Draft Plan Spatial Strategy

Showing comments and forms 31 to 59 of 59

Support

Draft Local Plan

Representation ID: 14992

Received: 26/04/2016

Respondent: Mr and Mrs Simon and Jeanie Hughes

Number of people: 2

Representation Summary:

Providing accommodation to the growing population is best served by finding large plots where a cross section of housing can be offered. Therefore thought the option of Officers Meadow and other such large sites should generally be supported

The large extent of 'fill in' housing should only be done if it does not change the character of the living conditions of those houses near to the 'fill in' plots.

Full text:

My wife and I attended the presentation evening at Shenfield Parish Hall and now respond to what we saw.

1. We accept the need for more housing as Brentwood's contribution to providing accommodation to the growing population and think this is best served by finding large plots where a cross section of housing can be offered

2. We therefore thought the option of Officers Meadow (near to us) and other such large sites should generally be supported

3. We have far more doubts about the large extent of 'fill in' housing that seems to be in the plan which should only be done if it does not change the character of the living conditions of those houses near to the 'fill in' plots

4. Specifically the plot off Priests Lane would seem likely to add to the already crowded road conditions in peak periods and, unless a solution can be found to that problem, be a poor choice

5. We are also very strong in our opinion that building housing should come with a plan for services. (I grew up in Chelmsford whose character was wrecked by house building fast out running the creation of services and leisure facilities).

6. In that context the plan to build football pitches for Hutton FC (I am not a member and have nothing to do with them) near to Officers Meadow is an excellent one but should be extended to build an all year round facility perhaps including cricket and tennis and even bowls for the summer to the assets are used fully

7. We also feel that there is likely to be a continuing under provision of homes for the elderly as well as the young first home seekers. There are many large family homes in Brentwood and Shenfield that are now occupied by two people. The lack of quality homes in which they could downsize (and the badly thought out stamp duty tax) means many of the over 60s will sit tight whereas the town would be best served by accommodating their move and freeing up the family homes. This is not just about bungalows but apartments and smaller homes near services

8. Lastly a specific point as you had a display about flooding. There is an underground stream under the Courage Fields that runs under the housing onto Chelmsford Road and leads to some flooding when rain is heavy (noticeable on the corner by the Vets). It is not yet a major problem but should be noted and nothing done to make it worse

Attachments:

Object

Draft Local Plan

Representation ID: 15038

Received: 27/04/2016

Respondent: Mrs Christine Blythe

Representation Summary:

The draft Local Plan disproportionally favours the centre and south of the Borough, along existing transport corridors that are ready congested, while failing to take into account the needs of existing villages in the north of the Borough, like Blackmore. The Strategic Growth Options consultation document (2015) recognizes that villages must grow to provide for local need, the current draft Spatial Strategy fails to take this into account. Where is the evidence to support this U‐turn in planning policy?

Full text:

1.
I strongly object to the current Spatial Strategy in the draft Local Plan. It fails to take into account the needs of existing villages in the north of the Borough.

The draft Local Plan disproportionally favours the centre and south of the Borough, along existing transport corridors that are already congested, while failing to take into account the needs of existing villages in the north of the Borough, like Blackmore. The Strategic Growth Options consultation document (2015) recognizes that villages must grow to provide for local need, the current draft Spatial Strategy fails to take this into account. Where is the evidence to support this U-turn in planning policy?

2.
Has the Council provided a Settlement Hierarchy paper to assess the needs at local villages?

For example what is the justification in allowing development at Mountessing, rather than larger villages further north in the Borough, like Blackmore? If the Council is basing the plan on transport corridors alone, it has failed to objectively assess the needs across the entire Borough.

3.
SO's 1 &2 (pg 25) prejudice development growth to existing or proposed infrastructure to the centre and south of the Borough. The Council has a duty of care to ensure the entire Borough's needs are met to 2033 and the draft plan only meets the needs of part of the Borough.

4.
S03 is not being met in the north of the Borough in the respect of creating "inclusive, balanced, sustainable communities" (p25) to the year 2033. An objectively assessed local plan would recognize the need to ensure that existing villages, like Blackmore, need some development to retain their working population which will ensure that services such as local shops, leisure amenities, primary schools, GP practices and public transport services are sustained.

5.
The proposed plan fails to spread economic prosperity across the Borough and in particular in the north of the Borough. SO4, S05, S06, S07 promoting Economic Prosperity in the Borough (pg 25) focus on Brentwood and new development in the south of the Borough. There is no evidence that this plan seeks to implement SO8 (Promote and support a prosperous rural economy) in the north of the Borough because no GB development is planned, despite there being no brownfield opportunities.

6.
How do you define "inappropriate" (S09 Safeguard the Green Belt from inappropriate development and enhance its beneficial use, pg 26)? A 10% increase in existing villages for the next 20 years (is "inappropriate") but the creation of a new garden village of 2,500 houses (is "appropriate")?

7. How do you define "character"?

Para. 5.21 of the draft plan indicate's that development in the rural north and rural south will be limited to retain local "character". Throughout the plan there are references to safeguarding the GB land and then the need to release some GB land for development as 96% of the Borough falls in GB allocation. Surely the loss of village services as a result of inadequate housing and subsequent decline in the working age community will result in a detrimental "character"?

8. Assessment of GB Site

An assessment of 60 GB sites was produced after this plan was written. And yet the draft plan proposes to create a new garden village at Dunton Hills on GB land that is rated "medium value", for 2,500 new homes (35%) of housing needs in the Borough to 2033, compared to SHLAA site G070A, Land South of Redrose Lane, Blackmore, being promoted by Crest Nicholson for circa 40 houses within the village with clearly defensible boundaries is also rated "medium" but not part of the proposed allocation plan. A Local Housing Requirements Study for Blackmore by Barton Wilmore in August 2013 projected household growth in the village required circa 80 dwellings in the next 20 years.

