Policy 10.10: Green Infrastructure

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Support

Draft Local Plan

Representation ID: 13220

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

The policy is supported on the basis it seeks an integrated approach to the provision of Green Infrastructure which would include sport and recreation facilities plus seeking new development to make appropriate provision either directly or through financial contributions.

Full text:

The policy is supported on the basis it seeks an integrated approach to the provision of Green Infrastructure which would include sport and recreation facilities plus seeking new development to make appropriate provision either directly or through financial contributions.

Object

Draft Local Plan

Representation ID: 13465

Received: 17/03/2016

Respondent: Mrs Jean Laut

Representation Summary:

Once again disabled access and facilities haven't been mentioned

Full text:

Once again disabled access and fcilities haven't been mentioned

Comment

Draft Local Plan

Representation ID: 13537

Received: 22/03/2016

Respondent: Essex Bridleways Association

Representation Summary:

Policy 10.10 - Green Infrastructure

We note that this policy aims to 'maximise opportunities for the creation, restoration, enhancement, expansion and connection of Green Infrastructure and ... major development proposals should seek to include elements of Green Infrastructure and Ecological Networks'. We request that the enhancement of the public rights of way network is included in this Policy, especially increasing the connectivity of the current Bridleway network.

Full text:

Policy 10.10 - Green Infrastructure

We note that this policy aims to 'maximise opportunities for the creation, restoration, enhancement, expansion and connection of Green Infrastructure and ... major development proposals should seek to include elements of Green Infrastructure and Ecological Networks'. We request that the enhancement of the public rights of way network is included in this Policy, especially increasing the connectivity of the current Bridleway network.

Comment

Draft Local Plan

Representation ID: 14918

Received: 26/04/2016

Respondent: Mr Gordon Bird

Representation Summary:

Public Rights of Way. Need to open up more. Better access to the Country Parks; improved crossings of the A12 and A127, must consider new bridges. Should include cycle paths as well as horse and pedestrian access.

Full text:

Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

I am pleased to have the opportunity to respond to the Brentwood Borough Draft Local Development Plan.
The Plan and the attachments and appendices are voluminous (hundreds of pages). Reviewing the documents had to be done on line as printing was impractical. The volume, copious use of abbreviations and jargon made reviewing it extremely difficult particularly when it came to cross referencing. I had hoped that visiting the drop in display at the Town Hall would have been of help. For example, I was unable to find details in the Plan on the future population and demographics of Brentwood. On approaching a council representative I was advised this was in an attachment however they were unable to find it. It has not been an easy task reviewing the Plan.
As a resident, in North Brentwood I have seen many changes over the years as the area's population has grown.
I particularly value the open countryside (Green Belt) and strongly support its protection. I regularly walk both Weald and Thorndon Park and use the extensive public right of ways which cross the district. Although I walk into town it is not a particularly pleasant experience due to the high volume of traffic which generate high levels of noise and pollutants. Until recently I frequently cycled, however the dangerous state of the roads ( e. g pot holes) and the high volume of traffic, which is often unsympathetic to the cyclist, has restricted this activity. As a motorist I experience the usual lengthy traffic jams and hold ups which clog up Brentwood during peak times and school term. The bus service to and from town is good however it is often late due to adverse traffic conditions.

2)Population Growth and Demographics

This whole plan is has been drafted to show how Brentwood District Council intends to cater for a 15% rise in population over an 18 year period to 2030.
The population growth primarily arises through inward migration, much of which will be from London. The Plan states that the Brentwood's present population is over 73,500 with a significant level of retires - an ageing population trend projected to continue. There are over 32000 properties 76% owner occupied, 63% being detached or semi detached; 58% being 3 or 4 bedroomed, 25% 2 bedroomed.
The only forecast I could find regarding population increases were in PBA Objectively Assessed Housing Needs, Appendix B SNPP 2012 Migration. This stated ' ---- the population of Brentwood is projected to increase from 74.0k in 2012 to 85.2k in 2030'. This is an increase of 15% (11,200 people), however 7200 dwellings are to be built giving an average occupancy rate of 1.6 people per dwelling. If this correct how does this reconcile with Figure 7.1 in the Plan?
Of the projected 7200 dwellings to be built figure 7.1, states that 65% will be 1 or 2 bedroomed. Clearly this implies a dramatic change in Brentwood's environment and demographic mix however the Plan is silent on the implications for infrastructure (e. g. highways, schools, surgeries). As stated in AECOM Sustainability report, some of these are already at capacity.
The plan is also silent on the social and economic effects of this population growth on existing and 'new' residents.







3)Highway Infrastructure

Looking specifically at Ongar Road; over the years traffic volumes have vastly increased as residential properties have been build both close to the town and in the outlying villages. There has been no major structural improvements to accommodate this increased volume save for the installation of mini roundabouts and bollards - which regularly get knocked over and do not get repaired for months. This situation is typical of Brentwood district; Shenfield Road, Ingrave Road, Doddinghurst Road, London Road and other highways all have similar issues.
The Highway Modelling exercise undertaken by PBA confirms that Brentwood roads have insufficient capacity to handle today's traffic volumes. (See section 11 Summary of Junction Outputs) I believe this modelling exercise understates the true size of the problem. Two periods were analysed, 0800 to 0900 and 1700 to 1800, no account has been taken of the effect of the school term when students exit between 1500 and 1600. Why not? During that time traffic in Brentwood centre comes to a stand still, even the paths have insufficient capacity to handle pedestrians. I also note no analysis was undertaken of the M25 junction 28. From experience there are frequent, long queues of vehicles waiting to gain access to the round about.
The Sustainability Appraisal by AECOM also identifies air quality/pollution issues in North Brentwood and Brentwood centre and raised concerns regarding Shenfield.
In short - the investment in public highway infrastructure, namely roads, cycle lanes and footpaths has been totally inadequate. As more dwellings get built the situation gets worse. The district has grown significantly but the highway infrastructure has largely remained as it was over 50 years ago.
The Plan states its policies regarding sustainability however it fails to identify any significant initiatives regarding highway infrastructure which address problems associated with traffic congestion and pollution, cycling or walking. Building more dwellings without properly addressing these issues first will be to the detriment of residents well being and employment prospects in Brentwood.


