Comment

Representation ID: 15761

Received: 11/05/2016

Respondent: Essex County Council

Acknowledged that the Draft Local Plan is an emerging document and that on-going commissioning and publication of evidence base is necessary to inform the next iteration of the Plan. The Council will need to be satisfied that the Local Plan is supported by a proportionate evidence base and that all reasonable alternatives have been considered. As part of `duty to cooperate' ECC would seek further clarification needed on a number of issues with the Spatial Strategy:
- How the A127 corridor provides more opportunities for growth than the A12 corridor;
- Identification of any cross border implications of the spatial strategy given its role as highway, education, minerals and waste authority; and
- Identification of what infrastructure is necessary to deliver the spatial strategy, strategic and individual site allocations.

Comment

Representation ID: 15780

Received: 11/05/2016

Respondent: Essex County Council

Brentwood Council will need to be satisfied that it has identified its preferred spatial strategy, which includes significant Green Belt release, based on a range of proportionate evidence. In so doing, BBC will need to be able to demonstrate that it has considered all reasonable locations for future growth against the criteria outlined in Policy 9.8 Green Belt, and demonstrate the most appropriate sites have been identified for allocation.

Comment

Representation ID: 15840

Received: 11/05/2016

Respondent: Sammi Developments Ltd

Agent: Phase 2 Planning and Development Ltd

The Plan overly relies on its allocations in the A127 corridor, which are not the most sustainable locations for growth, given that transport links, access to jobs and services and town centre facilities are more limited.

Comment

Representation ID: 15904

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

It is positive that the Council will release Green Belt land (albeit "limited") for development within transport corridors, in strategic locations and urban extensions. However, there are further areas that should be considered for release from the Green Belt to allow a flexible approach for expansion greater than that, which has already been considered in the Council's OAN projection.

Object

Representation ID: 15929

Received: 12/05/2016

Respondent: West Horndon Parish Council

5.20 of the Draft Local Plan states that "Significant improvements to infrastructure and services will be required to support growth within the A127 Corridor". SO13 states that BBC will "secure the delivery of essential infrastructure, including transportation schemes and community facilities in order to support new development growth throughout its delivery". However
WHPC note that there is no detail as to what this would entail, how it would be paid for and how it would be delivered. Given the high concentration of proposed development, this is an area which requires far greater
evidence than that provided.

Support

Representation ID: 15934

Received: 12/05/2016

Respondent: CALA Homes

Agent: JB Planning Associates Ltd.

Support the Council's strategy to focus growth in the A12 corridor, which contains the Borough's main settlements.

Object

Representation ID: 15938

Received: 12/05/2016

Respondent: West Horndon Parish Council

Para 87 of the National Planning Policy Framework ("NPPF") states that "inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in special circumstances." WHPC state that housing need alone does not necessarily represent special circumstances.

Object

Representation ID: 15939

Received: 12/05/2016

Respondent: West Horndon Parish Council

5.22 in the Draft Local Plan notes that loss of just 1% of Green Belt "means development needs can be sustainably met in the Borough whilst Green Belt would still make up 88% of the total area". WHPC challenge that a small loss of Green Belt implies that development needs can be met sustainably - there are far greater elements of sustainability than simply considering what proportion of Green Belt is lost. WHPC also note that whilst the Borough as a whole would lose only 1% of its Green Belt, the local impact on West Horndon Parish and indeed the south of the Borough is far more material.

Comment

Representation ID: 15958

Received: 12/05/2016

Respondent: Collins & Coward Ltd

Agent: Collins Coward

The Council is simply focusing development in the south of the Borough and not taking a balanced view of housing provision across the Borough. The Council should consider channelling development to large villages such as Blackmore.

Support

Representation ID: 15964

Received: 13/05/2016

Respondent: St Modwen Properties PLC

Number of people: 2

Agent: Strutt & Parker LLP

The focus of larger scale development on key transport corridors is supported. Sites in strategic locations such as the Brentwood Enterprise Park at Junction 29 of the M25 are particularly well suited to meeting needs of new development within the Borough during the plan period whilst minimising negative environmental or amenity mpacts in line with the Council's policies and those set out within the NPPF.