9. Villages in the north of the Borough will atrophy over the period of the plan.

As the plan covers the to period 2033, Blackmore and some of the other larger villages in the north of the Borough will atrophy in this timespan. How when both sites are rated GB "medium value" can it be justified to "create" rather than "sustain" a village?

Furthermore as the Council has noted "new housing growth will deliver a boost to the local economy" para. 5.39 Why then is there no consideration of the larger villages, like Blackmore in the north of the Borough?

10.
I strongly object to the creation of a new garden village at Dunton Hills.
The proposed new village is not equitable, deliverable or sustainable, requires the release of a significant area of GB land, adds more pressure to the already congested A127, is disproportionate in terms of total housing capacity for the Borough from one single source and will not be deliverable within a reasonable timeframe. I strongly disagree that para 5.41 "A proportionate approach has been taken...". It is clear contrary to para 5.42 the Council has NOT "applied densities to potential development sites in a realistic manner...".

11. Brownfield Redevelopment Opportunities in the rural north and rural south of the Borough

These "Brownfield redevelopment opportunities" (para 5.33) do not exist in the GB villages to the north of the Borough. The case has been made in this draft plan that larger villages in the rural north of the Borough have limited services/amenities and therefore development should not take place here. A limited amount of development needs to take place here to ensure the future vitality and viability of villages like Blackmore. This does not mean changing the "character" of the north of the Borough but rather managing growth in a discrete and viable way.

12.
I strongly disagree with the statement para 5.41 "the Council has reluctantly considered appropriate and sustainable locations within Green Belt". (See point 8 above)

With regard to S010 (Protect & enhance valuable landscape & the natural and historic environment), Figure 9.1 Environment and Biodiversity (p126) indicates that the proposed development sites to the south of the Borough are in areas of a high concentration of both local wildlife sites and sites of special scientific interest, compared to those in the north of the Borough which have a much lower concentration of these sites.

What justification can there be to allow the development of 2,500 houses in one area in GB, while not allowing a 10% growth of existing villages in the next 20 years. Para 9.53 "Development will be restricted to those limited types of development which may be allowed in exceptional circumstances within the Green Belt" but barring Brownfield opportunities such development has been excluded in the rural villages of the north of the Borough.

13.
With regard to SO11, S012, S13 re the Quality of Life & Community Infrastructure, rural villages to the north of the Borough have been largely overlooked.

For example S012 Improving public transport, cycle and walking facilities and encourage sustainable transport choices should be implemented throughout the Borough. Villages such as Blackmore need to maintain a demand for a bus service for it to be economically viable for services to run which means the village needs to maintain an active, balanced community. The existing road network needs to be maintained to 2033 to enable rural villages to reach existing and new services/amenities available in the Brentwood area.

The bias of the current plan is again evidenced by the lack of a proposed Green Travel Route linking villages to the north of the Borough to Brentwood and/or train links. Figure 10.1 Proposes a Green Travel Route to support the proposed development in the south, while ignoring linkages and benefits for those villages in the north of the Borough.

Ensuring a viable bus service, maintaining current road networks and implementing a Green Travel Route to the north of Brentwood would be in line with S011 & S012.

S013 benefits the centre and south of the Borough alone if the plan allows for no development to take place in the rural north. It seems that the population of the Borough is intended to be concentrated in a confined geographic area. It must be possible to protect and enjoy the GB in the Borough while at the same time permitting a more equitable dispersal of the population in the area available.

14. Primary school places in the Borough

I note that Brentwood has capacity for secondary school places but limited capacity for primary school places. Building new villages and new schools takes a significant amount of time. Keeping primary schools open in rural villages is key to ensuring an "inclusive, balanced, sustainable" pg 25 S03 community. Primary school capacity currently exists within the village of Blackmore and perhaps within other villages. Do we need to create a new village or focus on maintaining the ones that currently exist?

15. Housing Trajectory

Para 5.46 states that "The Council has strived to be realistic about the likelihood of sites coming forward .... A clear commitment is shown in this Plan to bring forward land as quickly as possible to meet housing needs swiftly in line with national policy and guidance."

May I ask why, when in the Council's SHLAA (2010) and Draft Site Assessment (July 2013) site (ref 70A, site 076 in this plan) is identified as a suitable site for development of new housing being within defensible boundaries of the village and available to be delivered within 1-5 years, the Council's new spatial policy eliminates this site?

Crest Nicholson, second time National Builder of the Year, have a vision statement that identifies the benefits and opportunities to Blackmore for the development of site 076. I believe it can be proven that it falls within national policy and guidance. This site is achievable and could assist with the five year housing suppy. This complies with site selection para 7.29 "The fourth tier allows for limited greenfield sites in the GB which comprise urban extensions within reach of services and infrastructure and with defensible boundaries".

16. Travel by non-car modes

It is not reasonable to have a policy para. 7.62 that requires: "the ability to travel by non-car modes" in a Borough with an extensive rural community. This again demonstrates extreme bias and a lack of consideration for assuring the future viability of the Borough's rural villages in the north. Furthermore if development is to be limited to areas where non-car modes exist, then the local plan will be spatially inequitable... as this draft is.

Thank you for re-considering these points and re-examining the draft plan.

