Sustainability Appraisal
Object
Draft Local Plan
Representation ID: 14381
Received: 14/04/2016
Respondent: Thurrock Borough Council
Thurrock Council considers the approach set out in the Interim Sustainabilty Appraisal (SA) is flawed and that a number of assumptions on the way that options have been scored is not supported by the available evidence.
The Interim SA does not adequately include or reflect in paragraph 6.2.9, Thurrock Council's concerns about development focused on the A127 corridor and impact on Green Belt and Landscape. Paragraphs 6.2.11 to 6.2.12 also do not include a reference to Thurrock Council's fundamental concerns about the deliverability, viability and impact on Green Belt and Landscape of the Dunton Garden Suburb.
The SA appraises and scores six options for the location of development with the assumption that most development would be located in one of the locations and with a strategic scale of development. Whilst this may be useful as an initial approach it is considered that actual development may result in a hybrid of such options with development in several key locations but not necessarily the dispersed option or one strategic location. A hybrid option may well moderate the scoring and impact of development in these locations therefore giving more positive scores rather than a large scale concentration of development.
It is noted that further assessment needs to be undertaken of urban extensions around Brentwood. A new option should be considered including development north and east south east of Brentwood/Shenfield. Again this may result in different scores for a Brentwood Town based option. Such an option is likely to give different scores than presented in the report.
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.
Object
Draft Local Plan
Representation ID: 14382
Received: 14/04/2016
Respondent: Thurrock Borough Council
It is suggested that some of the scoring for the options in the SA has been based on assumptions that may not be correct or realistic and should be reconsidered.
* It is unclear that the options and sites have been comprehensively appraised in terms of access and sustainable transport.
* It is uncertain whether the benefits of improved accessibility brought about by Crossrail and longer term the A12 widening are taken into account.
* It is consider the housing appraisal skews the findings towards meeting the OAN but undermines the location of the housing.
* It is not considered that Housing along the A127 corridor would meet housing needs (p34) in Brentwood/Shenfield as well as housing located along A12.
* It is not considered that a new strategic settlement at Dunton Hills would be a self -sustaining community.
The scoring of the development options in relation to community and well-being tends to overstate the benefits for new strategic developments in the south without evidence being provided. Conversely the SA under-states the ability of existing locations to gain improved and additional capacity in infrastructure.
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.
Object
Draft Local Plan
Representation ID: 14563
Received: 19/04/2016
Respondent: Ms Chloë Sanders
The only Sustainability Appraisal that has been found is that produced in January 2015. It reviewed a number of sites in detail, but the Priests Lane sites (044 and 178) were not mentioned or identified.
See attached.
Object
Draft Local Plan
Representation ID: 14568
Received: 19/04/2016
Respondent: Mr C Lonergan
Agent: Strutt & Parker LLP
We have concerns with the current approach to SA in respect of both how the proposed total
housing figure has been considered and specific individual sites have been assessed.
The Interim SA published alongside the DLP assumes the Local Plan will plan for the delivery of 7,240 new homes over the plan period. The provision of a greater number of new homes is clearly a reasonable alternative that merits consideration. However, there appears to be no assessment of the sustainability of a higher level of growth.
See attached
Object
Draft Local Plan
Representation ID: 14639
Received: 20/04/2016
Respondent: Mr Kevin Mate
Key conclusions of the sustainability appraisal: Looking at the two ends of a growth spectrum, it is clear that Scenario 1 (no growth) would be beneficial in terms of protecting Green Belt and preventing coalescence. It would also maintain the existing village character and its setting. However it would not provide for any real development of community spirit and investment in infrastructure and facilities.
See attached
Object
Draft Local Plan
Representation ID: 14641
Received: 20/04/2016
Respondent: Mr Kevin Mate
Scenario 5 looks at expansive growth, defined as being greater than that anticipated by the first four scenarios. Such a level of growth has been put forwards by BBC in the latest draft of its LDP. It would involve a much larger development on open Green Belt land such that the Parish would increase from around 700 dwellings to around 3,700. The village itself would increase from around 700 dwellings to around 1,300. Given the location of West Horndon at a distance from larger centres, and the current strain on services and facilities, such a scenario scores poorly in respect of social, environmental and economic dimensions. Out of the 11 elements of the sustainability framework it scores 5 reds, 6 ambers and no greens. It would be disproportionate and unsustainable.
See attached
Object
Draft Local Plan
Representation ID: 14643
Received: 20/04/2016
Respondent: Mr Kevin Mate
Scenario 2 is described as "controlled growth". It suggests an additional 400 houses for the village and scores well against most sustainability objectives. It is important to note however that some of the positive scores, say in respect of residential amenity, or in the provision for education and healthcare, are dependent on a commensurate level of new infrastructure. Without the infrastructure in place, such growth cannot be described as "controlled" or in accordance to The Vision. It would not therefore be sustainable.
See attached
Object
Draft Local Plan
Representation ID: 14700
Received: 20/04/2016
Respondent: Hermes Fund Managers Limited
Agent: McGough Planning Consultants
We have submitted our letter of February 2015 commenting on those draft SAs at that time. It is clear the detailed comments on previous SAs have not been addressed. Given that, and the previous comments appear to be largely still relevant, our client Is content to let their comments to the previous SAs stand as their representation to the current SA.
