Comment

Representation ID: 15909

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

It is imperative that a full Green Belt review is undertaken to identify additional sites that could be considered for release in the medium and longer term.

Comment

Representation ID: 15910

Received: 11/05/2016

Respondent: Essex County Council

Consider the phasing of development and funding of infrastructure will be crucial for effective delivery and this will need to be reflected in the evidence base as Local Plan preparation progresses, and its supporting IDP. Any proposed strategy is of particular importance to ECC as it will need to be satisfied that the impact of any planned scale and distribution of growth can be accommodated by ECC areas of responsibility, or identify what additional facilities or mitigation is required to make the strategy sustainable in social, economic and environmental grounds.

Object

Representation ID: 15953

Received: 12/05/2016

Respondent: Collins & Coward Ltd

Agent: Collins Coward

It is important to interrogate the Council's Green Belt assessment. This study is not wholly reflective or representative of the NPPF. Paragraph 84 requires Council's when reviewing Green Belt boundaries to take account of sustainable patterns of development. The Council's Green Belt study does not take account of the NPPF paragraphs 84 or 85 and is therefore fundamentally flawed. Nor does it consider permitted development rights and locations where development would not be inappropriate (paragraphs 89 and 90). On this basis the Green Belt work is simply no more than a landscape assessment.

Comment

Representation ID: 15957

Received: 12/05/2016

Respondent: Collins & Coward Ltd

Agent: Collins Coward

Survey sheet for site 249 there are a number of errors. Firstly, on the boundary type the whole site is contained within tall evergreen trees not hedges. There are no views into or out of the site. There is no clear separation of the site from Blackmore village as it is surrounded by residential development on the north, east and west sides. There is a private access from the site into the village of Blackmore which can be opened up if the site is allocated for housing making all facilities within walking distance. The site is highly sustainable. The site has medium tranquillity as it lies next to the main Ingatestone Road.

Object

Representation ID: 15961

Received: 13/05/2016

Respondent: Simply Planning

Agent: Simply Planning

The Council's Green Belt Assessment of the site 104 assessed a larger site of 8.3 ha and identifies that the site currently has a low visual amenity, low tranquillity and is a mix of uses. The assessment finds that the site is not contained as the site lies away from the village of Stondon Massey and has no defined boundaries. We object to this description as the boundaries of the site are the current industrial and storage uses which are clearly defined. Whilst separate from the settlement of Stondon Massey it is within easy reach and currently provides a heavily used industrial/sui generis site. The Green Belt Assessment accepts that development of the site would not cause surrounding towns to coalesce.

Comment

Representation ID: 15966

Received: 11/05/2016

Respondent: Essex County Council

The `Brentwood Borough Local Plan Development Options - Highway Modelling' has been published in draft form. It is acknowledged that the draft Report has not yet been fully considered by Highways England or ECC as local highway authority. This work will be further developed in partnership with highways authorities, under `duty to co-operate', before a final version is published.
Highway modelling will need to consider the impact of the growth in the preferred strategy, and the identification of necessary mitigation; the cumulative impact of growth; and the impact of wider planned growth. In addition, consideration will need to be given to the modelling undertaken to support the emerging Basildon Local Plan.

Object

Representation ID: 16063

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Summary of Objections :
OBJECT TO THE LOCAL PLAN ON THE BASIS THAT IT IS UNSOUND AS CURRENTLY
DRAFTED DUE TO THE ABSENCE OF AN APPROPRIATE, COMPREHENSIVE AND UPTO-DATE EVIDENCE BASE.

THE ABSENCE OF AN ADEQUATE SUSTAINABILITY APPRAISAL. FAILURE TO COMPLY WITH THE RELEVANT EU DIRECTIVE AND REGULATIONS MADE TO IMPLEMENT IT.
NOTWITHSTANDING THE ABOVE SUBMISSION THAT THE PLAN AS A WHOLE IS
UNSOUND, OBJECT TO POLICIES:

5.1 SPATIAL STRATEGY;
5.2 HOUSING GROWTH;
6.1 SUSTAINABLE DEVELOPMENT;
6.2 MANAGING GROWTH;
6.6 STRATEGIC SITES;
7.1 DUNTON HILLS GARDEN VILLAGE; and
7.4 HOUSING LAND ALLOCATIONS.

Please note that 15 documents were submitted for this representation.

