We live on the main road - not rural - between Billericay and had an infrequent bus service that doesn't even go to Shenfield. So we have to use a car for all of our transport.

Road access aand parking are dreadful

Regarding the draft plan for the building of numerous houses in the area I hope the larger picture is looked at before final decisions are made such as schools, doctors, car parking, transport and utility services.

1. The proposed building of 250 houses in Honeypot Lane. A few months ago the govenors of St Peters school in South Weald applied for planning permission to extend the school. Planning permission was refused. This was obviously requested because it was considered to be necessary. Now if 250 houses are planned to be built near the school where will the children attend school. Obviously St.Peters will not be able to take them and other schools will have to accomodate children where more houses are being planned.
2. Doctors. It is almost impossible to get a doctors appointment if one is needed quickly so new surgeries will need to be built. Having more doctors at the present surgeries will not solve the problem, it would almost impossible to ring for an appointment on the day. Also surgeries have limited car parking.
3. More care parks would need to be built. When I shop in Brentwood I usually arrive at the multi storey at about 9.00am and have to park on the 9th or 11th floors. There are not many more floors left for general public parking.
4. More people would presumably need to use buses. Services now seem to be cut rather than the other way round.
5. Could utility services cope as they do at present if all the proposed houses are built.

I am not against new houses being built provided that all the points raised are taken into consideration and any others that I have not mentioned.

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.

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