Our client is concerned about specific inaccuracies within the current SA's assessments for site's ref. 021 and 152 [see supporting document for detail]
These are inaccuracies are not insignificant factors and they were found on just one allocation in the draft Local Plan. These should be rectified before proceeding further. However, our client is concerned that if these inaccuracies are repeated in the assessments of other allocations considered within the SA, it must undermine the whole document.
See attached
Object
Draft Local Plan
Representation ID: 14756
Received: 21/04/2016
Respondent: Mr Geoff Sanders
The only Sustainability Appraisal that has been found is that produced in January 2015. It reviewed a number of sites in detail, but the Priests Lane sites (044 and 178) were not mentioned or identified.
See attached.
Object
Draft Local Plan
Representation ID: 14815
Received: 22/04/2016
Respondent: Mrs Sandra Mate
Key conclusions of the sustainability appraisal: Looking at the two ends of a growth spectrum, it is clear that Scenario 1 (no growth) would be beneficial in terms of protecting Green Belt and preventing coalescence. It would also maintain the existing village character and its setting. However it would not provide for any real development of community spirit and investment in infrastructure and facilities.
See attachment.
Object
Draft Local Plan
Representation ID: 14816
Received: 22/04/2016
Respondent: Mrs Sandra Mate
Scenario 5 looks at expansive growth, defined as being greater than that anticipated by the first four scenarios. Such a level of growth has been put forwards by BBC in the latest draft of its LDP. It would involve a much larger development on open Green Belt land such that the Parish would increase from around 700 dwellings to around 3,700. The village itself would increase from around 700 dwellings to around 1,300. Given the location of West Horndon at a distance from larger centres, and the current strain on services and facilities, such a scenario scores poorly in respect of social, environmental and economic dimensions. Out of the 11 elements of the sustainability framework it scores 5 reds, 6 ambers and no greens. It would be disproportionate and unsustainable.
See attachment.
Object
Draft Local Plan
Representation ID: 14817
Received: 22/04/2016
Respondent: Mrs Sandra Mate
Scenario 2 is described as "controlled growth". It suggests an additional 400 houses for the village and scores well against most sustainability objectives. It is important to note however that some of the positive scores, say in respect of residential amenity, or in the provision for education and healthcare, are dependent on a commensurate level of new infrastructure. Without the infrastructure in place, such growth cannot be described as "controlled" or in accordance to The Vision. It would not therefore be sustainable.
See attachment.
Comment
Draft Local Plan
Representation ID: 14891
Received: 25/04/2016
Respondent: Mr Chris Puddefoot
With regard to my distance measurements I have used as an initial point 47, Honeypot Lane, the nearest property where site 022 could have road access, and Google Maps as a measurement tool. I could not find any specific measurement points or tools within the Sustainability Appraisal.7) Bus Stop The report indicates that the nearest bus stop is within 400m, using classification "Performs Well". Using the initial point, and the nearest bus stop, being between Honeypot Lane and South Weald Road travelling to Brentwood, the walking distance is a minimum of 475m. According to the SA criteria, this should be reclassified as "Performs Poorly".
Having read the Local Plan, it was disappointing to see the Honeypot Lane site 022 included in the plans. I assume it is due to the comments from Barwood Land and Estates Ltd, together with their agents Chilmark Consulting, who in their responses to the 2013 consultation implied that Brentwood Council was failing to plan to deliver Brentwood's full objectively assessed housing needs.
You have already acknowledged receipt of my previous email of 4th March highlighting specific inaccuracies in the AECOM Sustainability Report regarding this site. There are other reasons why I believe this site 022 is unsuitable for development which are as follows:
ACCESS
All roads which would be used to access the site either have chicanes, Weald Road, Sandpit Lane and Wigley Bush Lane, or have parts of the road which are too narrow for two vehicles to pass, Weald Park Way. Honeypot Lane has its own specific restriction. All this would hinder construction traffic to begin with, and would substantially increase local traffic once the site had been completed. The roads currently take high volumes of traffic, especially mornings, evenings and school run times, which has increased substantially with the St Charles development. Regrettably, due to no enforcement Honeypot Lane is a speeding "rat run" and I would not be surprised if at some stage there was a serious pedestrian injury, especially in the construction period, at the Honeypot Lane narrowing. There is no commentary as to how these access issues would be resolved. Clements Park, which is a similar sized development, has three access points at Crescent Road, Warley Hill and Mascalls Lane which allows traffic to disperse relatively efficiently.
FLOODING/DRAINAGE
At the road show for this consultation, one of the exhibits highlighted this issue in the BT fields and Selwood Road area. The Environment Agency website also shows a high risk of flooding arising from surface water. There is a meaningful water course that runs diagonally through the whole site. Although it is not possible to access site 022, it is lower than the lowest BT fields opposite which are completely waterlogged. I would suggest any development would create increased flooding exposure to the properties east of the site. It would also probably provide additional flood insurance issues, not only for the development but also those other properties which are near the existing water courses.
