Policy 5.1: Spatial Strategy
Object
Draft Local Plan
Representation ID: 14284
Received: 06/04/2016
Respondent: Mr Ian Blackburn
* Transport
The ability of existing transport corridors to accommodate growth needs careful and transparent examination rather than just being stated. Whether they can absorb focused growth any better than local roads could accommodate a more dispersed growth in traffic or need for other infrastructure is unsupported.
The A127 and A128 are extremely busy and at times over capacity with traffic delays at the junction with Station Road, East Horndon. Additional traffic on these roads generated by a large development could not be accommodated without road widening on the A127 and A128 and junction improvements. Whatever the situation this remains unsupported in the evidence base to the Plan.
The location of the Dunton Hills Garden Village is adjacent to the boundary with Thurrock and very dependent of the A128 for connections to the south, but there is no evidence of cooperation with Thurrock.
See attached.
Object
Draft Local Plan
Representation ID: 14285
Received: 11/04/2016
Respondent: J M Gillingham
* Competitiion to Brentwood Town Centre
Dunton Hill Garden Village would create a new urban centre which would divert use of facilities and reduce footfall in Brentwood and hence be detrimental to the economic sustainability of Brentwood Town Centre.
See attached.
Object
Draft Local Plan
Representation ID: 14286
Received: 06/04/2016
Respondent: Mr Ian Blackburn
* Competitiion to Brentwood Town Centre
Dunton Hill Garden Village would create a new urban centre which would divert use of facilities and reduce footfall in Brentwood and hence be detrimental to the economic sustainability of Brentwood Town Centre.
See attached.
Object
Draft Local Plan
Representation ID: 14287
Received: 06/04/2016
Respondent: Mr Ian Blackburn
* Preservation of the Green Belt:
The sitting of this proposed large allocation would be especially detrimental to the Green Belt. The A127 corridor where both the large allocations are being proposed (the A127/M25 junction together with the Dunton Hills Garden Village plus contiguous development in Basildon) would come close to being a developed/semi development wedge through London's Green Belt. The Plan talks about retaining infrastructure to create 'defensible boundaries' to development but in fact the greatest defensible boundary there is to sprawl is a continuous and substantial Green Belt- the very designation that would be eroded by the Plan.
See attached.
Object
Draft Local Plan
Representation ID: 14288
Received: 11/04/2016
Respondent: J M Gillingham
* Preservation of the Green Belt:
The sitting of this proposed large allocation would be especially detrimental to the Green Belt. The A127 corridor where both the large allocations are being proposed (the A127/M25 junction together with the Dunton Hills Garden Village plus contiguous development in Basildon) would come close to being a developed/semi development wedge through London's Green Belt. The Plan talks about retaining infrastructure to create 'defensible boundaries' to development but in fact the greatest defensible boundary there is to sprawl is a continuous and substantial Green Belt- the very designation that would be eroded by the Plan.
See attached.
Object
Draft Local Plan
Representation ID: 14290
Received: 11/04/2016
Respondent: J M Gillingham
* Preservation of the Green Belt:
The first reason is that I believe that effective preservation of the principle and character of the Green Belt should be foremost in thinking. This is supported in 5.21 where it is stated that growth in the rural north and south will be limited to retain their rural character. I believe that a very large allocation would have a far greater effect on the Green Belt than more dispersed developments and particularly if those many smaller releases of the Green Belt were contiguous with existing development.
See attached.
Object
Draft Local Plan
Representation ID: 14291
Received: 06/04/2016
Respondent: Mr Ian Blackburn
* Preservation of the Green Belt:
The first reason is that I believe that effective preservation of the principle and character of the Green Belt should be foremost in thinking. This is supported in 5.21 where it is stated that growth in the rural north and south will be limited to retain their rural character. I believe that a very large allocation would have a far greater effect on the Green Belt than more dispersed developments and particularly if those many smaller releases of the Green Belt were contiguous with existing development.
See attached.
Object
Draft Local Plan
Representation ID: 14292
Received: 06/04/2016
Respondent: Mr Ian Blackburn
The Spatial Strategy is dependent on two seriously flawed ideas that find expression in several places through the Plan (especially 7.6) and is therefore flawed itself:
A- The idea that eroding Green Belt by virtue of an urban development protects it. A well planned designed and executed development is better than one that is not but it doesn't contribute to the Green Belt purpose of restricting urban sprawl.
