See attached

Although I welcome the proposition of new, affordable housing, l am concerned with the concept of using the current central parking areas for development. Your plan is contradictory in that you aim to develop High Street retailing facilities through investment, but you do not evidence how you will attract consumers if there are no parking facilities. The park and walk scheme focuses on commuters, there appears to be no such facility for shoppers and consequentially the success of the High Street.

My other concern with a lack of parking facilities is the impact that this will have on the side roads, not only for residents, particularly as there is currently a paucity of 'policing' parking 'out of hours', but also the effects that inconsiderate parking has on road users leading to dangerous driving conditions and traffic congestion 'Hot Spots'.

I was pleased to be able to attend your presentation at the Ingatestone Community Centre on 22nd February. I have since been able to download the Draft Plan and read some parts of it. Overall it seems very comprehensive, well-reasoned and informative.
As a former local government housing officer for some 30+ years, I very much support the provision of more genuinely affordable housing for the Borough in general and Ingatestone in particular. The sites earmarked within Ingatestone seem to me to be good & appropriate options.
Of course the definition of "affordable" is somewhat contentious & at times Orwellian - i.e affordability = unaffordabilty. The Government seems to regard affordable as being something like 80% of market rents for the rented sector, although their whole housing policy now seems to lean overheavily towards owner-occupation with little regard for those that are unable or do not wish to buy. My view is that there is a definite need for more sub-market rented homes, provided by Housing Associations or dare I say it the local authority itself.
Obviously in an ideal world, every bit of open countryside would be protected (I say this as a keen rambler in the countryside & elsewhere), and places like Ingatestone Garden Centre (IGC) wouldn't be closing. But as IGC has closed down that seems to be an ideal site for genuinely affordable rented housing and/or low-cost owner-occupied dwellings - ideally affordable in perpetuity and perhaps with a reasonable priority for local people. I think somewhere like Ingatestone needs an increase in that type of provision. What it doesn't need is more footballers' mansions, or developments like that at Trueloves Lane (where, hilariously, the new homes were marketed as affordable with a price tag of some £1.5 million!). Without more affordable housing, where do people expect the next generation to live? Kids living with parents until they're about 50? Or moving to Scunthorpe (for example) just to find somewhere to live.
Reading a recent article in "Inside Housing" it was reported that just over 10% of England was currently used for housing. Nationally, to build some 2.5 million homes over the coming years would only take things up to around 12%. So I think we are some way short yet of concreting over the entire countryside, as some fear.
As you state in your report, any new development needs to be appropriate in scale and design for its location, have suitable infrastructure, protect Green Belt as much as possible, have suitable landscape buffers / definable boundaries etc (e.g. between Ingatestone & Mountnessing) and, where affordable housing is included with a scheme, to be well integrated (i.e. avoiding what has been referred to in the media as "poor doors"!).
On the question of affordable housing (Policy 7.5), I am aware that developers will at times seek to avoid any affordable quotas, instead making a payment for the Council / HA to develop elsewhere. I think this leads to less mixed communities and should be resisted as far as possible.
From some of the conversations I overheard at the meeting of 22nd February, I suspect a fair few local residents won't share most of my views, and will probably be in the "nimby" camp, of not building anything anywhere ever. I wonder how many of those objecting are living in developments which were themselves once open land and no doubt subject to similar objections a generation or two ago?
One thing I'd query - in Sections 7.20 /7.21 you refer to 17.1% of local households having someone with a disability / long-term illness, yet only 5% provision for such groups is proposed for new developments.
I remember at one time there was discussion of "lifetime homes" - developing new homes that could be easily adaptable for people in all stages of their life. But these are probably not popular with developers.
To finish on a parochial note, I'm wondering what the plans are for 24 Norton Road, Ingatestone - the former Children & Families Consultation Service offices - which have been empty and boarded up for some months now. I assume this site will be earmarked for housing?
Many thanks.
John Bright CIHCM

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

7. How do you define "character"?

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

8. Assessment of GB Site

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

14. Primary school places in the Borough

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

15. Housing Trajectory

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

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

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

16. Travel by non-car modes

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

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