Attachments:

Object

Draft Local Plan

Representation ID: 15043

Received: 27/04/2016

Respondent: Mrs Christine Blythe

Representation Summary:

Has the Council provided a Settlement Hierarchy paper to assess the needs at local villages?

For example what is the justification in allowing development at Mountessing, rather than larger villages further north in the Borough, like Blackmore? If the Council is basing the plan on transport corridors alone, it has failed to objectively assess the needs across the entire Borough.

A Local Housing Requirements Study for Blackmore by Barton Wilmore in August 2013 projected household growth in the village required circa 80 dwellings in the next 20 years.

Full text:

1.
I strongly object to the current Spatial Strategy in the draft Local Plan. It fails to take into account the needs of existing villages in the north of the Borough.

The draft Local Plan disproportionally favours the centre and south of the Borough, along existing transport corridors that are already congested, while failing to take into account the needs of existing villages in the north of the Borough, like Blackmore. The Strategic Growth Options consultation document (2015) recognizes that villages must grow to provide for local need, the current draft Spatial Strategy fails to take this into account. Where is the evidence to support this U-turn in planning policy?

2.
Has the Council provided a Settlement Hierarchy paper to assess the needs at local villages?

For example what is the justification in allowing development at Mountessing, rather than larger villages further north in the Borough, like Blackmore? If the Council is basing the plan on transport corridors alone, it has failed to objectively assess the needs across the entire Borough.

3.
SO's 1 &2 (pg 25) prejudice development growth to existing or proposed infrastructure to the centre and south of the Borough. The Council has a duty of care to ensure the entire Borough's needs are met to 2033 and the draft plan only meets the needs of part of the Borough.

4.
S03 is not being met in the north of the Borough in the respect of creating "inclusive, balanced, sustainable communities" (p25) to the year 2033. An objectively assessed local plan would recognize the need to ensure that existing villages, like Blackmore, need some development to retain their working population which will ensure that services such as local shops, leisure amenities, primary schools, GP practices and public transport services are sustained.

5.
The proposed plan fails to spread economic prosperity across the Borough and in particular in the north of the Borough. SO4, S05, S06, S07 promoting Economic Prosperity in the Borough (pg 25) focus on Brentwood and new development in the south of the Borough. There is no evidence that this plan seeks to implement SO8 (Promote and support a prosperous rural economy) in the north of the Borough because no GB development is planned, despite there being no brownfield opportunities.

6.
How do you define "inappropriate" (S09 Safeguard the Green Belt from inappropriate development and enhance its beneficial use, pg 26)? A 10% increase in existing villages for the next 20 years (is "inappropriate") but the creation of a new garden village of 2,500 houses (is "appropriate")?

7. How do you define "character"?

Para. 5.21 of the draft plan indicate's that development in the rural north and rural south will be limited to retain local "character". Throughout the plan there are references to safeguarding the GB land and then the need to release some GB land for development as 96% of the Borough falls in GB allocation. Surely the loss of village services as a result of inadequate housing and subsequent decline in the working age community will result in a detrimental "character"?

8. Assessment of GB Site

An assessment of 60 GB sites was produced after this plan was written. And yet the draft plan proposes to create a new garden village at Dunton Hills on GB land that is rated "medium value", for 2,500 new homes (35%) of housing needs in the Borough to 2033, compared to SHLAA site G070A, Land South of Redrose Lane, Blackmore, being promoted by Crest Nicholson for circa 40 houses within the village with clearly defensible boundaries is also rated "medium" but not part of the proposed allocation plan. A Local Housing Requirements Study for Blackmore by Barton Wilmore in August 2013 projected household growth in the village required circa 80 dwellings in the next 20 years.

9. Villages in the north of the Borough will atrophy over the period of the plan.

As the plan covers the to period 2033, Blackmore and some of the other larger villages in the north of the Borough will atrophy in this timespan. How when both sites are rated GB "medium value" can it be justified to "create" rather than "sustain" a village?

Furthermore as the Council has noted "new housing growth will deliver a boost to the local economy" para. 5.39 Why then is there no consideration of the larger villages, like Blackmore in the north of the Borough?

10.
I strongly object to the creation of a new garden village at Dunton Hills.
The proposed new village is not equitable, deliverable or sustainable, requires the release of a significant area of GB land, adds more pressure to the already congested A127, is disproportionate in terms of total housing capacity for the Borough from one single source and will not be deliverable within a reasonable timeframe. I strongly disagree that para 5.41 "A proportionate approach has been taken...". It is clear contrary to para 5.42 the Council has NOT "applied densities to potential development sites in a realistic manner...".

11. Brownfield Redevelopment Opportunities in the rural north and rural south of the Borough

These "Brownfield redevelopment opportunities" (para 5.33) do not exist in the GB villages to the north of the Borough. The case has been made in this draft plan that larger villages in the rural north of the Borough have limited services/amenities and therefore development should not take place here. A limited amount of development needs to take place here to ensure the future vitality and viability of villages like Blackmore. This does not mean changing the "character" of the north of the Borough but rather managing growth in a discrete and viable way.

12.
I strongly disagree with the statement para 5.41 "the Council has reluctantly considered appropriate and sustainable locations within Green Belt". (See point 8 above)

With regard to S010 (Protect & enhance valuable landscape & the natural and historic environment), Figure 9.1 Environment and Biodiversity (p126) indicates that the proposed development sites to the south of the Borough are in areas of a high concentration of both local wildlife sites and sites of special scientific interest, compared to those in the north of the Borough which have a much lower concentration of these sites.