EDUCATIONAL ESTABLISHMENTS
St. Peter's school in Wigley Bush Lane is the nearest primary school and is currently oversubscribed. This has recently been refused planning permission to expand due to it being within the Green Belt. There is a substantial shortage of primary places in the Brentwood district, and clearly no room for expansion at St. Peter's. I understand Holly Trees school, which would be the next nearest is also over subscribed and I'm unaware of where there would be additional primary provision. As there are no schools within walking distance of site 022, contrary to the AECOM Sustainability Appraisal, (see my previous email 4th March) that would imply up to four traffic movements per day per pupil. I refer you back to my comments under ACCESS.
HEALTH FACILITIES
Again, contrary to the AECOM report, (see 4th March email) there are no medical facilities within 800m which forms part of Dept of Transport guidance to those facilities which would be deemed a walkable distance. Again, I understand the NHS have intimated there is a shortage of facilities in the Brentwood area, and I'm not aware of additional health facilities being planned.
BRENTWOOD STATION
The Draft LDP incorrectly states that Brentwood Station is within 15 minutes walk from anywhere on the site. As per my 4th March email as this was using "as the crow flies" measurements, it is clearly incorrect. From the nearest road access to site 022 using roads and paths it takes a minimum of 20 minutes. As I would suggest, many of the proposed new residents would be commuting via rail, and in view of the distance from Brentwood Station, this again would increase traffic volumes.
WILDLIFE
What a great disappointment it would be to lose this habitat which amongst many species is also used by badgers.
OTHER
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Comment
Draft Local Plan
Representation ID: 14892
Received: 25/04/2016
Respondent: Mr Chris Puddefoot
With the same measurement criteria: 8) Health Facility. The report indicates that a Health Facility is between 800m and 1.5km, using classification "Performs Poorly". Again using the initial point and, this time the Brambles Surgery off Greenwich Avenue, the distance is over 1.6km if using the unlit pedestrian path opposite the Weald Road exit of Honeypot Lane, or in excess off 1.9km if using roads. Using the SA criteria this should therefore be reclassified as "Performs Particularly Poorly".
Having read the Local Plan, it was disappointing to see the Honeypot Lane site 022 included in the plans. I assume it is due to the comments from Barwood Land and Estates Ltd, together with their agents Chilmark Consulting, who in their responses to the 2013 consultation implied that Brentwood Council was failing to plan to deliver Brentwood's full objectively assessed housing needs.
You have already acknowledged receipt of my previous email of 4th March highlighting specific inaccuracies in the AECOM Sustainability Report regarding this site. There are other reasons why I believe this site 022 is unsuitable for development which are as follows:
ACCESS
All roads which would be used to access the site either have chicanes, Weald Road, Sandpit Lane and Wigley Bush Lane, or have parts of the road which are too narrow for two vehicles to pass, Weald Park Way. Honeypot Lane has its own specific restriction. All this would hinder construction traffic to begin with, and would substantially increase local traffic once the site had been completed. The roads currently take high volumes of traffic, especially mornings, evenings and school run times, which has increased substantially with the St Charles development. Regrettably, due to no enforcement Honeypot Lane is a speeding "rat run" and I would not be surprised if at some stage there was a serious pedestrian injury, especially in the construction period, at the Honeypot Lane narrowing. There is no commentary as to how these access issues would be resolved. Clements Park, which is a similar sized development, has three access points at Crescent Road, Warley Hill and Mascalls Lane which allows traffic to disperse relatively efficiently.
FLOODING/DRAINAGE
At the road show for this consultation, one of the exhibits highlighted this issue in the BT fields and Selwood Road area. The Environment Agency website also shows a high risk of flooding arising from surface water. There is a meaningful water course that runs diagonally through the whole site. Although it is not possible to access site 022, it is lower than the lowest BT fields opposite which are completely waterlogged. I would suggest any development would create increased flooding exposure to the properties east of the site. It would also probably provide additional flood insurance issues, not only for the development but also those other properties which are near the existing water courses.
EDUCATIONAL ESTABLISHMENTS
St. Peter's school in Wigley Bush Lane is the nearest primary school and is currently oversubscribed. This has recently been refused planning permission to expand due to it being within the Green Belt. There is a substantial shortage of primary places in the Brentwood district, and clearly no room for expansion at St. Peter's. I understand Holly Trees school, which would be the next nearest is also over subscribed and I'm unaware of where there would be additional primary provision. As there are no schools within walking distance of site 022, contrary to the AECOM Sustainability Appraisal, (see my previous email 4th March) that would imply up to four traffic movements per day per pupil. I refer you back to my comments under ACCESS.
HEALTH FACILITIES
Again, contrary to the AECOM report, (see 4th March email) there are no medical facilities within 800m which forms part of Dept of Transport guidance to those facilities which would be deemed a walkable distance. Again, I understand the NHS have intimated there is a shortage of facilities in the Brentwood area, and I'm not aware of additional health facilities being planned.
BRENTWOOD STATION
The Draft LDP incorrectly states that Brentwood Station is within 15 minutes walk from anywhere on the site. As per my 4th March email as this was using "as the crow flies" measurements, it is clearly incorrect. From the nearest road access to site 022 using roads and paths it takes a minimum of 20 minutes. As I would suggest, many of the proposed new residents would be commuting via rail, and in view of the distance from Brentwood Station, this again would increase traffic volumes.
WILDLIFE
What a great disappointment it would be to lose this habitat which amongst many species is also used by badgers.
