Conversion of redundant or under utilised agricultural buildings should be permitted to minimise the requirement for new builds in the GB.
Ancillary buildings to facilitate the use of open space for sport and recreation should be permitted. ie. to play football one needs CHANGING FACILITIES and TOILET FACILITIES and a place to PARK. The council cannot provide football/Rugby/cricket fields without providing these vital ancillary buildings. By doing so the council will effectively be permitting unworkable facilities that are not fit for purpose.

Objection is made to the wording of the second paragraph of the policy "Proposals for small scale buildings and facilities required for outdoor sport and recreation will need to demonstrate a justifiable need for such buildings and facilities". This wording implies that the principle of small scale facilities required for outdoor/sport recreation needs to be justified because such proposals are considered inappropriate development in the Green Belt. However, as set out in paragraph 89 of the NPPF, appropriate facilities for outdoor sport should be regarded as an exception to the general approach to the construction of new buildings in the Green Belt and are therefore not inappropriate development. Consequently, justification for the principle of such uses should not be required. As an assessment needs to be made by the Council of whether such facilities are 'appropriate' it would be acceptable for a policy to require such proposals to demonstrate a need for the scale of the proposed building but not the principle as implied by the policy wording. It is therefore requested that this part of the policy be deleted or amended to refer to a "justifiable need for the scale for such buildings and facilities"

Absolutely no new development in the green belt

Policy 9.9 - Green Belt

Again, as per the above comment, we note that the Council wishes to encourage the beneficial use of the Green Belt to improve outdoor recreation, although no mention is made of rights of way or that the Council will be pro-active in enhancing the rights of way network - something that would be a beneficial use of the Green Belt.

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

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1. I acknowledge the challenges the LDP needs to address and the difficulties Brentwood Borough Council faces to deliver all the requirements
* Strategic Housing allocation
o 360 new home per year from 2013
o This amounts to 5500 over a 15-year time frame or 7200 over 20 years
o Brentwood is 89% Green Belt
o Brentwood only has brown field locations for ~2500 houses
o Thus needs to find locations for some 3000 extra houses
o Inevitably some of these will have to be built on land that is currently classed as green belt
o Green belt loss must be kept to an absolute minimum
* Employments needs
* Retail sites

2. I total support for protection of the green belt, especially the area immediately next to the Village of West Horndon. Under no circumstances should this Green Belt be sacrificed to meet housing need. It would be creep and start to join the urban areas of Greater London with Basildon. It would also change the rural character of the existing village beyond recognition.

3. I accept development of the Brown Field Industrial estate but need to find appropriate solutions to the infrastructure issues this creates. These include:
o Safe acceptable road access onto the site - the current entrance is already a hazard. Changing the Industrial estate to mixed residential without a security gate to slow traffic would increase the hazard significantly
o Need to ensure development has SuDs in place
o Schools places
o Doctors/medical facilities
o Mixed development
* some of the more modern industrial units to remain
* Starter homes
* Family homes
* Homes for elderly/disabled residents
o Development that is compatible with the current village style not too dense, 30 homes per ha maximum if possible somewhat less
* Maximum housing density of 30 homes per ha (pro rata down if as probable some of the smaller industrial units remain)

4. I accept with great reluctance the concept that if Green Belt development has to take place as set out in the NPPF section 83, then it should be as separate discreet village developments and not wide spread small incremental additions. They must be big enough to be self-sustainable and generate sufficient CIL &106 money to provide appropriate infrastructure, but not so big as to become small towns. Only the absolute minimum amount of Green Belt should be reclassified in order to prevent further development at some time in the future.

* Dunton Garden Village
o Done properly this is possibly the least harmful option
o Accept the idea of achieving the required level of development by building new villages that are self-sustainable and developed in such a way as to deter further development creep
o Question the size at 2500 - the new West Horndon with the development of the industrial estate will be ~ 1100 to 1200 homes. DHGV should replicate that and not be much bigger, although I might accept slightly more if it could be proved that a larger number was absolutely necessary to generate the required infrastructure
o There needs to be an environmental barrier between DHGV and West Horndon so as to prevent the possibility of developmental creep in the future
o There are a lot infrastructure issues that need to be resolved these include:
* Road access
* Schools - junior & senior
* Medical facilities
* Access to the railway station
* A127 capacity
* C2C rail capacity
o If the DHGV option is progressed, then as per my comments in section 4 above only the absolute minimum of land necessary should be reclassified. In appendix 2 on page 185 site ref 200 is identified as being 237.49ha. This is vastly more land than is required for even the proposed 2500 houses. I strongly object to this whole area being reclassified as that would make further redevelopment and thus urban creep much easier to occur in the future

* A127 capacity vs A12 corridor capacity
o Disagree that the capacity of both the rail and road are greater for the A127 corridor than the A12
o Much of the A12 is already 6 lane and there are plans in place to upgrade all the 4 lanes sections from the M25 to Marks Tey to 6 lanes.
o There are no 6 lane sections on the A127 and plans to upgrade it are only at a very early stage. This would need to be done before more development takes palace.
o The railway from Shenfield station into London as 4 tracks and is currently being upgraded by the Crossrail project.
o The C2C railway from Southend to London Fenchurch Street is only two tracks and expansion west of Upminster would be almost impossible because the tracks run through built/residential areas.
The A12 corridor already clearly has far more capacity than the A127 and plans to upgrade it even further far more advanced.

* To prevent creep, the overriding priority must be to protect the green belt immediately around the village of West Horndon
* Any development that takes place must be preceded or at the very least accompanied by appropriate and necessary infrastructure. Under no circumstance should infrastructure come after development

* All developments must have appropriate levels of affordable housing. Where possible this should be prioritised for Brentwood residents.

* BBC will need to work out how to get/guarantee any rail infrastructure upgrades, these are not part of the same development plan and Network rail have a long history of delay and failure to implement necessary infrastructure improvements.

* I support the concept of the J29 Employment Cluster. It will be particularly good for employment that requires significant HGV activity.
o Need to ensure that there is sufficient public transport access to the site

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