What justification can there be to allow the development of 2,500 houses in one area in GB, while not allowing a 10% growth of existing villages in the next 20 years. Para 9.53 "Development will be restricted to those limited types of development which may be allowed in exceptional circumstances within the Green Belt" but barring Brownfield opportunities such development has been excluded in the rural villages of the north of the Borough.

13.
With regard to SO11, S012, S13 re the Quality of Life & Community Infrastructure, rural villages to the north of the Borough have been largely overlooked.

For example S012 Improving public transport, cycle and walking facilities and encourage sustainable transport choices should be implemented throughout the Borough. Villages such as Blackmore need to maintain a demand for a bus service for it to be economically viable for services to run which means the village needs to maintain an active, balanced community. The existing road network needs to be maintained to 2033 to enable rural villages to reach existing and new services/amenities available in the Brentwood area.

The bias of the current plan is again evidenced by the lack of a proposed Green Travel Route linking villages to the north of the Borough to Brentwood and/or train links. Figure 10.1 Proposes a Green Travel Route to support the proposed development in the south, while ignoring linkages and benefits for those villages in the north of the Borough.

Ensuring a viable bus service, maintaining current road networks and implementing a Green Travel Route to the north of Brentwood would be in line with S011 & S012.

S013 benefits the centre and south of the Borough alone if the plan allows for no development to take place in the rural north. It seems that the population of the Borough is intended to be concentrated in a confined geographic area. It must be possible to protect and enjoy the GB in the Borough while at the same time permitting a more equitable dispersal of the population in the area available.

14. Primary school places in the Borough

I note that Brentwood has capacity for secondary school places but limited capacity for primary school places. Building new villages and new schools takes a significant amount of time. Keeping primary schools open in rural villages is key to ensuring an "inclusive, balanced, sustainable" pg 25 S03 community. Primary school capacity currently exists within the village of Blackmore and perhaps within other villages. Do we need to create a new village or focus on maintaining the ones that currently exist?

15. Housing Trajectory

Para 5.46 states that "The Council has strived to be realistic about the likelihood of sites coming forward .... A clear commitment is shown in this Plan to bring forward land as quickly as possible to meet housing needs swiftly in line with national policy and guidance."

May I ask why, when in the Council's SHLAA (2010) and Draft Site Assessment (July 2013) site (ref 70A, site 076 in this plan) is identified as a suitable site for development of new housing being within defensible boundaries of the village and available to be delivered within 1-5 years, the Council's new spatial policy eliminates this site?

Crest Nicholson, second time National Builder of the Year, have a vision statement that identifies the benefits and opportunities to Blackmore for the development of site 076. I believe it can be proven that it falls within national policy and guidance. This site is achievable and could assist with the five year housing suppy. This complies with site selection para 7.29 "The fourth tier allows for limited greenfield sites in the GB which comprise urban extensions within reach of services and infrastructure and with defensible boundaries".

16. Travel by non-car modes

It is not reasonable to have a policy para. 7.62 that requires: "the ability to travel by non-car modes" in a Borough with an extensive rural community. This again demonstrates extreme bias and a lack of consideration for assuring the future viability of the Borough's rural villages in the north. Furthermore if development is to be limited to areas where non-car modes exist, then the local plan will be spatially inequitable... as this draft is.

Thank you for re-considering these points and re-examining the draft plan.

Attachments:

Object

Draft Local Plan

Representation ID: 15056

Received: 27/04/2016

Respondent: Mrs Christine Blythe

Representation Summary:

As the plan covers the to period 2033, Blackmore and some of the other larger villages in the north of the Borough will atrophy in this timespan. How when both sites are rated GB "medium value" can it be justified to "create" rather than "sustain" a village?

Furthermore as the Council has noted "new housing growth will deliver a boost to the local economy" para. 5.39 Why then is there no consideration of the larger villages, like Blackmore in the north of the Borough?

Full text:

1.
I strongly object to the current Spatial Strategy in the draft Local Plan. It fails to take into account the needs of existing villages in the north of the Borough.

The draft Local Plan disproportionally favours the centre and south of the Borough, along existing transport corridors that are already congested, while failing to take into account the needs of existing villages in the north of the Borough, like Blackmore. The Strategic Growth Options consultation document (2015) recognizes that villages must grow to provide for local need, the current draft Spatial Strategy fails to take this into account. Where is the evidence to support this U-turn in planning policy?

2.
Has the Council provided a Settlement Hierarchy paper to assess the needs at local villages?

For example what is the justification in allowing development at Mountessing, rather than larger villages further north in the Borough, like Blackmore? If the Council is basing the plan on transport corridors alone, it has failed to objectively assess the needs across the entire Borough.

3.
SO's 1 &2 (pg 25) prejudice development growth to existing or proposed infrastructure to the centre and south of the Borough. The Council has a duty of care to ensure the entire Borough's needs are met to 2033 and the draft plan only meets the needs of part of the Borough.

4.
S03 is not being met in the north of the Borough in the respect of creating "inclusive, balanced, sustainable communities" (p25) to the year 2033. An objectively assessed local plan would recognize the need to ensure that existing villages, like Blackmore, need some development to retain their working population which will ensure that services such as local shops, leisure amenities, primary schools, GP practices and public transport services are sustained.

5.
The proposed plan fails to spread economic prosperity across the Borough and in particular in the north of the Borough. SO4, S05, S06, S07 promoting Economic Prosperity in the Borough (pg 25) focus on Brentwood and new development in the south of the Borough. There is no evidence that this plan seeks to implement SO8 (Promote and support a prosperous rural economy) in the north of the Borough because no GB development is planned, despite there being no brownfield opportunities.