Object

Representation ID: 16069

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Documents described as 'forthcoming':
Green Belt Review.
Infrastructure Delivery Plan.
New economic evidence including the impact of Crossrail.
Documents requiring an Update/Further Assessment:
A Green Infrastructure Study.
Transport Assessment.
Objectively Assessed Housing Needs.
Strategic Housing Market Assessment (SHMA).
Strategic Housing Land Availability Assessment.
The Plan is therefore supported by a limited evidence base, which by the Council's own admission is "emerging and ongoing" (DLP, paragraph 1.22). Paragraph 2.16 confirms: "several pieces of evidence are being undertaken alongside Local Plan preparation to inform policies as they are being developed and ensure the Council is able to produce a Plan as quickly as possible".

Object

Representation ID: 16116

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The government places a strong emphasis on the importance of infrastructure planning. It is therefore unacceptable that the Local plan has been prepared in the absence of an Infrastructure Delivery Plan (IDP). Proposed land allocations for strategic growth have been identified in the absence of a proper understanding of the level and distribution of existing infrastructure and where new provision is required.

Comment

Representation ID: 16123

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Whilst the draft Plan makes various general references to supporting evidence, there is very little reference to specific evidence base documents relied upon. Additionally, as we understand at paragraph 2.16 of the draft Plan, there is further evidence "being undertaken to inform policies as they are being developed". It stands to reason that the Plan, prepared as it has, in the absence of this evidence will fail to satisfy the requirements of the NPPF.

Object

Representation ID: 16130

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council commissioned Crestwood Environmental to undertake an independent assessment of Housing Sites within the Green Belt and their relative contribution to the purposes of the Green Belt designation. The assessment is not a parcel based analysis nor does it take into consideration the results of the Council's Mid Essex Landscape Character Assessment 2006. The principal weakness is that it does not consider the role and function of the Green Belt in Brentwood and beyond to determine the best Green Belt sites to release.

Object

Representation ID: 16142

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council's SHMA is dated July 2014. Whilst October 2011 is the date the SHLAA was published, the assessment itself took place between October 2009 and May 2010 (see Executive Summary). In the absence of any up to date evidence from the SHMA or the SHLAA, the sustainability appraisal fails to adequately update the assessment of sites in terms of any sequential analysis required to inform their deliverability and suitability for development. There is therefore a complete lack of an upto-date evidence base on housing numbers and allocations.

Object

Representation ID: 16143

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The overwhelming conclusion to draw on the DLP is that in all topic areas it has not been influenced by an appropriate and proportionate evidence base. There is no background assessment to support or justify the policies of the Plan. It is flawed in terms of evidence on housing, business, infrastructure, the environment, and in terms of viability and deliverability to list but a few. There has been a complete lack of evidence to inform what is in the plan and the Council is hastily collating and publishing this retrospectively. Some documents that are only now being published were commissioned three years ago. These are now seen to be contradicting the policies of the plan. Without an evidence base there can be no SA. The effects of the options and the plans policies must have been appraised in relation to the baseline situation. The absence of an evidence base and SA mean that the plan cannot be found sound. It is questionable whether this situation can be corrected in due course and we call for the Council to address the matter now and undertake the work required.

Object

Representation ID: 16153

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

In the DLP there is reference to an evidence base document entitled Green Infrastructure Strategy and published in September 2015. We submit that this report fails to draw any overriding conclusions but defers instead to additional work. A note is attached to this report that states that the GIS will require review and update upon receipt of Open Space and Sport Assessment and Landscape Sensitivity and Landscape Capacity Study, commissioned by the Council and due Spring 2016. The broad findings of the report are at odds with the latest interim SA. The report lends some support to Dunton for strategic growth but the results appear contrived. In dealing with Dunton the report also refers to "or another current new development site".

Object

Representation ID: 16160

Received: 16/05/2016

Respondent: Joy Fook Restaurant

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: 16170

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Appendix 1 to the report of OM provides a critique of the modelling work by PBA. This finds fundamental issues with the depth of the work carried out, the data presented and conclusions drawn from that data. Critically the work has not been reviewed by the Highways Authority, Essex County Council and Highways England. The methodology used is not clear and the modelling tool is unreliable. For example it does not appear to take account of existing and proposed major development including infrastructure. It lacks depth and serious technical analysis. No real conclusions on the various strategic options for growth can be drawn from it.

Comment

Representation ID: 16182

Received: 16/05/2016

Respondent: Joy Fook Restaurant

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: 16187

Received: 16/05/2016

Respondent: Mr Hugh Thomson

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: 16219

Received: 16/05/2016

Respondent: Mr Hugh Thomson

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.