OTHER
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Comment
Draft Local Plan
Representation ID: 14893
Received: 25/04/2016
Respondent: Mr Chris Puddefoot
With the same measurement criteria: 9) Educational Establishment:
The report indicates an Educational Establishment less than 800m using classification "Performs Particularly Well". Again using the initial point and St Peter's School in Wigley Bush Lane, the distance is over 1.6km. I would also highlight that this is the most direct route using Weald Road which has no pedestrian path for the majority of the route. This should also be reclassified as "Performs Particularly Poorly".
Having read the Local Plan, it was disappointing to see the Honeypot Lane site 022 included in the plans. I assume it is due to the comments from Barwood Land and Estates Ltd, together with their agents Chilmark Consulting, who in their responses to the 2013 consultation implied that Brentwood Council was failing to plan to deliver Brentwood's full objectively assessed housing needs.
You have already acknowledged receipt of my previous email of 4th March highlighting specific inaccuracies in the AECOM Sustainability Report regarding this site. There are other reasons why I believe this site 022 is unsuitable for development which are as follows:
ACCESS
All roads which would be used to access the site either have chicanes, Weald Road, Sandpit Lane and Wigley Bush Lane, or have parts of the road which are too narrow for two vehicles to pass, Weald Park Way. Honeypot Lane has its own specific restriction. All this would hinder construction traffic to begin with, and would substantially increase local traffic once the site had been completed. The roads currently take high volumes of traffic, especially mornings, evenings and school run times, which has increased substantially with the St Charles development. Regrettably, due to no enforcement Honeypot Lane is a speeding "rat run" and I would not be surprised if at some stage there was a serious pedestrian injury, especially in the construction period, at the Honeypot Lane narrowing. There is no commentary as to how these access issues would be resolved. Clements Park, which is a similar sized development, has three access points at Crescent Road, Warley Hill and Mascalls Lane which allows traffic to disperse relatively efficiently.
FLOODING/DRAINAGE
At the road show for this consultation, one of the exhibits highlighted this issue in the BT fields and Selwood Road area. The Environment Agency website also shows a high risk of flooding arising from surface water. There is a meaningful water course that runs diagonally through the whole site. Although it is not possible to access site 022, it is lower than the lowest BT fields opposite which are completely waterlogged. I would suggest any development would create increased flooding exposure to the properties east of the site. It would also probably provide additional flood insurance issues, not only for the development but also those other properties which are near the existing water courses.
EDUCATIONAL ESTABLISHMENTS
St. Peter's school in Wigley Bush Lane is the nearest primary school and is currently oversubscribed. This has recently been refused planning permission to expand due to it being within the Green Belt. There is a substantial shortage of primary places in the Brentwood district, and clearly no room for expansion at St. Peter's. I understand Holly Trees school, which would be the next nearest is also over subscribed and I'm unaware of where there would be additional primary provision. As there are no schools within walking distance of site 022, contrary to the AECOM Sustainability Appraisal, (see my previous email 4th March) that would imply up to four traffic movements per day per pupil. I refer you back to my comments under ACCESS.
HEALTH FACILITIES
Again, contrary to the AECOM report, (see 4th March email) there are no medical facilities within 800m which forms part of Dept of Transport guidance to those facilities which would be deemed a walkable distance. Again, I understand the NHS have intimated there is a shortage of facilities in the Brentwood area, and I'm not aware of additional health facilities being planned.
BRENTWOOD STATION
The Draft LDP incorrectly states that Brentwood Station is within 15 minutes walk from anywhere on the site. As per my 4th March email as this was using "as the crow flies" measurements, it is clearly incorrect. From the nearest road access to site 022 using roads and paths it takes a minimum of 20 minutes. As I would suggest, many of the proposed new residents would be commuting via rail, and in view of the distance from Brentwood Station, this again would increase traffic volumes.
WILDLIFE
What a great disappointment it would be to lose this habitat which amongst many species is also used by badgers.
OTHER
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Comment
Draft Local Plan
Representation ID: 14894
Received: 25/04/2016
Respondent: Mr Chris Puddefoot
10) Community Facilities: In the SA Community Facilities does not appear to be very well defined. I am using shops and Brentwood Station. The report indicates Community Facilities less than 800m using classification "Performs Poorly". The walking distance to Brentwood Station is 1.6km, Brook St sub Post Office is over 1.4km and Brentwood Sainsbury's is also1.6km. Following the SA criteria I believe this should also be reclassified as "Performs Particularly Poorly". With regard to distances from Brentwood Station, Figure 5.5 on page 36 of the Brentwood Draft Local Plan, implies that all of the Honeypot Lane site 022 is within a 15 minute walk of Brentwood Station. I would point out that the measuring tool used in Fig 5.5 is " as the crow flies" and therefore walking using roads and paths, from my measuring point of 47 Honeypot Lane, which would be the nearest point to the Station from site 022, is in excess of a 20 minutes walk, at a swift walking speed of nearly 5k per hour.
Having read the Local Plan, it was disappointing to see the Honeypot Lane site 022 included in the plans. I assume it is due to the comments from Barwood Land and Estates Ltd, together with their agents Chilmark Consulting, who in their responses to the 2013 consultation implied that Brentwood Council was failing to plan to deliver Brentwood's full objectively assessed housing needs.
