Comment

Representation ID: 14658

Received: 20/04/2016

Respondent: Hermes Fund Managers Limited

Agent: McGough Planning Consultants

Para 5.20 - Whilst there is still some doubt about the deliverability of Dunton Hills Garden Village, the reference to "brownfield opportunities" is welcomed. However, it is unclear what the local plan's amended focus is given the emphasise that housing delivery on these sites will be taken to effectively meet local needs. Our client is concerned that this may be used to stymie the redevelopment of the Horndon Estate and request further information in the context of the capacity of the sites to deliver new homes.
Our client welcomes the reference to "a residential led mixed use redevelopment of existing industrial land in West Horndon, creating a new village centre with supporting services and facilities close to the village rail station".

Comment

Representation ID: 14710

Received: 21/04/2016

Respondent: Mr Brian Worth

Once Crossrail arrives at Brentwood and Shenfield stations, it will act as a magnet to people, so they will be looking for housing in the A12 corridor. In addition, the A12 is being expanded to 3 lanes. It makes sense that these areas are where the development should be.

Crossrail is already being built, which eliminates a large slice of infrastructure cost associated with the new development.

It makes sense to direct this investment to into new development that will benefit the most people. Given that most people will be looking to live near Brentwood and Shenfield for the above reasons, this is where the new development and infrastructure spending should take place.

Support

Representation ID: 14965

Received: 26/04/2016

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

General support given. The development or redevelopment of land in existing urban areas should always be prioritised over development of brownfield or greenfield sites in the Green Belt Support is given to the hierarchical approach taken in determining where sustainable growth will be best accommodated, and in particular the main focus being the Urban Area of Brentwood, including Shenfield, where new development will be best served by public transport, retail, employment areas, health and leisure facilities and schools. The Brentwood Urban Area offers the most scope to deliver development in accordance with sustainable development principles.

Object

Representation ID: 15040

Received: 27/04/2016

Respondent: Lisa Atkinson

Sustainable development in the West Horndon area should be limited to less than 500 new homes, these would still need infrastructure expenditure. Redevelopment of West Horndon industrial estates would reduce the HGV traffic. However, it would still double the homes in West Horndon. 500 or more additional cars would also have an impact.

Support

Representation ID: 15142

Received: 28/04/2016

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Commend the approach taken by the Council in the staged preparation of the DLP, with a proportionate evidence base, extensive public consultation over an appropriate period of time and the modification of the spatial strategy and related policies in the light of that evidence and opinion.

Support

Representation ID: 15186

Received: 29/04/2016

Respondent: Punch Taverns

Agent: Plainview Planning

Strongly support the principle of focusing new development on land within the Borough's transport corridors, especially at Brentwood and Shenfield.

Support the release of Green Belt sites for development within the transport corridors, provided that:
- they have clear defensible physical boundaries to avoid further sprawl; and
- they are accessible to public transport, services and facilities; and
- they would have no significant impact on the Green Belt, visual amenity, heritage, transport and environmental quality including landscape, wildlife, flood-risk, air and water pollution; and
- they are deliverable over the plan period.

Support

Representation ID: 15212

Received: 03/05/2016

Respondent: Spire Hartswood Hospital

Agent: Turley

Welcomes the recognition within Policy 5.1 of the importance that the Borough's
transport corridors can play in providing sustainable, well connected locations for additional development within the Borough. In doing so the Policy acknowledges that there will be limited release of Green Belt land for development within these corridors.

Object

Representation ID: 15226

Received: 03/05/2016

Respondent: Billericay Action Group

Billericay Action Group objects to Brentwood Borough Council meeting its Objectively Assessed Need (OAN). The Council is not obliged to remove any land from Green Belt, and the Appendix is included to reinforce that point. Brentwood can build around 2500 homes without Green Belt loss and this is the
minimum Brentwood are obliged to build. This is far more than the borough's local needs (Natural Change\Growth) of 1200-1560 homes over the Plan period, so if the AN is met a large majority of homes would be for incomers.
We would prefer Brentwood to use Green Belt as a constraint to meeting OAN and so produce a sub-OAN Housing target of 2500.
Meeting the OAN effects SE Essex in a number of undesirable ways, including the unnecessary creation of Dunton Garden Suburb on the edge of Basildon. (Detailed appendix attached).