B- The idea that infrastructure routes such as the A12, A127, A128 and railway being defensible boundaries to unrestricted urban sprawl. One of the main purpose of the Plan is to decide where development will or will not be permitted to occur, therefore it is entirely in Brentwood Borough's gift as to how much land on the currently undeveloped site of a road or railway should be released. It is abundantly clear that roads, railway lines, etc are not inherent defenses.
See attached.
Object
Draft Local Plan
Representation ID: 14293
Received: 11/04/2016
Respondent: J M Gillingham
The Spatial Strategy is dependent on two seriously flawed ideas that find expression in several places through the Plan (especially 7.6) and is therefore flawed itself:
A- The idea that eroding Green Belt by virtue of an urban development protects it. A well planned designed and executed development is better than one that is not but it doesn't contribute to the Green Belt purpose of restricting urban sprawl.
B- The idea that infrastructure routes such as the A12, A127, A128 and railway being defensible boundaries to unrestricted urban sprawl. One of the main purpose of the Plan is to decide where development will or will not be permitted to occur, therefore it is entirely in Brentwood Borough's gift as to how much land on the currently undeveloped site of a road or railway should be released. It is abundantly clear that roads, railway lines, etc are not inherent defenses.
See attached.
Object
Draft Local Plan
Representation ID: 14327
Received: 14/04/2016
Respondent: Thurrock Borough Council
It is considered the role and development of Brentwood and in particular Shenfield as a terminus of Crossrail should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to considered with some weight as a way of meeting the undersupply of housing requirement currently identified in the Brentwood Local Plan options and supporting evidence.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14331
Received: 14/04/2016
Respondent: Thurrock Borough Council
A127 corridor. The Brentwood Plan and supporting evidence identifies the requirement for additional employment land. However it is unclear why the employment sites (Policy 8.2) are proposed in the draft local plan. It is not always the case that employment land should be located at busy junctions or along the A127 corridor where it would add to traffic flows on a road at current capacity. The sites are not located close to existing centres and are without easy access for workers other than by car. Alternative locations and options should be investigated including the A12 corridor possibly as part of edge of settlement expansion and in mixed use schemes.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14332
Received: 14/04/2016
Respondent: Thurrock Borough Council
Green Belt issues on the A127 corridor. The draft local plan document 2016 identifies there are several sites for development of brownfield land and Green Belt release along the A127. It is considered that brownfield redevelopment and a limited Green Belt release north of West Horndon as indicated by sites (referenced site 37) represented a suitable scale of housing development in this location. Thurrock Council remains concerned about the lack of detail on location, delivery and phasing of such a development. It is considered that if these issues are not properly addressed then the development may not be delivered and exacerbate the lack of housing provision within the Brentwood Local Plan. Thurrock Council requests that more detail is provided as to how such a release is to be achieved and incorporated into a more formal Green Belt review process and Local Plan consultation.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14333
Received: 14/04/2016
Respondent: Thurrock Borough Council
Large strategic Green Belt development such at Dunton Hill Garden Village or the Dunton Garden Suburb or at West Horndon or in combination will have significant harm to the openness and function of the Metropolitan Green Belt as it meets the purposes of the Green Belt including preventing urban sprawl and coalescence between Basildon and West Horndon in the east and from West Horndon westwards to Cranham and Upminster. Dunton Hill Garden Village would result in significant Green Belt release leaving limited gap between Basildon and West Horndon. The significant Basildon Local Plan West Basildon Urban extension with the Dunton Hill Garden Village would also result in potential coalescence and urbanisation of the A127 corridor. Further Green Belt releases including employment land (Brentwood Enterprise Park) at Junction 29 of the M25 with A127 taken together with a strategic release for housing at Dunton Hills Garden Village will also contribute to an even greater cumulative impact on the openness of the Green Belt in this broad corridor.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14334
Received: 14/04/2016
Respondent: Thurrock Borough Council
Further Green Belt releases including the previous proposal for land north of West Horndon and employment land (Brentwood Enterprise Park) at Junction 29 of the M25 with A127 taken together with a strategic release for housing at Dunton Hills Garden Village will also contribute to an even greater cumulative impact on the openness of the Green Belt in this broad corridor.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14341
Received: 14/04/2016
Respondent: Thurrock Borough Council
The A127 is at capacity and does not represent a better road transport alternative to the A12. Any larger development is going to require additional road infrastructure investment to improve access. There is limited public information currently available in order to consider highway capacity impacts at this stage.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14342