You have already acknowledged receipt of my previous email of 4th March highlighting specific inaccuracies in the AECOM Sustainability Report regarding this site. There are other reasons why I believe this site 022 is unsuitable for development which are as follows:
ACCESS
All roads which would be used to access the site either have chicanes, Weald Road, Sandpit Lane and Wigley Bush Lane, or have parts of the road which are too narrow for two vehicles to pass, Weald Park Way. Honeypot Lane has its own specific restriction. All this would hinder construction traffic to begin with, and would substantially increase local traffic once the site had been completed. The roads currently take high volumes of traffic, especially mornings, evenings and school run times, which has increased substantially with the St Charles development. Regrettably, due to no enforcement Honeypot Lane is a speeding "rat run" and I would not be surprised if at some stage there was a serious pedestrian injury, especially in the construction period, at the Honeypot Lane narrowing. There is no commentary as to how these access issues would be resolved. Clements Park, which is a similar sized development, has three access points at Crescent Road, Warley Hill and Mascalls Lane which allows traffic to disperse relatively efficiently.
FLOODING/DRAINAGE
At the road show for this consultation, one of the exhibits highlighted this issue in the BT fields and Selwood Road area. The Environment Agency website also shows a high risk of flooding arising from surface water. There is a meaningful water course that runs diagonally through the whole site. Although it is not possible to access site 022, it is lower than the lowest BT fields opposite which are completely waterlogged. I would suggest any development would create increased flooding exposure to the properties east of the site. It would also probably provide additional flood insurance issues, not only for the development but also those other properties which are near the existing water courses.
EDUCATIONAL ESTABLISHMENTS
St. Peter's school in Wigley Bush Lane is the nearest primary school and is currently oversubscribed. This has recently been refused planning permission to expand due to it being within the Green Belt. There is a substantial shortage of primary places in the Brentwood district, and clearly no room for expansion at St. Peter's. I understand Holly Trees school, which would be the next nearest is also over subscribed and I'm unaware of where there would be additional primary provision. As there are no schools within walking distance of site 022, contrary to the AECOM Sustainability Appraisal, (see my previous email 4th March) that would imply up to four traffic movements per day per pupil. I refer you back to my comments under ACCESS.
HEALTH FACILITIES
Again, contrary to the AECOM report, (see 4th March email) there are no medical facilities within 800m which forms part of Dept of Transport guidance to those facilities which would be deemed a walkable distance. Again, I understand the NHS have intimated there is a shortage of facilities in the Brentwood area, and I'm not aware of additional health facilities being planned.
BRENTWOOD STATION
The Draft LDP incorrectly states that Brentwood Station is within 15 minutes walk from anywhere on the site. As per my 4th March email as this was using "as the crow flies" measurements, it is clearly incorrect. From the nearest road access to site 022 using roads and paths it takes a minimum of 20 minutes. As I would suggest, many of the proposed new residents would be commuting via rail, and in view of the distance from Brentwood Station, this again would increase traffic volumes.
WILDLIFE
What a great disappointment it would be to lose this habitat which amongst many species is also used by badgers.
OTHER
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Comment
Draft Local Plan
Representation ID: 14895
Received: 25/04/2016
Respondent: Mr Chris Puddefoot
If my findings are correct, and I have only reviewed site 022 Honeypot Lane then I would suggest that it brings into question the many aspects of the Appraisal Findings. No doubt you will be able to confirm that these will be reviewed and Appendix II will be re-issued and circulated.
Having read the Local Plan, it was disappointing to see the Honeypot Lane site 022 included in the plans. I assume it is due to the comments from Barwood Land and Estates Ltd, together with their agents Chilmark Consulting, who in their responses to the 2013 consultation implied that Brentwood Council was failing to plan to deliver Brentwood's full objectively assessed housing needs.
You have already acknowledged receipt of my previous email of 4th March highlighting specific inaccuracies in the AECOM Sustainability Report regarding this site. There are other reasons why I believe this site 022 is unsuitable for development which are as follows:
ACCESS
All roads which would be used to access the site either have chicanes, Weald Road, Sandpit Lane and Wigley Bush Lane, or have parts of the road which are too narrow for two vehicles to pass, Weald Park Way. Honeypot Lane has its own specific restriction. All this would hinder construction traffic to begin with, and would substantially increase local traffic once the site had been completed. The roads currently take high volumes of traffic, especially mornings, evenings and school run times, which has increased substantially with the St Charles development. Regrettably, due to no enforcement Honeypot Lane is a speeding "rat run" and I would not be surprised if at some stage there was a serious pedestrian injury, especially in the construction period, at the Honeypot Lane narrowing. There is no commentary as to how these access issues would be resolved. Clements Park, which is a similar sized development, has three access points at Crescent Road, Warley Hill and Mascalls Lane which allows traffic to disperse relatively efficiently.
FLOODING/DRAINAGE
At the road show for this consultation, one of the exhibits highlighted this issue in the BT fields and Selwood Road area. The Environment Agency website also shows a high risk of flooding arising from surface water. There is a meaningful water course that runs diagonally through the whole site. Although it is not possible to access site 022, it is lower than the lowest BT fields opposite which are completely waterlogged. I would suggest any development would create increased flooding exposure to the properties east of the site. It would also probably provide additional flood insurance issues, not only for the development but also those other properties which are near the existing water courses.