Comment

Representation ID: 15982

Received: 11/05/2016

Respondent: Essex County Council

National infrastructure projects of relevance have been realised in the Governments Road Building Strategy which includes commitments to the A12, which seek to improve its long term reliability and capacity.
Other national infrastructure projects of relevance include the Lower Thames Crossing following which a range of potential Implications / Opportunities need to be assessed and factored in to the further modelling in support of the Brentwood Local Plan, regardless of the LTC route. In respect of modelling Highways England, acknowledge within their consultation that further modelling is required, and this is strongly supported by ECC.
ECC strongly agrees with the proposal for a new Crossing at Location C, east of Gravesend and Tilbury.

Comment

Representation ID: 15983

Received: 11/05/2016

Respondent: Essex County Council

Specific reference should be made to the "A127 A Corridor for Growth: an Economic Plan" (2014), which recognises the importance of the A127 to support economic growth both within Brentwood and as a strategic corridor for South Essex, and proposes a range of improvements including the safeguarding of the A127 corridor.
A major aim of ECC is to improve journey time reliability along this route. There is significant growth planned along the A127 Corridor in adopted and emerging Local Development Plans along its entire route, which will need to be considered in any highway modelling in terms of capacity, key junctions and access from direct and access to side roads, if necessary.

Comment

Representation ID: 15984

Received: 11/05/2016

Respondent: Essex County Council

Proposed Amendment to Policy 5.1, criterion b - ECC supports reference to development having no significant impact on transport, but this should be widened to refer to impact on:

`....transport (highway safety, capacity and congestion)'

Comment

Representation ID: 16023

Received: 13/05/2016

Respondent: Countryside Properties

Agent: Phase 2 Planning and Development Ltd

The Plan overly relies on its Dunton allocation in the A127 corridor, which is not the most sustainable locations for growth, given that transport links, access to jobs and services and town centre facilities are more limited. Brentwood, Hutton and Shenfield are sequentially preferable locations, the Council should recognise this in the policy and examine whether there are any additional sites in the Brentwood/ Shenfield/ Hutton area that could be brought forward.

Object

Representation ID: 16029

Received: 13/05/2016

Respondent: Countryside Properties

Agent: Phase 2 Planning and Development Ltd

The Council should take account of previous under-delivery in identifying sufficient sites to meet housing requirements and also a 20% buffer in accordance with the NPPF.

The significant housing allocations at Dunton Hill Garden Village and West Horndon will contribute to the Basildon's housing market area to a greater extent than the Brentwood housing market area due to the location of these sites relative to the main urban areas. Sites on the edge of Brentwood and Shenfield can make a greater contribution towards meeting local need for housing within the Brentwood housing market area.

Additional sites on the periphery of the principal urban area of Brentwood and Shenfield should be allocated.

Object

Representation ID: 16033

Received: 13/05/2016

Respondent: Elizabeth Finn Care

Agent: Strutt & Parker LLP

The Brentwood Local Plan should seek to deliver a greater number of new homes than the DLP proposes. However, we would question the deliverability of even the reduced quantum based on the strategy currently proposed by the DLP. Of particular concern is the reliance placed on Dunton Hills Garden Village and on windfall to help meet housing needs.

Support

Representation ID: 16070

Received: 13/05/2016

Respondent: Martin Grant Homes

Agent: Pegasus Group

Martin Grant Homes fully support growth within the A12 corridor.

Object

Representation ID: 16083

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representations made in 2013 include an SA of the land to the east of West Horndon out by consultants on behalf of Countryside Properties to address the absence of such assessment by the Council. This considers the issues of transport and access, landscape and design, and delivery and viability. Appendix 1 to the 2013 representations comprises a report by Rummey Design that explores a landscape-led urban extension to West Horndon.
Representations submitted in 2015 provided further justification for growth at West Horndon and include a critique of other strategic growth options being considered by the Council, such as Dunton. The appendices to the 2015 representations include comprehensive assessment of a number of issues including transport, landscape and Green Belt Assessment, archaeology and ecology, to demonstrate that there are no overriding constraints to strategic growth at West Horndon.

Object

Representation ID: 16087

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

West Horndon as a settlement capable of absorbing significant growth, has been strongly supported in the emerging Local Plan for Brentwood. A significant amount of growth can be focused on the settlement because it is relatively unconstrained by landscape and visual effects, and offers opportunities to mitigate the impacts of development by integrating them into the existing landscape. Green Belt releases are inevitable in the Borough in order to meet OAHN. In a Borough where 89% lies within the Green Belt, land at West Horndon, that has been the subject of years of intensive farming, represents one of the least attractive and lowest amenity parts of the Green Belt that could be released to meet housing and employment needs.

