Basildon Borough Council made it clear in its response to Brentwood Borough Council regarding the Brentwood Borough's Local Plan Strategic Growth Options in early 2015 that it would expect the SHLAA to be updated before a Local Plan for Brentwood is progressed. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments to help inform the emerging 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. It is not clear how any of the proposed housing sites included in the Draft Local Plan have been put forward and how the sites are justified as suitable without crucial supporting evidence which is missing including recent landscaping, ecology and open space evidence.

Object

Representation ID: 15643

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council are generally supportive of the approach Brentwood has taken to identifying its employment land and job requirements. However, it is noted that the evidence only looks to 2030. Consideration should be given, at the least to annualising the employment requirement for the remainder of the plan period, or else looking to update the evidence base regarding employment and retail needs to cover the remainder of the plan period.

Object

Representation ID: 15647

Received: 10/05/2016

Respondent: Basildon Borough Council

Brentwood Borough Council has produced a draft Development Options - Highway Modelling. This was done by independent transport consultants and it is not clear how Essex County Council, as the local highways authority was engaged in the modelling process. Consequently, Basildon Borough Council has concerns with regards to the way in which the modelling takes into account planned growth in neighbouring authorities, or planned improvements/changes to the current highway network. Furthermore, whilst the document looks at the changes in junction capacity arising from the four development options tested, it does not look at ways to mitigate the impacts of the development proposed in the Draft Local Plan.

Object

Representation ID: 15648

Received: 10/05/2016

Respondent: Basildon Borough Council

Given that Brentwood Borough Council are looking to focus development around the key transport routes, including the A127 which runs through Basildon, it is important to understand the resulting effect any development along the A127 corridor would have on the Basildon Borough. Further work by Brentwood Borough Council needs to be undertaken to assess this.

Object

Representation ID: 15651

Received: 10/05/2016

Respondent: Basildon Borough Council

It would appear from the information given within the Brentwood Borough Council Draft Local Plan that consultations with the NHS into healthcare facilities were carried out prior to detailed locations of development being identified. Therefore consideration to the proximity to the Basildon Borough and the shared facilities has not been fully considered and would need to be if development were to go ahead at Dunton Hills Garden Village.

Object

Representation ID: 15652

Received: 10/05/2016

Respondent: Basildon Borough Council

The detail given in relation to schools also appears to be general and does not specifically detail the future requirements based on the development locations proposed. This would need to be evidenced further. Public transport requirements and discussions with Essex County Council are also stated as ongoing.

Object

Representation ID: 15653

Received: 10/05/2016

Respondent: Basildon Borough Council

Given that Brentwood Borough Council are proposing development adjacent the Basildon Borough Boundary, and considering some existing services are already shared, e.g. hospital and schools, it is considered essential for Brentwood Borough Council to work with Basildon Borough Council to determine the impacts such development proposals may have on infrastructure and services in the Basildon Borough and how development options of this nature may need to support the upgrade of services and facilities in Basildon Borough should the Council continue to favour them through the Local Plan. At this time, Basildon Borough Council does not feel that enough work has been carried out to determine the relevant infrastructure requirements for the Brentwood Borough growth.

Object

Representation ID: 15659

Received: 10/05/2016

Respondent: Basildon Borough Council

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.

Object

Representation ID: 15661

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council are disappointed that there is still a significant evidence base gap which has not been addressed following our last consultation response. The lack of evidence is felt to be a fundamental flaw to the Brentwood Borough Draft Local Plan. Basildon Borough Council therefore considers that the Brentwood Borough Draft Local Plan requires further work and that it is premature of a clear appreciation and understanding of the baseline context in the Brentwood Borough and the wider Essex area. It is difficult to see how the Draft Local Plan can be taken forward without the necessary evidence base having informed its development.

Comment

Representation ID: 15702

Received: 10/05/2016

Respondent: S & J Padfield and Partners

Agent: Strutt & Parker LLP

The Assessment of Sites in the Green Belt report prepared by Crestwood Environmental has now been published by the Council. This report, however, was not available at the start of the consultation period. We welcome the findings that the towns would not coalesce if site was developed and that the site presently has limited or no countryside function.

The land at Codham Hall appears to have been considered within two parts. This does not reflect the current area for allocation as proposed in Figure 8.2 or the 'Site Allocations Maps'. There is presently inconsistency in these areas and it is essential that changes are made to accurate reflect the area of existing uses on site.

Comment

Representation ID: 15729

Received: 11/05/2016

Respondent: National Highways

As you know, in 2014 we were consulted by you and made comments on your suggested approach to the transport assessment for your Local Plan at that time. We have not heard further to this time any more details of an assessment but assume that you will still be undertaking such an assessment. We look forward to receiving your full Local Plan transport assessment in due course. Should you require further advice on transport related issues please do not hesitate to contact us.

Comment

Representation ID: 15749

Received: 11/05/2016

Respondent: Essex County Council

An Infrastructure Delivery Plan (IDP) will need to be prepared and ECC is keen to assist BBC in the preparation of the IDP. An Infrastructure Delivery Plan (IDP) will need to be prepared to support the emerging Brentwood Local Plan, and identify infrastructure required. The Local Plan should make clear, for at least the first five years, what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development. For the later stages of the plan period less detail may be provided.
As a provider of key services and subject to statutory responsibilities ECC is keen to assist the Borough Council in the preparation of the IDP.

Object

Representation ID: 15768

Received: 11/05/2016

Respondent: National Highways

Whilst we broadly agree with the approach to funding transport infrastructure outlined within the LP, through the pooling of contributions secured through Planning Obligations and, once adopted, the Council's Community Infrastructure Levy Charging Schedule (CIL), further details of the specific infrastructure schemes that may be required to support development across the Borough are not provided within the LP at this stage. Furthermore, an Infrastructure Delivery Plan (IDP) has not been prepared to accompany the LP and without this I can see the plan being challenged.

Object

Representation ID: 15769

Received: 11/05/2016

Respondent: Persimmon Homes Essex

Disagree with the SHMA's conclusion that Brentwood Borough can be considered a self-contained housing market area. Brentwood is within easy access to London and the M25 making it a popular place for commuters, especially with the coming of Crossrail. This should be considered in determining housing needs in the borough. With London not being able to meet its housing needs, the surrounding area will be required to make up this shortfall. Brentwood Council need to consider the implication of the projected shortfall in housing delivery in the GLA. The inclusion of reserved sites can assist in case the OANs change or the Council cannot demonstrate the 5year housing land supply.