I do not know the areas of West Horndon and Dunton Hills so cannot comment on there.
Of the other proposed sites, I would suggest that only Warley Training Centre, the Council Depot and Ingatestone Garden Centre are acceptable. All of the other sites would result in traffic congestion. Many roads in the borough are already clogged with traffic.

Why build more homes? The more you build the more it encourages people to move into the borough. Our essential services such as doctors are already "stretched"

It is proposed to reduce the fire service. More homes would put added pressure on a reduced fire service.

See attached.

1. The pollution from vehicle around the junction of Priests Lane and Middleton Hall Lane which already exceeds EU guidelines will only be made worse by the addition of these dwellings.

2. There will be a loss of open land wildlife habitat as a result of the development of these plots.

3. Using the already narrow Priests Lane which is used by large numbers of school children raises safety issues as the result of further developments.

4. The general environment will suffer during building work as well as after completion.

Generally, I am also concerned about the number of additional dwellings detailed in the plan which are proposed for the Town Centre. These will add considerably to congestion and will make Brentwood a less pleasant place to use.

See attached.

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See attached.

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

These are my comments to the Draft Council Planning document.

* Use of Car Parks to develop

My main concern is that it would appear wherever there is a council owned car park, it is proposed to convert these into dwellings. This includes the car parks in Westbury Road, Chatham Way and William Hunter Way.

Where are the current users of these car parks to park? There is nowhere near the centre of Brentwood for people to park. This reduces significantly the attraction for visitors and shoppers and workers.

The Brentwood Council car park should also be included in these plans. If you are to build on most car parks, why not build on the main council car park too.

* Use of existing empty shop units

There are a number of empty shopping units in Brentwood. I counted over 20 empty and there is a very high percentage of empty units in the BayTree centre.
These units should be considered first before building new units to supply the niche shopping towards the vision.

* Cycle Paths

Brentwood still does not have a dedicated cycle route or markings along the main route towards London. If you are to encourage cycling and reduce the vehicle road use, you need to have purpose built paths and markings.
There are road markings and dedicated cycle paths from the M25 into central London. The paths/markings stop abruptly at the M25 towards Brentwood.

* Westbury Road Car Park and St Charles Napier Pub Land

I note that there are dwellings planned for Westbury Road car park. The surrounding Victorian houses have been affected by flooding in the past. This needs to be considered when building new properties.
What is to happen to the land where the St Charles Napier Pub once stood. This is unsightly and needs developing.

* Cinema

The best place to build a cinema complex for Brentwood is at the Brentwood Leisure Centre. There is already ample parking there. This would avoid building at the William Hunter Way car park. So the town centre would avoid the vehicle traffic from cinema goers.

1. It would appear that the Council has allocated a number of its Car parks, as land suitable for building dwellings. This includes the car parks in Westbury Road, Chatham Way and William Hunter Way. This creates two problems:
a) In fill like this does not provide an attractive environment - either for the new residents or existing residents.
b) There does not seem to be clear provision of new/alternative car parking to replace the lost spaces. Where are visitors/shoppers supposed to park? Where do workers park, long-stay? Its difficult enough now.
2. Section 8 discusses that the town apparently requires more retail units and section 5.74 states that the existing vacant units are not sufficient to provide for the requirement.
There are currently at least 20 empty units in the High Street, Bay Tree Centre, Kings Road and Chapel Ruins area. Why can these not be filled first? Can these be adapted for use by retailers, with their advance agreement, so that shopping in Brentwood is an attractive proposition.
3. The consultation for the semi-pedestrianisation of the High Street was largely ignored by the Council, who appeared determined to press ahead regardless of public opinion. The subsequent decision to re-surface the High Street has been an expensive disaster. The road needs extensive, expensive repairs and although its appearance is pleasing, it was not necessary. Please do not make the same mistake of ignoring public opinion.
4. Regarding a cinema - something that has been promised for the last 15+ years. I still don't understand why this cannot be at the Brentwood Sports and Leisure Centre where there is the space for a new building, and the parking that would be needed. I have been told that one concern is "already congested roads" but I don't agree that the roads are congested towards the Brentwood Centre. In fact, if the cinema were built in William Hunter Way, the increased traffic in William Hunter Way, Western Avenue and Weald Road, including the crossroads junctions with the High Street would be worse.
5. What is happening with the space that has been boarded up since the demolition of the Grade 11 listed building that was the Sir Charles Napier pub? It is very ugly at the moment, and a waste of development space that is sorely needed.


* Brentwood needs some open spaces and to retain its Victorian market town feel. The little "green area" in Kings Road makes such a difference and more like this would be very welcome.
* I was told a few years ago that there was a waiting list for long-term parking annual permits: a friend asked to park on my drive because he couldn't park in Brentwood while he worked. Also, I know one retailer who received £3,000 worth of parking fines for parking his work van at the back of his shop, because he could no longer get a parking permit for a local car park. He has since closed the shop in Brentwood High Street.
* The Council removed the small free parking bay at the end of the High Street, which allowed for 30 minutes of shopping - very appropriate for the types of shops directly next to this bay. A number of these have now shut - the shoe repairers, the florist, the fruit and veg shop etc which were independent shops. The Council claims to encourage these in section 8.37.
* Brentwood is too expensive and not an attractive enough shopping area with its difficult-to-find and very expensive when-you-do-find-it parking. If I needed to drive to shops, I would drive to Upminster which has lovely shops, a choice of supermarkets and cheap, available parking. Or, I would drive further afield for a much wider choice of niche shops, for example to Tunbridge Wells, or Cambridge.
* I haven't counted the empty units apart from in Central Brentwood (Warley Hill, for example). Why can these not be filled before considering building others? S. 8.37 refers to Brentwood Town Centre attracting many visitors for a variety of reasons including a high quality shopping environment. The current empty units are unattractive, and the choices of retailers who have recently taken some of the larger spaces are not conducive to an interesting and up-market shopping experience. And if, as per s. 8.56 the Council "seeks to retain existing large retail units as they can be a major driver of footfall" why did it allow The Dairyman and Wildwood to take the larger retail sites when they became vacant?
* Re. resurfacing the High street : Not only did this close the High Street for nearly a year causing major sales problems for many retailers, but it also means that you cannot cycle in the High Street, and nor can there be the annual Cycle Race that used to occur.
* Re. the Cinema: I have been told that one concern is "already congested roads" but I don't agree that the roads are congested towards the Brentwood Centre. In fact, if the cinema were built in William Hunter Way, the increased traffic in William Hunter Way, Western Avenue and Weald Road, including the crossroads junctions with the High Street would be worse.

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.

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

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

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

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

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

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

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

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

7. How do you define "character"?

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

8. Assessment of GB Site

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

14. Primary school places in the Borough

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

15. Housing Trajectory

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

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

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

16. Travel by non-car modes

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

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

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