Received: 14/04/2016
Respondent: Thurrock Borough Council
The Government is currently giving further consideration to Options A and C for the future Lower Thames Crossing. This includes assessing three alternative routes for Option C. Any assessment of development proposals at Dunton Hill Garden Village or West Horndon will need to take account of the any decision on the Lower Thames crossing. The most northern and easterly route path for a route for option C depending on the location may have implications for development proposals in terms of land - take south of the A127 and west of the A128.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14349
Received: 14/04/2016
Respondent: Thurrock Borough Council
Thurrock Council suggests that the potential impact of large scale developments on the A127 Corridor is more significant than stated by Brentwood Council. The impact of development on the landscape depends on the size and scale of the development and the sensitivity of the landscape. It also depends on the level that any landscape character assessment is undertaken.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14350
Received: 14/04/2016
Respondent: Thurrock Borough Council
The A127 corridor sits within an important large fenland landscape character area, which extends across part of Brentwood, Havering and Thurrock authorities. The character assessments undertaken for Mid Essex including the Brentwood section do not reflect the importance of this open landscape. This fenland has been recognised by the Thames Chase Heritage Lottery Fund as a 'distinctive landscape character worth conservation' and has been identified by the CPRE as a nationally significant area of tranquillity in the metropolitan greenbelt.
The urban edges of Brentwood and Basildon are set back from the steeper slopes and screened with woodlands from views across the fenland. The settlements of Upminster and South Ockendon are identifiable in distant views to the east and south-east. There are built features within the open fenland character which do not significantly impact the value of the area but may lower the quality or condition of smaller local character area and field by field character assessments. It is highly likely from the outcomes of landscape capacity studies that any development greater than discreet infill plots would significantly harm the landscape character.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14351
Received: 14/04/2016
Respondent: Thurrock Borough Council
The Brentwood section of the Mid Essex Landscape Character Assessment does not assess different scales of development. Furthermore the Mid Essex Landscape Character Assessment Sep 2006: Chris Blandford Associates Section 4 Character of Brentwood Borough description of open views to the south of Horndon Fenland, suggest the negative influence of '"proximity of the area to a landscape which is more influenced by human activity around Thurrock and the Thames Gateway". This description does not properly reflect the character of the extensive fenland which is described in Thurrock Landscape Capacity: March 2005 Chris Blandford Associates as in having a " Rural character" and "Sense of tranquillity due to absence of major roads and built developed".
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Object
Draft Local Plan
Representation ID: 14352
Received: 14/04/2016
Respondent: Thurrock Borough Council
West Horndon Village retains a rural settlement character in the open landscape despite the relatively modern style of residential buildings and rural-urban fringe clutter that is disproportionate to the scale of the settlement. The east of the village, particularly the north- east, has a more intact and important rural landscape character. The larger fenland landscape character area would be affected by any further development. It is considered that development of the scale of the Dunton Hill Garden Village or Garden Suburb or an extension east of West Horndon will significantly harm the open rural character of the broad fenland and the setting of rolling farmland and wooded hills of Thurrock.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
Support
Draft Local Plan
Representation ID: 14360
Received: 15/04/2016
Respondent: Mrs Sandra Keeble
I agree with the proposed LDP that the major development should occur in the A12, A127 corridor. Dunton Village provides an ideal site for major development where infrastructure can be built into the project to suit the increased population. The rural north should not have any major development although individual "infill" homes should be built for local young key workersused to living in a rural situation.
See attached.
Support
Draft Local Plan
Representation ID: 14388
Received: 15/04/2016
Respondent: Mr Alan Shaw
Support proposals, sensible strategy. Proposal to develop in areas where transport systems and good roads are already in existance and able to handle extra housing is paramount, given that much of the rural ares are not well served with these facilities. Prioritising brownfield development is essentiala nd we would thoroughly support. As our borough is 89% green belt any area that has been developed befoe are now avilable for development must be an absolute priority.
See attached.
Support
Draft Local Plan
Representation ID: 14391
Received: 15/04/2016
Respondent: Mr Alan Shaw
Welcome that there are no intentions to vary the Green Belt boundaries surrounding our smaller villages. Will avoid the spread of our smaller villages which have so much character and which need protecting for the longer term. Special care should be made in conservation areas and with listed buildings if considering any developments.
See attached.