Comment

Representation ID: 15227

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Support the spatial strategy in general and recommend Site at Sawyers Hall Lane is allocated as it meets the requirements of Policy 5.1, being located in the A12 Corridor and the demonstrating characteristics which are necessary to justify Green Belt release for housing.

Recommended that due to Crossrail, strategic infrastructure investment, that deliverable and suitable potential housing sites around Brentwood town are identified for development in the Local Plan e.g. Sawyers Hall Lane. It must be noted that the effect of Crossrail enhances the Site at Sawyers Hall Lane's credentials as an accessible location and suitable site for growth.

Comment

Representation ID: 15240

Received: 03/05/2016

Respondent: Natural England

We have also looked at, and are generally supportive of, the Strategic Objectives, Spatial Strategy, General Development Criteria, and the various policies covering the environment, Green Infrastructure, air quality, lighting, flood risk and Sustainable Urban Drainage.

Comment

Representation ID: 15333

Received: 05/05/2016

Respondent: Ford Motor Company

Agent: Iceni Projects Limited

On review of the Green Belt boundary Ford are aware of the challenge facing Brentwood BC with regards to allocating land for development - it is apparent that there is considerable pressure on the Green Belt to accommodate such growth. In addition, the Draft Local Plan identifies the requirement to identify land for a further 5,000 new jobs over the plan period, increasing the pressure on Brentwood BC to identify land for development. The need for Brentwood BC to identify additional land for housing and employment is also required in order to address cross-boundary pressures such as London's future growth.
Ford believe that the arrival of Crossrail will also result in an increase in people both living and working in the Borough - therefore placing further pressure on land for development.

Support

Representation ID: 15343

Received: 05/05/2016

Respondent: Countryside Properties

Agent: Colliers International

Policy adopts an approach which seeks to meet local needs. We consider that the proposed limited release of Green Belt for development within transport corridors, strategic locations and urban extensions provides the optimal solution for achieving the development needs of the Borough. In particular, focusing development along the A12 corridor to the main Towns of Brentwood and Shenfield is considered the most sustainable approach to delivering growth in this area, particularly in light of the introduction of Crossrail to these areas in 2017.

Object

Representation ID: 15358

Received: 06/05/2016

Respondent: Maylands Green Estate Co. Ltd

Agent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Object

Representation ID: 15378

Received: 06/05/2016

Respondent: Robert Mulholland & Co Ltd

Agent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Object

Representation ID: 15399

Received: 06/05/2016

Respondent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Object

Representation ID: 15463

Received: 09/05/2016

Respondent: Mr Martin Morecroft

Agent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Object

Representation ID: 15483

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Comment

Representation ID: 15505

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support the approach contained in Policy 5.1 for development to be focused in the 'A12 Corridor', which includes Brentwood and Shenfield.

The growth strategy for the Borough should include a proportion of development within each of the broad areas, namely the 'A12 Corridor', 'A127 Corridor', 'Rural North' and the 'Rural South', in line with the sustainability credentials of each of the settlements, informed by evidence base documents and strategic priorities for the Borough.

Support

Representation ID: 15510

Received: 10/05/2016

Respondent: Environment Agency

We are pleased that this policy ensures development sites will be identified having regard to environmental quality, including wildlife, flood risk, and air and water pollution.

Comment

Representation ID: 15545

Received: 24/03/2016

Respondent: Greater London Authority

The Mayor welcomes the Council's corridor-based approach and the consideration of transport implications beyond its boundaries. The arrival of the Elizabeth Line in 2019 at Brentwood and Shenfield will improve the existing metro service and connectivity to Stratford as well as Central London, although the potential longer-term capacity is still under consideration. Within this context, the Councils may wish to look at growth options close to these train stations and their catchment areas. The Mayor also supports the principle of improvements to the Greater Eastern Mainline between London and Norwich through Brentwood and would welcome policy support for it.