6.
How do you define "inappropriate" (S09 Safeguard the Green Belt from inappropriate development and enhance its beneficial use, pg 26)? A 10% increase in existing villages for the next 20 years (is "inappropriate") but the creation of a new garden village of 2,500 houses (is "appropriate")?

7. How do you define "character"?

Para. 5.21 of the draft plan indicate's that development in the rural north and rural south will be limited to retain local "character". Throughout the plan there are references to safeguarding the GB land and then the need to release some GB land for development as 96% of the Borough falls in GB allocation. Surely the loss of village services as a result of inadequate housing and subsequent decline in the working age community will result in a detrimental "character"?

8. Assessment of GB Site

An assessment of 60 GB sites was produced after this plan was written. And yet the draft plan proposes to create a new garden village at Dunton Hills on GB land that is rated "medium value", for 2,500 new homes (35%) of housing needs in the Borough to 2033, compared to SHLAA site G070A, Land South of Redrose Lane, Blackmore, being promoted by Crest Nicholson for circa 40 houses within the village with clearly defensible boundaries is also rated "medium" but not part of the proposed allocation plan. A Local Housing Requirements Study for Blackmore by Barton Wilmore in August 2013 projected household growth in the village required circa 80 dwellings in the next 20 years.

9. Villages in the north of the Borough will atrophy over the period of the plan.

As the plan covers the to period 2033, Blackmore and some of the other larger villages in the north of the Borough will atrophy in this timespan. How when both sites are rated GB "medium value" can it be justified to "create" rather than "sustain" a village?

Furthermore as the Council has noted "new housing growth will deliver a boost to the local economy" para. 5.39 Why then is there no consideration of the larger villages, like Blackmore in the north of the Borough?

10.
I strongly object to the creation of a new garden village at Dunton Hills.
The proposed new village is not equitable, deliverable or sustainable, requires the release of a significant area of GB land, adds more pressure to the already congested A127, is disproportionate in terms of total housing capacity for the Borough from one single source and will not be deliverable within a reasonable timeframe. I strongly disagree that para 5.41 "A proportionate approach has been taken...". It is clear contrary to para 5.42 the Council has NOT "applied densities to potential development sites in a realistic manner...".

11. Brownfield Redevelopment Opportunities in the rural north and rural south of the Borough

These "Brownfield redevelopment opportunities" (para 5.33) do not exist in the GB villages to the north of the Borough. The case has been made in this draft plan that larger villages in the rural north of the Borough have limited services/amenities and therefore development should not take place here. A limited amount of development needs to take place here to ensure the future vitality and viability of villages like Blackmore. This does not mean changing the "character" of the north of the Borough but rather managing growth in a discrete and viable way.

12.
I strongly disagree with the statement para 5.41 "the Council has reluctantly considered appropriate and sustainable locations within Green Belt". (See point 8 above)

With regard to S010 (Protect & enhance valuable landscape & the natural and historic environment), Figure 9.1 Environment and Biodiversity (p126) indicates that the proposed development sites to the south of the Borough are in areas of a high concentration of both local wildlife sites and sites of special scientific interest, compared to those in the north of the Borough which have a much lower concentration of these sites.

What justification can there be to allow the development of 2,500 houses in one area in GB, while not allowing a 10% growth of existing villages in the next 20 years. Para 9.53 "Development will be restricted to those limited types of development which may be allowed in exceptional circumstances within the Green Belt" but barring Brownfield opportunities such development has been excluded in the rural villages of the north of the Borough.

13.
With regard to SO11, S012, S13 re the Quality of Life & Community Infrastructure, rural villages to the north of the Borough have been largely overlooked.

For example S012 Improving public transport, cycle and walking facilities and encourage sustainable transport choices should be implemented throughout the Borough. Villages such as Blackmore need to maintain a demand for a bus service for it to be economically viable for services to run which means the village needs to maintain an active, balanced community. The existing road network needs to be maintained to 2033 to enable rural villages to reach existing and new services/amenities available in the Brentwood area.

The bias of the current plan is again evidenced by the lack of a proposed Green Travel Route linking villages to the north of the Borough to Brentwood and/or train links. Figure 10.1 Proposes a Green Travel Route to support the proposed development in the south, while ignoring linkages and benefits for those villages in the north of the Borough.

Ensuring a viable bus service, maintaining current road networks and implementing a Green Travel Route to the north of Brentwood would be in line with S011 & S012.

S013 benefits the centre and south of the Borough alone if the plan allows for no development to take place in the rural north. It seems that the population of the Borough is intended to be concentrated in a confined geographic area. It must be possible to protect and enjoy the GB in the Borough while at the same time permitting a more equitable dispersal of the population in the area available.

14. Primary school places in the Borough

I note that Brentwood has capacity for secondary school places but limited capacity for primary school places. Building new villages and new schools takes a significant amount of time. Keeping primary schools open in rural villages is key to ensuring an "inclusive, balanced, sustainable" pg 25 S03 community. Primary school capacity currently exists within the village of Blackmore and perhaps within other villages. Do we need to create a new village or focus on maintaining the ones that currently exist?

15. Housing Trajectory

Para 5.46 states that "The Council has strived to be realistic about the likelihood of sites coming forward .... A clear commitment is shown in this Plan to bring forward land as quickly as possible to meet housing needs swiftly in line with national policy and guidance."

May I ask why, when in the Council's SHLAA (2010) and Draft Site Assessment (July 2013) site (ref 70A, site 076 in this plan) is identified as a suitable site for development of new housing being within defensible boundaries of the village and available to be delivered within 1-5 years, the Council's new spatial policy eliminates this site?