EDUCATIONAL ESTABLISHMENTS
St. Peter's school in Wigley Bush Lane is the nearest primary school and is currently oversubscribed. This has recently been refused planning permission to expand due to it being within the Green Belt. There is a substantial shortage of primary places in the Brentwood district, and clearly no room for expansion at St. Peter's. I understand Holly Trees school, which would be the next nearest is also over subscribed and I'm unaware of where there would be additional primary provision. As there are no schools within walking distance of site 022, contrary to the AECOM Sustainability Appraisal, (see my previous email 4th March) that would imply up to four traffic movements per day per pupil. I refer you back to my comments under ACCESS.
HEALTH FACILITIES
Again, contrary to the AECOM report, (see 4th March email) there are no medical facilities within 800m which forms part of Dept of Transport guidance to those facilities which would be deemed a walkable distance. Again, I understand the NHS have intimated there is a shortage of facilities in the Brentwood area, and I'm not aware of additional health facilities being planned.
BRENTWOOD STATION
The Draft LDP incorrectly states that Brentwood Station is within 15 minutes walk from anywhere on the site. As per my 4th March email as this was using "as the crow flies" measurements, it is clearly incorrect. From the nearest road access to site 022 using roads and paths it takes a minimum of 20 minutes. As I would suggest, many of the proposed new residents would be commuting via rail, and in view of the distance from Brentwood Station, this again would increase traffic volumes.
WILDLIFE
What a great disappointment it would be to lose this habitat which amongst many species is also used by badgers.
OTHER
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Comment
Draft Local Plan
Representation ID: 14899
Received: 25/04/2016
Respondent: Mr Chris Puddefoot
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Having read the Local Plan, it was disappointing to see the Honeypot Lane site 022 included in the plans. I assume it is due to the comments from Barwood Land and Estates Ltd, together with their agents Chilmark Consulting, who in their responses to the 2013 consultation implied that Brentwood Council was failing to plan to deliver Brentwood's full objectively assessed housing needs.
You have already acknowledged receipt of my previous email of 4th March highlighting specific inaccuracies in the AECOM Sustainability Report regarding this site. There are other reasons why I believe this site 022 is unsuitable for development which are as follows:
ACCESS
All roads which would be used to access the site either have chicanes, Weald Road, Sandpit Lane and Wigley Bush Lane, or have parts of the road which are too narrow for two vehicles to pass, Weald Park Way. Honeypot Lane has its own specific restriction. All this would hinder construction traffic to begin with, and would substantially increase local traffic once the site had been completed. The roads currently take high volumes of traffic, especially mornings, evenings and school run times, which has increased substantially with the St Charles development. Regrettably, due to no enforcement Honeypot Lane is a speeding "rat run" and I would not be surprised if at some stage there was a serious pedestrian injury, especially in the construction period, at the Honeypot Lane narrowing. There is no commentary as to how these access issues would be resolved. Clements Park, which is a similar sized development, has three access points at Crescent Road, Warley Hill and Mascalls Lane which allows traffic to disperse relatively efficiently.
FLOODING/DRAINAGE
At the road show for this consultation, one of the exhibits highlighted this issue in the BT fields and Selwood Road area. The Environment Agency website also shows a high risk of flooding arising from surface water. There is a meaningful water course that runs diagonally through the whole site. Although it is not possible to access site 022, it is lower than the lowest BT fields opposite which are completely waterlogged. I would suggest any development would create increased flooding exposure to the properties east of the site. It would also probably provide additional flood insurance issues, not only for the development but also those other properties which are near the existing water courses.
EDUCATIONAL ESTABLISHMENTS
St. Peter's school in Wigley Bush Lane is the nearest primary school and is currently oversubscribed. This has recently been refused planning permission to expand due to it being within the Green Belt. There is a substantial shortage of primary places in the Brentwood district, and clearly no room for expansion at St. Peter's. I understand Holly Trees school, which would be the next nearest is also over subscribed and I'm unaware of where there would be additional primary provision. As there are no schools within walking distance of site 022, contrary to the AECOM Sustainability Appraisal, (see my previous email 4th March) that would imply up to four traffic movements per day per pupil. I refer you back to my comments under ACCESS.
HEALTH FACILITIES
Again, contrary to the AECOM report, (see 4th March email) there are no medical facilities within 800m which forms part of Dept of Transport guidance to those facilities which would be deemed a walkable distance. Again, I understand the NHS have intimated there is a shortage of facilities in the Brentwood area, and I'm not aware of additional health facilities being planned.
BRENTWOOD STATION
The Draft LDP incorrectly states that Brentwood Station is within 15 minutes walk from anywhere on the site. As per my 4th March email as this was using "as the crow flies" measurements, it is clearly incorrect. From the nearest road access to site 022 using roads and paths it takes a minimum of 20 minutes. As I would suggest, many of the proposed new residents would be commuting via rail, and in view of the distance from Brentwood Station, this again would increase traffic volumes.
WILDLIFE
What a great disappointment it would be to lose this habitat which amongst many species is also used by badgers.