Object

Representation ID: 15546

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The policy test of "no significant impact" on the aspects listed does not comply with National policy. Notably:

For Green Belt: The NPPF directs that Green Belt boundaries should only be altered in "exceptional circumstances". To require "no significant impact" on the Green Belt is therefore considered over prescriptive and beyond the wording of the NPPF. It is considered appropriate that reference is made to the 5 Green Belt purposes.

For visual amenity/environmental quality - Unless the NPPF directs that development should be restricted, for both plan-making and decision-taking, development should be positively sought unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies of the Framework taken as a whole.

For Transport - The NPPF states that development should only be prevented or refused whether the residual cumulative impact of development are severe.

For Heritage -The test to be considered in the NPPF is whether such development would lead to
substantial harm to/total loss of a heritage asset's significance, or less than substantial harm.

Support

Representation ID: 15547

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Support the identified of Shenfield and Brentwood as Category 1 settlements, and thereby under Policy 5.1, are the focus for development.

Support

Representation ID: 15557

Received: 18/03/2016

Respondent: Epping Forest District Council

Support Brentwood Borough Council's spatial strategy which concentrates new housing and employment development in the A12 and A127 corridors; and allows for limited release of Green Belt for development, and limited development, including infilling, within rural villages;

Object

Representation ID: 15561

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Object

Representation ID: 15581

Received: 10/05/2016

Respondent: Castle Point Borough Council

In terms of objectively assessed housing need, whilst a plan that will meet its needs is supported, there are concerns regarding the appropriateness of the locations of the strategic housing sites selected, for the reasons set out below. A significant proportion of the new housing sites are planned for locations outside the current urban areas of the borough. It is a laudable aim of the Plan is to protect the character of the suburban areas and villages; however, by directing new developments outside of these areas it is likely to give rise to issues concerned with sustainability. Travel and transport become significant issues, and there are no proposals within the plan for significant improvements in transport capacity to support dispersed growth, which in turn could have implications for the accessibility of neighbouring areas.

Object

Representation ID: 15607

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

Support

Representation ID: 15692

Received: 10/05/2016

Respondent: S & J Padfield and Partners

Agent: Strutt & Parker LLP

The focus of larger scale development on key transport corridors is supported. The allocation of employment land in strategic locations such as the Brentwood Enterprise Park and the land at Codham North at Junction 29 of the M25 are particularly well suited to meeting needs whilst minimise negative environmental or amenity impacts in line with the Council's policies and those set out within the NPPF.

Comment

Representation ID: 15754

Received: 11/05/2016

Respondent: National Highways

It is noted that some development sites are located in close proximity to the M25 and A12 corridors and therefore consider that these could potentially have a notable impact on the number of trips at the junctions. It is considered that the proposed development locations could have a notable impact on the Strategic Road Network, particularly on M25 Junction 28 and Junction 29, as well as A12 Junction 12. The flow diagrams provided within the Local Plan appendices demonstrate that approximately 500 and 1,200 additional vehicles per hour could route via Junction 28 and 29 respectively as a result of LP development. Furthermore, there is predicted to be a material impact at A12 Junction 12, although the flow diagrams were not clear enough to calculate an accurate total.

Support

Representation ID: 15755

Received: 11/05/2016

Respondent: Persimmon Homes Essex

Support the approach to focus development around the main transport corridors as this offers the most sustainable locations in terms of settlement size and existing service and facilities to support new growth.

Comment

Representation ID: 15756

Received: 11/05/2016

Respondent: National Highways

As some notable development is located in close proximity to the A12, we would like Brentwood Borough Council to be mindful of the Road Investment Strategy (RIS) proposals announced and the potential for the widening of the A12, as well as strategic re-routing that could potentially occur as a result of large schemes in the RIS such as the Lower Thames Crossing, which was recently out to consultation. Additionally cross-border impacts will need to be considered from adjacent local authorities' local plans, including how these impacts will be mitigated. I would also draw your attention to the potential for noise and air quality problems and recommend suitable consideration is given to ensure new occupants are not adversely affected.