Crest Nicholson, second time National Builder of the Year, have a vision statement that identifies the benefits and opportunities to Blackmore for the development of site 076. I believe it can be proven that it falls within national policy and guidance. This site is achievable and could assist with the five year housing suppy. This complies with site selection para 7.29 "The fourth tier allows for limited greenfield sites in the GB which comprise urban extensions within reach of services and infrastructure and with defensible boundaries".

16. Travel by non-car modes

It is not reasonable to have a policy para. 7.62 that requires: "the ability to travel by non-car modes" in a Borough with an extensive rural community. This again demonstrates extreme bias and a lack of consideration for assuring the future viability of the Borough's rural villages in the north. Furthermore if development is to be limited to areas where non-car modes exist, then the local plan will be spatially inequitable... as this draft is.

Thank you for re-considering these points and re-examining the draft plan.

Attachments:

Object

Draft Local Plan

Representation ID: 15093

Received: 28/04/2016

Respondent: Graham Palmer

Representation Summary:

Brentwood cannot fulfil housing targets due to greenbelt constraints and should not consider re-designating greenbelt land as viable for development as it has done with land where the A127 meets the M25, this was supposed to be used temporarily and returned to greenbelt.
Castle Point council has refused to consider building on their greenbelt and our councillors should also refuse to build on greenbelt as it is vital to keep us from becoming an extension of London, the London Borough of Brentwood, It is also vital environmentally to help keep our air clean, the pollution in the air is already dangerously close to illegal levels

Full text:

I object to ANY proposals to build on greenbelt land including the planned dunton garden village, I feel the supposed need for 5000 to 6000 houses is not to cater for the existing residents in the Brentwood area but will be mostly for people coming in to the area from other places. We do not have the necessary infrastructure to support this many new residents, the roads, schools, doctors, hospitals are already struggling to cope with the needs of the existing locals
Brentwood cannot fulfil housing targets due to greenbelt constraints and should not consider re-designating greenbelt land as viable for development as it has done with land where the A127 meets the M25, this was supposed to be used temporarily and returned to greenbelt.
Castle Point council has refused to consider building on their greenbelt and our councillors should also refuse to build on greenbelt as it is vital to keep us from becoming an extension of London, the London Borough of Brentwood, It is also vital environmentally to help keep our air clean, the pollution in the air is already dangerously close to illegal levels

Object

Draft Local Plan

Representation ID: 15192

Received: 29/04/2016

Respondent: Crest Nicholson

Agent: Savills UK

Representation Summary:

The draft Spatial Strategy fails to consider the local needs of the more rural areas within the Borough and is contrary to the views of the Council in the Strategic Growth Options consultation document (2015) in which it stated that "it is important to consider allowing villages to grow in order to provide for local need". There remains a need to do this for a number of reasons: to address local issues of affordability, to retain the working age population within villages, to ensure the viability and vitality of local shops and to ensure the sustainability of local services, including schools.

There should be some development land allocated in villages through Green Belt release, including Blackmore.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15194

Received: 29/04/2016

Respondent: Crest Nicholson

Agent: Savills UK

Representation Summary:

Paragraph 5.21 - There are very limited brownfield sites to develop within the Rural Areas. As such there will there be little or no growth within the Villages which again will only worsen local issues of affordability and put additional pressure on viability and vitality of local shops and services.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15196

Received: 29/04/2016

Respondent: Crest Nicholson

Agent: Savills UK

Representation Summary:

Paragraph 5.41 - No Green Belt release at large villages is clearly not a proportionate approach and is a U turn on the previous strategy as well as being contradictory to the Local Plan's strategic aims to meet local needs and ensure that village facilities continue to "thrive".

Paragraph 5.33 states that "No amendment is proposed to the Green Belt around larger villages in order to retain the character of the Borough". However, there is no definition of character. The loss of village services as a result of inadequate housing and subsequent decline in the working age population will result in a detrimental "character". Rural character is retained by allowing new housing to sustain village services and enabling community activity and interaction.

Spatial Strategy has not been considered in thorough and logical way.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15198

Received: 29/04/2016

Respondent: Crest Nicholson

Agent: Savills UK

Representation Summary:

As a result of the lack of development over recent years, the services within Blackmore village are under threat, which is evidenced by the closure of The Bull Public House.

Without the residential development to sustain local business and services, they will close and the quality and sustainability of the village will come under pressure.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15293

Received: 04/05/2016

Respondent: Transport for London

Representation Summary:

It is clear that the arrival of TfL-operated Crossrail (to be known as the Elizabeth line) services in 2019 at Brentwood and Shenfield will greatly improve the existing metro servi ces and connectivity to Stratford and central/west London, and will provide significant capacity increase on the inner Great Eastern Main Line in the short to medium term.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15294

Received: 04/05/2016

Respondent: Transport for London

Representation Summary:

Given the Local Plan covers the period to 2033, forecasts shows that there might be capacity issues on the Elizabeth line between Stratford and Central London in the 2030's, primarily due to expected high levels of growth in inner east London. Therefore, TfL is working on the East London Transport Option Study assessing various further transport options to relieve forecast capacity issues in this period. Further interventions could include lengthening Elizabeth line trains and/or frequency enhancements; however these are not yet committed and funded.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15305

Received: 04/05/2016

Respondent: Thorndon Park Golf Club Ltd.

Agent: JTS Partnership LLP

Representation Summary:

Despite having acknowledged the difficulties of meeting housing needs without the release of Green Belt sites, the Plan proposes no amendment to the Green Belt boundaries surrounding larger villages.