Comment

Representation ID: 16094

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

We do not consider the Council has fully assessed the impact on the Green Belt by absence of an independent and objective assessment, nor has the Council assessed the feasibility of the strategic sites put forward in their ability to be delivered in the plan period. Furthermore, the sustainability of settlements with underutilised public transport services should have been assessed. In this regard the policy is not justified or consistent with national policy.

Object

Representation ID: 16101

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

As referenced at paragraph 5.20, we do not consider the Dunton Hills garden Village Suburb would achieve the Council's Spatial Strategy in that the plan lacks evidence confirming the timescales for key developments through infrastructure delivery and lack confirmation from relevant stakeholders that the delivery can be accomplished. We therefore consider the policy is not effective on cross-boundary strategic priorities.

Support

Representation ID: 16152

Received: 16/05/2016

Respondent: Crest Nicholson

Agent: Bidwells

Support the policy insofar as it relates to the following:
- Brentwood and Shenfield being the focus for new development within the A12 corridor;
- Proposals to allocate land within and on the edge of the Brentwood Urban Area to assist with achieving a five-year supply of housing; and
- That the Plan proposes to meet the Borough's objectively assessed need in full.

Object

Representation ID: 16158

Received: 16/05/2016

Respondent: Joy Fook Restaurant

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: 16179

Received: 16/05/2016

Respondent: Anderson Group

Agent: Bidwells

Object. The spatial strategy relates specifically the following: - Arbitrary blanket restraint to growth in the villages including Blackmore - The totality of development proposed in the Dunton Hills Garden Suburb.

The Draft Plan's supporting material provides no evidence to support its stance that rural growth restraint would retain local character. The Landscape Character Assessment makes no such assertion that development would be detrimental in the rural area around Blackmore. The Retail and Commercial Leisure Study identifies the range of shops and facilities in Blackmore Village Centre as "providing an in-demand service" the Draft Plan acknowledges the role of the village local centres such as Blackmore as playing a "vital role in providing day to day services". But the Draft Plan's blanket restriction on growth assumes that such development would have negative consequences without evidence to back up the assertion.

Object

Representation ID: 16180

Received: 16/05/2016

Respondent: Anderson Group

Agent: Bidwells

All of the available evidence points to the acceptability of rural housing in line with national policy and practice guidance. But the Plan disregards all of this in favour of a strategy proposing rural restraint which is not led by any evidence. This approach is likely to have serious unintended negative consequences for wider sustainability objectives in the rural but this goes unappreciated by the Draft Local Plan because it has not been drafted with an understanding of such issues. The proposed policy of rural restraint is therefore unsound because it is not consistent with national policy, not based on adequate evidence and is unjustified, contrary to paragraph 183 of the Framework.

Object

Representation ID: 16185

Received: 16/05/2016

Respondent: Mr Hugh Thomson

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: 16200

Received: 16/05/2016

Respondent: South Essex Partnership University NHS Trust

Agent: Bidwells

Support policy 5.1 insofar as it relates to: - Brentwood and Shenfield being the focus for new development within the A12 corridor; - The use of a sequential approach to land uses which proposes the release of brownfield sites adjoining
existing urban areas above the release of greenfield sites; - The proposed allocation of sites on the edge of the existing Brentwood Urban Area in order to ensure
certainty of delivery; and - The proposal to meet the Borough's objectively assessed need in full.

Object

Representation ID: 16282

Received: 18/05/2016

Respondent: Margaret Noonan

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

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

Object

Representation ID: 16289

Received: 18/05/2016

Respondent: Dunton Community Association

Agent: Dunton Community Association

Object the claim that the A127 corridor provides growth opportunities that are not possible in the A12 corridor.

Comment

Representation ID: 16323

Received: 18/05/2016

Respondent: Ingatestone and Fryerning Parish Council

Agent: Ingatestone and Fryerning Parish Council

Sitting of new development in the Ingatestone area will place strain on medical, education, sewage disposal and parking all of which is currently under pressure.
We also concern the potential increase in traffic at the Mountnessing roundabout junction. The problem is of access to the proposed commercial site adjacent to the A12, its slip road and the B1002