Comment
Draft Local Plan
Representation ID: 14439
Received: 18/04/2016
Respondent: Chelmsford City Council
CCC supports the proposed growth strategy and a Brentwood Local Plan which seeks to meet its own housing needs in full. CCC also supports the proposed housing and employment allocations which are unlikely to have any adverse cross-boundary impacts on Chelmsford. It is however unclear if this new option has been informed by a comprehensive Green Belt review. CCC looks forward to continuing to working constructively and continuously with Brentwood Borough Council on our respective Local Plans.
Thank you for consulting Chelmsford City Council (CCC) on the Brentwood Draft Local Plan consultation. CCC supports the proposed growth strategy and a Brentwood Local Plan which seeks to meet its own housing needs in full. CCC also supports the proposed housing and employment allocations which are unlikely to have any adverse cross-boundary impacts on Chelmsford. It is however unclear if this new option has been informed by a comprehensive Green Belt review. CCC looks forward to continuing to working constructively and continuously with Brentwood Borough Council on our respective Local Plans.
Object
Draft Local Plan
Representation ID: 14466
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
The reuse/recycling of brownfield sites in Green Belt is identified as sequentially preferable sites than strategic sites or greenfield sites in Green Belt, the Local Plan's Spatial Strategy under Policy 5.1 does not reflect this sequential approach to meeting local needs (for which no definition is given and appears to be contrary to the NPPF referring to 'local needs'relative to the housing needs in rural areas). We therefore consider that Policy 5.1 should be amended, which is also necessary in order to ensure the effectiveness of Policy 9.11.
See attached
Object
Draft Local Plan
Representation ID: 14544
Received: 19/04/2016
Respondent: Mr Richard Swift
Object to spatial strategy, villages in the north need growth, support a semi-dispersed model and incremental growth to enable sustainable communities. The borough has not considered the A414/M11 corridor which is to the north of Brentwood Borough.
See attached
Object
Draft Local Plan
Representation ID: 14567
Received: 19/04/2016
Respondent: Mr C Lonergan
Agent: Strutt & Parker LLP
Policy 5.1 could be suitable to deliver appropriate development within larger villages only if additional sites were allocated for housing in these locations within the local plan.
The current proposals, which limit development in otherwise suitable locations due to the current Green Belt boundaries, are considered to be too restrictive and inflexible to help meet the housing needs of the Borough and restrict the ability of larger villages to grow to meet their population requirements.
Land such as land at Salmonds Farm, Ingrave, [Site Ref. 067A & B], should be allocated as a suitable site fordevelopment, which is able to fulfil the policy expectations set out in Policy 5.1. In combination with the reliance on Windfall sites and the Dunton Garden Village, it is perverse that the Council has not allocated larger villages for a greater quantum of development where sites have been assessed as being suitable, available and achievable.
See attached
Support
Draft Local Plan
Representation ID: 14586
Received: 19/04/2016
Respondent: Childerditch Properties
Agent: Strutt & Parker LLP
The focus of new development on key transport corridors is supported. The proposed allocation of employment land at Childerditch Industrial Park and the adjoining Range are particularly well suited to assist, meet the needs for employment land and new jobs having regard to the requirements of Paragraph 21 of the NPPF, whilst minimising environmental or amenity impacts having regard to the information set out at 1) above in line with the Council's policies outlined at 5.17 of the Draft Local Plan and those set out within the NPPF.
See attached
Comment
Draft Local Plan
Representation ID: 14599
Received: 19/04/2016
Respondent: Mr Colin Foan
A127 capacity vs A12 corridor capacity
o Disagree that the capacity of both the rail and road are greater for the A127 corridor than the A12
o Much of the A12 is already 6 lane and there are plans in place to upgrade all the 4 lanes sections from the M25 to Marks Tey to 6 lanes.
o There are no 6 lane sections on the A127 and plans to upgrade it are only at a very early stage. This would need to be done before more development takes palace.
o The railway from Shenfield station into London as 4 tracks and is currently being upgraded by the Crossrail project.
o The C2C railway from Southend to London Fenchurch Street is only two tracks and expansion west of Upminster would be almost impossible because the tracks run through built/residential areas.