In the context that the housing needs are significantly greater than the Local Authority have been able to deliver in recent years, it will be sensible for small sites within the larger villages to contribute to overall housing provision and that there are opportunities for Greenfield urban extensions within the Green Belt to assist in overall housing delivery without demonstrable harm to the Green Belt or the character of the villages.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15671

Received: 10/05/2016

Respondent: Southend on Sea Council

Representation Summary:

With regard to additional housing development and infrastructure, Southend Borough Council notes that the A127, alongside the A130 and A13, forms a key route into Southend and this route is very important for business and residents within Southend and the wider area. As such it is vital that any development proposed in proximity to the strategic transport network provides the necessary infrastructure improvements and mitigation to support the additional growth; and to not have a negative impact on the strategic highway network. In additional, measures that promote the use of public transport and alternatives to the car should also be considered as part of these new developments and incorporated into policy.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15935

Received: 12/05/2016

Respondent: West Horndon Parish Council

Representation Summary:

5.20 of the Draft Local Plan states that a new village centre will be created for West Horndon, with supporting services and facilities close to the village rail station. No evidence is provided as to how this would be funded and provided, and indeed hence if this is a realistic assumption based on the other changes needed at sites 020 and 021 in order to make them suitable for large scale residential redevelopment.

Full text:

See eight attached documents

Attachments:

Object

Draft Local Plan

Representation ID: 15971

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

On Friday 13th March 2015 the Secretary of State for Communities and Local Govt and Brentwood MP Mr Eric Pickles categorically stated "If local authority's cannot meet their housing targets because of the Green Belt, that is NO reason to use the Green Belt".

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15972

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

Brentwood Borough Council acknowledge that 80% of growth from 2015-2033 will be from people moving into the borough from other parts of the UK. There is no local housing need to build on Brentwoods 2005 Green Belt. Green Belt is a material constraint 'which may restrain the ability of an authority to meets its need'. As per http://planningguidance.communities.gov.uk/blog/guidance/housing-and-economic-land-availability-assessment/stage-5-final-evidence-base/

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15973

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

Do local planning authorities have to meet in full housing needs identified in needs assessments? Local authorities should prepare a Strategic Housing Market Assessment to assess their full housing needs. However, assessing need is just the first stage in developing a Local Plan. Once need has been assessed, the local planning authority should prepare a Strategic Housing Land Availability Assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, and in so doing take account of any constraints such as Green Belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need. Revision date: 06 10 2014.
Clearly Brentwoods Green Belt does 'restrain the ability of an authority to meet its need'.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15974

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

Among a number of court cases, relating to greenbelt being a restraint on housing targets, is the following http://www.stalbans.gov.uk/Images/2013%20EWCA%20Civ%201610_tcm15-,38904.pdfthe
Within paragraph 6 of the Court of Appeals judgement its states;
'There is no doubt, that in proceeding their local plans, local planning authorities are required to ensure that the "full objectively assessed needs" for housing are to be met " as far as is consistent with policies st out in this framework". Those policies include the protection of greenbelt land. Indeed, a whole section of the framework, Section 9, is devoted to that topic, a section which begins by saying " The Government attaches great importance to Green Belts": Para 79. The Framework seems to envisage some review of Green Belt boundaries through the new Local Plan process but states that " the general extent of Green Belts across the country is already established." It seems clear, and is not in dispute in this appeal, that such a Local Plan could properly fall short of meeting the " full objectively assessed needs" for housing in its area because of the conflict which would otherwise arise with policies on the Green Belt...'.
Clearly this Court of Appeal judgement demonstrates Green Belt as a constraint to meeting " full objectively assessed needs" for housing. Brentwoods proposed LDP is particularly damaging and excessive in its proposed housing targets and there is absolutely no need for any re-designation of Green Belt for development.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15975

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

We do not have sufficient schools, doctors or hospital facilities to cope with a dramatic increase in the boroughs population. Basildon Hospital, which serves Brentwood, is on Black Alert most of the time and has no planned extra funding or plans for expansion.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15976

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

Road Infrastructure is insufficient and there are no planned budgets to make improvements to the very congested A127. Further road building will cause more pollution leading to increased ill health ie Asthma and a deterioration to residents quality of life with increased congestion and noise.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15977

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

In January 2016 Castle Point Council rejected their proposed Local Development Plan on the grounds that they will not submit to building on their Green Belt to meet housing targets, causing further urban sprawl and a convergence with neighbouring boroughs.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 15978

Received: 13/05/2016

Respondent: Herongate and Ingrave Parish Council

Representation Summary:

The greenbelt has, by and large, held firm to the original ideals for being set up as a green lung for London and to prevent urban sprawl. This proposed LDP is a full on frontal assault on the Green Belt and any re-designation of greenbelt land will create a precedent for its demise, as a whole, with subsequent LDP's every 10-15 years.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 16021

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Representation Summary:

Consider Plan will be found unsound due to duty to cooperate; objectively assessed housing need; Brentwoods housing growth strategy and the Sustainability Appraisal.
The following needs to be done to make the plan sound:
Review the current proposed number of homes to be provided 2013-2033 having regard to market signals and unmet housing need within areas with which the Borough is connected, to be determined through further working under the Duty to Cooperate with relevant Authorities.
Ensure that the Local Plan does not rely on the delivery of Dunton Garden Hills Village or windfall to meet housing needs, due to considerable uncertainty regarding their potential to deliver housing.
Reduce reliance on large strategic sites that will not be delivered in the short- term, and seek to address the current, urgent housing need through the identification of a range of smaller, deliverable sites in sustainable locations; and ensure the provision of a five-year housing land supply.
Apply a more sophisticated and transparent approach to site selection (and Sustainability Appraisal of potential sites) that considers the sustainability and deliverability of sites, along with their potential to relate to a spatial strategy for development linked to the settlement hierarchy.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 16027

