Before going on to the third stage ('reluctantly' developing on the green belt), a feedback loop to the first stage must be added, mandating a higher density of buildings on non-green-belt sites. Only after covering every non-green-belt brownfield site with 100-storey skyscrapers should the Council countenance releasing a single square metre of green belt.

In practice, this means adding an explicit presumption against low-density housing being permitted at all (in other words, all new housing must be terraced or flats, and preference must be given to tall buildings -- the green belt is far, far more important than the skyline).

I respond the the current consultation of the draft Local Development Plan.

1. I oppose the loss of any greenbelt land to meet housing needs.
2. I challenge BBC as to why they have not contested/objected to the levels of housing development outlined on the basis of the greenbelts special needs.
3. I do not agree to the transport-corridor approach that BBC has adopted, I do not see this as a fair way of apportioning development Borough wide.
4. I refute the assumption that the A127 corridor has greater potential to sustain growth than the A12 corridor or elsewhere in the /borough.
5. Not all brownfield sites are allocated for housing redevelopment. Why?
6. I note that certain locations/areas of the Borough have requested some controlled development but this is being ignored. Why?
7. I vehemently oppose the proposals as set out for West Horndon.
8. I align my response with that as submitted by West Horndon Parish Council.
9. From an earlier consultation on the Dunton scheme, 84% of respondents opposed this. Why hne is it still being put forward?
10. West Horndon is being targeted with almost 60% of the entire Boroughs housing requirement. This is an increase on the 43% proposed in the 2013 draft! This increase is still being proposed despite the 84% objection rate to DGS.
11. DGV as proposed is not sustainable. Once again BBC has produced insufficient assessments to justify such a proposal.
12. Adjoining Authorities including Basildon and Thurrock objected to DGS as did Essex County Council. With such united rejection of the proposal, why does BBC persist with it?
13. Neither ECC nor Highways England have plans to upgrade the A127, again rendering the DGS proposal unsustainable.
14. I do support again in alignment with WHPC, for limited and controlled residential development of the current West horndon Industrial sites. However, this support would be subject a full transport.highways appraisal as the current entrance/exit to the site could absolutely not support 500 new homes with the additional traffic congestion this would bring with it!
15. Neither C2c or Network Rail have any scope to improve the current rail link. In fact recent changes to the timetable have in fact backfired causing WH residents more travel problems.
16. There are no assurances that the loss of employment land would be offered up at the new BEC.
17. Whilst Green Transport routes are mentioned in the document, here again there is no detail to support the intention for these routes.
18. West Horndon has a primary/junior school which already operates over capacity. Its doctors surgery is near capacity, any development simply has to come with the guarantee of amenities and infrastructure upgrade not just a proposal for it!

I respond the the current consultation of the draft Local Development Plan.

1. I oppose the loss of any greenbelt land to meet housing needs.
2. I challenge BBC as to why they have not contested/objected to the levels of housing development outlined on the basis of the greenbelts special needs.
3. I do not agree to the transport-corridor approach that BBC has adopted, I do not see this as a fair way of apportioning development Borough wide.
4. I refute the assumption that the A127 corridor has greater potential to sustain growth than the A12 corridor or elsewhere in the /borough.
5. Not all brownfield sites are allocated for housing redevelopment. Why?
6. I note that certain locations/areas of the Borough have requested some controlled development but this is being ignored. Why?
7. I vehemently oppose the proposals as set out for West Horndon.
8. I align my response with that as submitted by West Horndon Parish Council.
9. From an earlier consultation on the Dunton scheme, 84% of respondents opposed this. Why hne is it still being put forward?
10. West Horndon is being targeted with almost 60% of the entire Boroughs housing requirement. This is an increase on the 43% proposed in the 2013 draft! This increase is still being proposed despite the 84% objection rate to DGS.
11. DGV as proposed is not sustainable. Once again BBC has produced insufficient assessments to justify such a proposal.
12. Adjoining Authorities including Basildon and Thurrock objected to DGS as did Essex County Council. With such united rejection of the proposal, why does BBC persist with it?
13. Neither ECC nor Highways England have plans to upgrade the A127, again rendering the DGS proposal unsustainable.
14. I do support again in alignment with WHPC, for limited and controlled residential development of the current West horndon Industrial sites. However, this support would be subject a full transport.highways appraisal as the current entrance/exit to the site could absolutely not support 500 new homes with the additional traffic congestion this would bring with it!
15. Neither C2c or Network Rail have any scope to improve the current rail link. In fact recent changes to the timetable have in fact backfired causing WH residents more travel problems.
16. There are no assurances that the loss of employment land would be offered up at the new BEC.
17. Whilst Green Transport routes are mentioned in the document, here again there is no detail to support the intention for these routes.
18. West Horndon has a primary/junior school which already operates over capacity. Its doctors surgery is near capacity, any development simply has to come with the guarantee of amenities and infrastructure upgrade not just a proposal for it!