OTHER
Having reviewed the 2013 consultation responses, I see that the proposer for the Honeypot Lane site is Barwell Land and Estates Ltd. AECOM, who I assume are the successors to PBA who produced the 2013 Sustainability Appraisal, have produced the Sustainability Appraisal for Brentwood Council which has several inaccuracies (see 4th March email). In the previous consultation response by Barwell Land they highlight aspects such as public transport being easily accessible by foot, which is not necessarily the case. In reviewing the website of Barwell Land and Estates Ltd it seems that in other projects they are acting together with AECOM. Has this conflict of interest by AECOM been advised?
Object
Draft Local Plan
Representation ID: 15191
Received: 29/04/2016
Respondent: Punch Taverns
Agent: Plainview Planning
The Sustainability Appraisal made a critical error area in respect to the flood risk of the site 035A, where it states that more than 10% of the site intersects a flood risk zone. This conclusion is wrong. A FRA report is attached to show 91% of the site is in Flood zone 1, within which all uses of land are appropriate according to the NPPF.
The site boundary could be redrawn to only include the developable area within Flood Zone 1 and still leave a a developable area of 0.2 ha and a potential capacity of 10-22 dwellings.
Site 035A should be reconsidered as a residential allocation.
See attached
Comment
Draft Local Plan
Representation ID: 15237
Received: 03/05/2016
Respondent: Natural England
We have therefore examined the Draft Local Plan and Interim Sustainability Appraisal in the light of the concerns expressed in our previous response, dated 16 February 2015, at the Strategic Growth Options stage. Both the Draft Local Plan and the Interim Sustainability Appraisal now include several references to the three Sites of Special Scientific Interest (SSSIs) within the district and to the potential threats to them arising from increased recreational pressure. We also note that there is now an explicit reference to the need for the Habitats Regulations Assessment (HRA) of the Plan to include consideration of the potential impact of the Plan's policies on the Epping Forest Special Area of Conservation (SAC) as a result of increased road traffic and the associated air pollution.
See attached
Comment
Draft Local Plan
Representation ID: 15533
Received: 10/05/2016
Respondent: Environment Agency
Within the Climate Change Mitigation topic, an objective could be included on ensuring that people and wildlife can adapt better to climate change. For example, using blue and green infrastructure to protect green corridors and help to reduce the urban heat island effect.
See attachments
Comment
Draft Local Plan
Representation ID: 15555
Received: 18/03/2016
Respondent: Rochford District Council
The Council has no observations to make.
Thank you for inviting Rochford District Council, as a Local Planning Authority in a neighbouring Housing Market Area, to submit comments on Brentwood Borough Council's Draft Local Plan 2016. Rochford District Council recognises that this is the first formal stage in the development of Brentwood's local development plan and therefore welcomes the opportunity to provide comments at this early opportunity.
The A127 - alongside the A130 and A13 - forms part of the strategic road network for South Essex serving as a key route for residents and businesses living in the District and surrounding areas. It is therefore imperative that any development proposed in proximity to any of these corridors, is accompanied by adequate mitigation measures to the strategic road network.
Two strategic development sites are proposed within the vicinity of the A127 corridor to the south east and south west of the Borough. However, it is unclear from the Draft Local Plan 2016, what mitigation measures would be required to accompany significant development in this location. It is therefore strongly recommended that any future iterations of Brentwood's new Local Plan are clearly accompanied by appropriate mitigation measures, to ensure that any proposals would not have a detrimental impact on the A127 in particular.
Rochford District Council would welcome opportunities to engage with Brentwood Borough Council on strategic planning matters - particularly in relation to meeting housing needs and highways impacts - through the Duty to Co-operate as both Local Planning Authorities continue to progress and review their respective local development plans.
Interim Sustainability Appraisal
Thank you for inviting Rochford District Council, as a Local Planning Authority in a neighbouring Housing Market Area, to submit comments on Brentwood Borough Council's Interim Sustainability Appraisal for the Draft Local Plan 2016. The Council has no observations to make.
Comment
Draft Local Plan
Representation ID: 15811
Received: 11/05/2016
Respondent: Essex County Council
ECC acknowledges that the SA of the 6 reasonable options / alternatives identified, offer a very thorough and useful assessment of those options, and that the options selected for this part of the spatial strategy are comprehensive. However, it is noted that the SA seeks to develop `reasonable alternatives' for strategic level growth arising from the Strategic Growth Options/Dunton Garden Village consultations, rather than the overall SA process. Consequently, it is unclear what options have been considered regarding the level of proportionate growth in rural areas with regards scale of growth, as the Draft Plan does not allocate growth in rural areas. The council will need to ensure that it has considered such options moving forward.
See attached
Comment
Draft Local Plan
Representation ID: 15812
Received: 11/05/2016
Respondent: Essex County Council
The (Pre-) Submission SA will need to explore those spatial strategy options that were considered by the Council in 2009-2011 as part of their work towards a Core Strategy DPD (2009) and as stated in the Draft Local Plan 2016, paragraph 5.4, or at least offer some explanation as to why these alternatives are now not considered 'reasonable' if indeed this is considered the case. This could be explored (or re-explored) as part of a comprehensive audit trail of alternatives that have been considered and subject to SA throughout the plan-making process and should detail the reasons for rejecting and progressing alternatives at each stage. In addition, the cumulative assessment of the 'givens' (paras 6.3.5 - 6.3.7 of the Interim SA) for the purposes of satisfying the requirements of SA should be presented, alongside the cumulative impacts of these with the preferred strategic option.