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Representation Summary:

Noted that the Council are using the 362 dpA identified by the 2013 SHMA. Also noted that the OAHN considers the delivery of 411 dpA as a feasible target for Brentwood Borough. It is unclear on whet basis this level of growth was rejected. The borough should have regard to market signals and with the borouhs expensive housing cost, comparable to London prices, the figure should be revised upwards from the houshold projections. It is not clear from the DLP how unmet needs in neighbouring areas have been considered. On the contrary, the DLP indicates at paragraph 5.36 that only housing needs within the Brentwood Borough boundary have been addressed. The DLP recognises how well connected the Borough is with neighbouring areas and London. It follows that the Borough may be suitably placed to accommodate some of the unmet needs of such areas, and this should be explored through the Local Plan process if it is to avoid being unsound.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 16031

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Representation Summary:

The intrinsic economic benefit of housing development should be recognised and jobs relating to the supply chain. Housing development also engenders local economic benefits relating to additional local expenditure. It is important that the economic growth aspirations of the Local Plan and the housing growth policy support, rather than contradict, one another. There are clearly factors that suggest the Brentwood Local Plan should seek to deliver a greater number of homes than proposed in the DLP. At the very least the provision of a greater number of dwellings is a reasonable option that should be explored.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 16034

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Representation Summary:

Dunton Hills Garden Village requires support from Basildon which is not in evidence. The delivery of a development of the scale of Dunton Hills Garden Village would require collaborative working between a multitude of authorities, service / infrastructure providers, landowners and developers. the suitability and sustainability of Dunton Hills Garden Village is questionable, the proposed new station is not included in the Network Rail Anglia Route Study Draft for Consultation (November 2014), which sets out the strategic vision for the future of the Anglia route network over the next 30 years. The Dunton Garden Suburb consultation documents are largely silent on the access strategy and potential mitigation measures necessary to accommodate development traffic on the existing local and strategic highway network.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 16035

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Representation Summary:

The DLP strategy relies on windfall to deliver 928 dwellings - 12% of the proposed total. By definition, there is considerable uncertainty as to how much of a contribution windfall will be able to make towards delivery housing. It is far from clear that it will be able to make the level of contribution which the DLP assumes. Brentwood should not rely on windfall, as per para 47 of NPPF.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 16040

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

Representation Summary:

Figure 5.10 of the DLP shows that the current housing delivery rate is well below that required to meet what the Council consider to be the Borough's need. Furthermore, it is projected to remain below this level in the short-term. There is clearly a current, urgent housing need in the Borough. The DLP should not seek to rely on large strategic sites to deliver housing, as these cannot meet housing need in the short- term and enable the Borough to retain a five-year housing land supply, as required by the NPPF (para 47). To ensure the plan is capable of addressing the current urgent housing need and ensuring a five-year housing land supply a range of sites should be identified, including smaller sites that are deliverable in the short-term.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 16405

Received: 19/05/2016

Respondent: Mrs Winifred Wigington

Representation Summary:

Dissatisfied with the way in which Brentwood Borough Council has taken care to protect the village of Dunton Wayletts. In the Draft Plan the Council states it wants to protect the Green Belt around its villages, however Dunton Hills Garden Village combined with the development planned by Basildon Council would remove all the Green Belt land around Dunton Wayletts.

Full text:

Q1. Object to the Draft Plan

Q2. Very dissatisfied that Brentwood Borough Council proposes to located over one third of its new housing on the edge of their border next to Basildon, with the effect that the burden (e.g. infrastructure) will fall on the Borough of Basildon.

Q3. Very dissatisfied with the way in which Brentwood Borough Council are proposing to spread housing need across the Borough.

Q4. Very dissatisfied with the way in which Brentwood Borough Council is protecting the Green Belt and observing its aims. Added to the development plans of Basildon Council, the housing and industrial developments proposed would create an almost unbroken strip of development in the Green Belt along the A127, effectively joining Basildon to Upminster.

Q5. Very dissatisfied with the way in which Brentwood Borough Council has taken care to protect the village of Dunton Wayletts. In the Draft Plan the Council states it wants to protect the Green Belt around its villages, however Dunton Hills Garden Village combined with the development planned by Basildon Council would remove all the Green Belt land around Dunton Wayletts.

Q6. Very dissatisfied in relation to the likelihood / capability for the local road network to be improved sufficiently to handle the increased traffic. The new homes and industrial premises will add thousands more vehicles to the roads, on top of the traffic generated by Basildon's Plan. Roads such as the A127 already suffer regular congestion.

Q7. Dissatisfied in relation to the likelihood / capability of railway capacity to be increased sufficiently to accommodate the growth in passenger numbers. New homes proposed by Brentwood and Basildon Council will greatly increase the local population. The local railway service is currently overloaded at peak times.

Q8. Very dissatisfied in relation to the ability for local medical services to sufficiently cope with the increased capacity generated by the additional residents.

Q9. Very dissatisfied with the way in which Brentwood Borough Council have considered the impact that its plans would have on Dunton Wayletts, which is an important historical village.

Q10. Dissatisfied with the thought given to the risks associated with locating large housing development and schools in the Dunton area, which has extremely high levels of air pollution and is close to a major Accident Hazard Pipeline.

Q11. Very dissatisfied with the way in which Brentwood Borough Council's plans take account of the particular circumstances of those living in a mobile home. The great majority of Dunton Wayletts inhabitants live on Dunton Park.