The A12 corridor already clearly has far more capacity than the A127 and plans to upgrade it even further far more advanced
1. I acknowledge the challenges the LDP needs to address and the difficulties Brentwood Borough Council faces to deliver all the requirements
* Strategic Housing allocation
o 360 new home per year from 2013
o This amounts to 5500 over a 15-year time frame or 7200 over 20 years
o Brentwood is 89% Green Belt
o Brentwood only has brown field locations for ~2500 houses
o Thus needs to find locations for some 3000 extra houses
o Inevitably some of these will have to be built on land that is currently classed as green belt
o Green belt loss must be kept to an absolute minimum
* Employments needs
* Retail sites
2. I total support for protection of the green belt, especially the area immediately next to the Village of West Horndon. Under no circumstances should this Green Belt be sacrificed to meet housing need. It would be creep and start to join the urban areas of Greater London with Basildon. It would also change the rural character of the existing village beyond recognition.
3. I accept development of the Brown Field Industrial estate but need to find appropriate solutions to the infrastructure issues this creates. These include:
o Safe acceptable road access onto the site - the current entrance is already a hazard. Changing the Industrial estate to mixed residential without a security gate to slow traffic would increase the hazard significantly
o Need to ensure development has SuDs in place
o Schools places
o Doctors/medical facilities
o Mixed development
* some of the more modern industrial units to remain
* Starter homes
* Family homes
* Homes for elderly/disabled residents
o Development that is compatible with the current village style not too dense, 30 homes per ha maximum if possible somewhat less
* Maximum housing density of 30 homes per ha (pro rata down if as probable some of the smaller industrial units remain)
4. I accept with great reluctance the concept that if Green Belt development has to take place as set out in the NPPF section 83, then it should be as separate discreet village developments and not wide spread small incremental additions. They must be big enough to be self-sustainable and generate sufficient CIL &106 money to provide appropriate infrastructure, but not so big as to become small towns. Only the absolute minimum amount of Green Belt should be reclassified in order to prevent further development at some time in the future.
* Dunton Garden Village
o Done properly this is possibly the least harmful option
o Accept the idea of achieving the required level of development by building new villages that are self-sustainable and developed in such a way as to deter further development creep
o Question the size at 2500 - the new West Horndon with the development of the industrial estate will be ~ 1100 to 1200 homes. DHGV should replicate that and not be much bigger, although I might accept slightly more if it could be proved that a larger number was absolutely necessary to generate the required infrastructure
o There needs to be an environmental barrier between DHGV and West Horndon so as to prevent the possibility of developmental creep in the future
o There are a lot infrastructure issues that need to be resolved these include:
* Road access
* Schools - junior & senior
* Medical facilities
* Access to the railway station
* A127 capacity
* C2C rail capacity
o If the DHGV option is progressed, then as per my comments in section 4 above only the absolute minimum of land necessary should be reclassified. In appendix 2 on page 185 site ref 200 is identified as being 237.49ha. This is vastly more land than is required for even the proposed 2500 houses. I strongly object to this whole area being reclassified as that would make further redevelopment and thus urban creep much easier to occur in the future
* A127 capacity vs A12 corridor capacity
o Disagree that the capacity of both the rail and road are greater for the A127 corridor than the A12
o Much of the A12 is already 6 lane and there are plans in place to upgrade all the 4 lanes sections from the M25 to Marks Tey to 6 lanes.
o There are no 6 lane sections on the A127 and plans to upgrade it are only at a very early stage. This would need to be done before more development takes palace.
o The railway from Shenfield station into London as 4 tracks and is currently being upgraded by the Crossrail project.
o The C2C railway from Southend to London Fenchurch Street is only two tracks and expansion west of Upminster would be almost impossible because the tracks run through built/residential areas.
The A12 corridor already clearly has far more capacity than the A127 and plans to upgrade it even further far more advanced.
* To prevent creep, the overriding priority must be to protect the green belt immediately around the village of West Horndon
* Any development that takes place must be preceded or at the very least accompanied by appropriate and necessary infrastructure. Under no circumstance should infrastructure come after development
* All developments must have appropriate levels of affordable housing. Where possible this should be prioritised for Brentwood residents.
* BBC will need to work out how to get/guarantee any rail infrastructure upgrades, these are not part of the same development plan and Network rail have a long history of delay and failure to implement necessary infrastructure improvements.
* I support the concept of the J29 Employment Cluster. It will be particularly good for employment that requires significant HGV activity.
o Need to ensure that there is sufficient public transport access to the site
Support
Draft Local Plan
Representation ID: 14656
Received: 20/04/2016
Respondent: Hermes Fund Managers Limited
Agent: McGough Planning Consultants
Support
See attached