See attached
Comment
Draft Local Plan
Representation ID: 16051
Received: 13/05/2016
Respondent: Elizabeth Finn Care
Agent: Strutt & Parker LLP
The SA considers all reasonable alternatives. We would draw the Council's attention to judgments in respect of Heard v Broadland District Council, South Norfolk District Council, Norwich City Council [2012] and Save Historic Newmarket Ltd v. Forest Heath District Council [2011]. The judgments in these cases confirm inter alia the need for the public to be presented with an accurate picture of the reasonable alternatives at an early stage; for these alternatives to be subject to appraisal; and for reasons for their rejection / selection to be explained within the Environmental Report.
See attached
Comment
Draft Local Plan
Representation ID: 16053
Received: 13/05/2016
Respondent: Elizabeth Finn Care
Agent: Strutt & Parker LLP
We have concerns with the current approach to SA in respect of both how the proposed total housing figure has been considered; and specific individual sites have been assessed. In respect of the total housing target for inclusion in the Local Plan, we note the Interim SA published alongside the DLP assumes the Local Plan will plan for the delivery of 7,240 new homes over the plan period (2013 - 2033). As set out within this representation, the provision of a greater number of new homes is clearly a reasonable alternative that merits consideration. However, there appears to be no assessment of the sustainability of a higher level of growth.
See attached
Object
Draft Local Plan
Representation ID: 16056
Received: 13/05/2016
Respondent: Elizabeth Finn Care
Agent: Strutt & Parker LLP
In terms of our client's land at Rayleigh Road, Hutton the site appears to have been appraised as Site ID 219 within Table C of the SA, though this may in fact relate to the larger site in which the submitted site sits and which was assessed as part of the SHLAA 2011. We note that the text which accompanies Table C of the SA states that it presents an appraisal of all site options in terms of all the appraisal criteria set out previously within the SA. However, it also states the following:
"To reiterate, this table is presented for completeness. It is recognised that only limited understanding can be gained from strict GIS analysis; and equally it is recognised that presenting appraisal findings for all site options in tabular format is in practice of limited assistance to those interested in the spatial strategy".
We note, for example, that Site ID 219 has been assessed as performing "particularly poorly" against the Conservation Criteria, simply by virtue of being in the Conservation Area. We would question the robustness of such an approach.
We have been unable to identify the justification within the SA for the failure to include land adjacent to Rayleigh Road, Hutton as site for residential development in the DLP. The site is considered to be a sustainable location for development and the SA should reflect this in its assessment of the site.
See attached
Object
Draft Local Plan
Representation ID: 16071
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
Late in the process of preparing the Draft Plan, land at West Horndon has been rejected for strategic growth in favour of an allocation at Dunton. At paragraph 7.10 the Draft Plan confirms "Land around West Horndon Village remains a reasonable alternative because it can provide for similar development numbers towards local needs." The only justification given for rejecting this highly sustainable
location for growth is that "it has not been selected as a preferred site in this Draft Plan owing to impacts on the existing village, which would not be consistent with emerging spatial strategy."
The rejection of this alternative site is not supported by sustainability assessment. Indeed the limited assessment that has been undertaken gives more support to West Horndon as a strategic site for growth, based on landscape impact. We would add to this that an extension to an existing village served by a railway station and community services and facilities must be more sustainable than a randomly located site on open green fields that is not contained by defensible boundaries. This conclusion is summed up in the latest SA Interim report of February 2016 that states:
"The process of the assessment of sites that are suitable, available and deliverable for development within the Borough is on-going."
"The appraisal finds that the Draft Plan is set to result in significant positive effects in terms of housing and economy/employment objectives, but significant negative effects in terms of landscape objectives."
Specifically in respect of Dunton: "at the current time it remains appropriate to 'flag' the potential for significant negative effects given the uncertainty that remains regarding Dunton Hills Garden Village". (The key words are highlighted in bold and in red print by the authors of the Interim SA).
See attached
Object
Draft Local Plan
Representation ID: 16080
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
As a minimum, consultation is required on the scope of the SA and the SA report accompanying the Draft Plan. It is best practice for consultation to take place on SA during the plan preparation process for example through the production of interim SA Report and other means such as workshops and working groups.
The testing of the options and reasonable alternatives within the SA is required, however the evidence base is not complete nor up to date.
The land to the east of West Horndon performs better in the SA than the proposed Dunton Hills Garden Village.
See attached
Object
Draft Local Plan
Representation ID: 16140
Received: 16/05/2016
Respondent: EA Strategic Land LLP
Agent: Iceni Projects Limited
In considering the proposals for the Dunton Hills Garden Suburb, the SA stated that:
"Considerable assumptions [have been made] regarding how options would be implemented 'on the ground' and what the effect on particular receptors would be.... In many instances, given reasonable assumptions, it is not possible to predict likely significant effects, but it is possible to comment on the merits of an option in more general terms." EASL is unaware that a detailed analysis of the likely significant effects on the proposed development at Dunton Hills has yet been undertaken and considers there is a complete lack of evidence to support these proposals as a sustainable development. There is no evidence as to where the figure of 2,500 homes has come from.
See attached.