Provides essential housing for the area on a site that would not be prone detrimental to the environment. Additionally would reduce commercial lorry traffic in the area.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

I think Pilgrims Hatch area will benefit from more 3-4 bedroom houses.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

Need more affordable houses in Pilgrims Hatch area.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

More homes needed in Brentwood, Essex.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

Additional housing is required in this area. The proposal will provide much needed accomodation.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

Excellent idea. Much needed housing. A good site that fits in with local housing needs.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

Would be good for the community and help with housing shortage in Brentwood.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

More dwellings are required to help support local business.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

Better use of road.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

More dwellings in the area can proomote business for ourselves. Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

More housing needed and traffic will be less.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

More residents more work.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

We need more houses in the local area.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

More affordable housing required in Brentwood.

Page 47 Use of Brownfield land in the Green Belt supported.

Para 7.36 proposal for Pilgrims Hatch supported.

Page 78 site ref 010 Sow n Grow Nursery site supported for housing land allocation as a Brownfield Green Belt urban extension.

Policy 9.11 for redevelopment of brownfield land in the Green Belt is supported with explanatory paragraphs.

Policy 9.12 is supported for land release from the Green Belt with explanatory paragraphs.

Para 185 Appendix 2 is supported where the Sow n Grow site is listed no.010 approx. dwellings could be higher.

Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

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

2)Population Growth and Demographics

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







3)Highway Infrastructure

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


4)Green Travel Route

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


5)Public Rights of Way (PROW)

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


6)Financial

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

7)Conclusion

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

Having studied the draft local housing plan for Brentwood in some depth, I notice there is a plan to build on the land adjacent to the A12 (on its northern side) which is situated between the A12 and Viking Way. On a personal note, and I beg your indulgence as it is at odds with what I believe is best for our town, my wife and I have often said, during our thirty three years of residency here, that if this land was to be developed in the way proposed it would reduce, or even eradicate, the noise nuisance from the A12 that has increased over the years, mainly owing to regular resurfacing of the road resulting in it being higher now. As we find this so objectionable, I spent a great deal of time obtaining signatures on a petition for Vicki Davies who was able, on the strength of this, to arrange for noise testing to be done. The levels exceed those that are considered to be acceptable and it was proposed that a low noise surface be reinstated as this had reduced noise in the past. That was several years ago and nothing has been done!

It is common knowledge that for some years our housing stock has been diminishing, resulting in an increasing number of people being homeless, and I am a great believer in that something needs to be done to address this problem. I firmly believed that the best way forward was to develop brown fill areas such as the one local to me on the Highwood hospital site which, I believe, was very well done by the developers - a site to be proud of! Unfortunately, its completion has caused some problems.

After the houses on the site were fully occupied, I have it on good authority that when one of the GPs at the Brambles Surgery (the surgery situated on this site) retired, the local health authority refused to replace him. The NHS managers had expected his 1500 or so patients to be absorbed into existing local surgeries. One of these offered to run the practice as a branch surgery providing another GP could be employed my them, funded by the local health authority. The NHS managers, again, refused and this plan was only accepted when all the local surgeries closed their lists to new patients. Further to this, I learnt on the 2nd of February that there was a twenty six day wait for the first GP appointment at the surgery that I attend although, in fairness, patients are seen if the doctors feel the case is an emergency.

Since the Highwood hospital development, traffic between it and the centre of town has increased significantly. Testimony to this was one of our councillors complaining that he was finding it increasingly difficult to turn right out of Geary Drive onto the Ongar Road. This, of course, was remedied for him by the construction of the mini roundabout at this junction.

Although the draft plans discuss, very fully, the subject of infrastructure, considering the poor record of upgrading these to meet increasing needs, highlighted by the shortcomings above, I am not convinced that the residents of Brentwood would not suffer adversely if the proposals for the developments planned in the town and its environs are adopted.

Because of this, for some time now, I have come to recognise that the best solution for overcoming the housing shortage would be to build new towns well away from existing built up areas. There would almost certainly be some objections to this type of development by people living close to them but, owing to the relative remoteness of appropriate sites, the numbers objecting to and effected by them pale into insignificance compared to those living in already developed urban and suburban areas.

Other advantages of new towns/garden villages include, among other things, self sufficiency which means that all necessary facilities such as GP surgeries are included and, as such, are far more likely to meet the needs of residents compared to the erosion of services, as explained above, when attempting to boost existing facilities to meet additional needs. Although I am not in a position of knowledge to comment with any authority on schools, I suspect the same could be true of the provision of education for our young people.

Another obvious benefit of this type of development is, despite accommodating large numbers, the impact of traffic in local towns would be far less compared to that created by the provision of in town housing schemes - this also addresses one of my main concerns; one which I am sure is shared by many of Brentwood's residents.

With the above points in mind, I applaud the plan for Dunton Hills Garden Village and congratulate the planners for its conception. My greatest hope is that another area, or areas, could be developed in this way as an alternative to the additional housing being considered for development in Brentwood town and areas in close proximity to it.

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.

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