4)Green Travel Route

This Plan advocates adding public transport to the already congested A127 and A128.
The A128 is a very busy, narrow trunk road carrying passenger and commercial vehicles. At present, when stopping for passengers, buses cause hold ups particularly during school times and where there are no lay-bys. Adding more buses will slow traffic and create more noise and pollution for residents close to the road.
People do cycle along the A128 however it is a dangerous exercise as drivers have difficulty in overtaking and can become impatient. A cycle path would improve the situation.
Installing a 'Green Travel Route' would be a retrograde step, adding to the existing congestion and pollution and should not be actioned.


5)Public Rights of Way (PROW)

The Plan needs to actively consider the opportunity to open up access to the surrounding countryside and parks by investing in upgrading and creating footpaths and bridleways for non vehicular use. At present access routes to both Weald and Thorndon Parks encourages the use of cars at the expense of walking and cycling. Paths which cross the A12 and A127 are dangerous and recently there has been serious accidents involving pedestrians; public are reluctant to use them. The Ordnance Survey shows 6 PROWs crossing the A127 between the M25 and the Dunton intersection. Similarly there are 4 PROWs crossing the A12 between the M25 and Ingatestone.
To the North of the A127 footpaths provide access to open spaces and in particular Thorndon Park. Access to these areas from the south (Horndon and Basildon) is only practical using a vehicle. This is not satisfactory; building bridges over the A127 that connect the footpaths would enable none vehicular traffic to safely gain access to this wonderful amenity. Likewise a bridge over the A12 would enable people to move safely between Brentwood and Shenfield and outlying communities such as Pilgrims Hatch, Kelvedon Hatch and Doddinghurst. The paths would need upgrading to take cycles.
Weald Park is only 1 -2 kilometres from Brentwood centre yet walking or cycling to it using Weald Road and Weald Park Way is dangerous as the footpaths are not continuous, the traffic volumes high and the roads are narrow and winding. The paths should be upgraded and lengthened to enable pedestrians and cyclists safe access. The same could be said for Sand Pit Lane - a footpath is sorely needed.


6)Financial

Where are the financial figures that support this Plan? How can a plan be issued proposing such massive changes without some supporting financials e.g. infrastructure investment costs, impact on the tax payer.

7)Conclusion

The expansion of Brentwood District by over 20% through building 7200 new dwellings while increasing the population by over 15% (11,200 people) will have a dramatic effect on all aspects of life in Brentwood - social, environmental, commercial. It will change the nature and character of the area. Little demographic information is provided on who the new comers are and what their needs will be in addition to housing. It is hard to determine what benefit, if any, this expansion will have to present residents.
The draft plan is describes the proposed location of houses and the build schedule however I have major concerns over the need to upgrade Brentwood's infrastructure. My fear is the investment will not be forthcoming and policies relating to 'sustainability' will not be achieved. If that happens Brentwood will be a poorer place to live and work.

Support

Draft Local Plan

Representation ID: 15184

Received: 28/04/2016

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Representation Summary:

The allocation of a new village scale of development and particularly on the Dunton Hills site affords a unique opportunity to enhance, improve and extend the provision of Green infrastructure. Early evidence prepared on behalf of the Promoters identifies extensive opportunities to use the existing natural topography and landscape features as an integral part of the village design and then to improve and extend them into the site and beyond.

Full text:

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Comment

Draft Local Plan

Representation ID: 15242

Received: 03/05/2016

Respondent: Natural England

Representation Summary:

We have also looked at, and are generally supportive of, the Strategic Objectives, Spatial Strategy, General Development Criteria, and the various policies covering the environment, Green Infrastructure, air quality, lighting, flood risk and Sustainable Urban Drainage.
We also note that the Plan has been informed by the Brentwood Green Infrastructure Strategy (2015) and recognises the need, as highlighted therein, to better link formal and informal open spaces in the Borough to improve their wider use and value.

Full text:

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Comment

Draft Local Plan

Representation ID: 15526

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

It is encouraging to see the emphasis on protecting green belt land and the promotion of green infrastructure. It is extremely positive that the proposed development allocations will only reduce the Borough's proportion of green belt from 89% to 88%.

Full text:

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Comment

Draft Local Plan

Representation ID: 15527

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

We would like to see further information on the development of the proposed enhanced green wedges.

Full text:

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Comment

Draft Local Plan

Representation ID: 15528

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

We fully support this policy, which promotes an integrated approach to providing green infrastructure, including using it for open space, recreation, flood risk management, habitat creation, climate change mitigation and water quality improvements. This should be expanded to make reference to realising opportunities to meet the objectives of the Thames and Anglian River Basin Management Plan (RBMPs), for example through protecting and enhancing river corridors or networks of wildlife habitats. It is disappointing that no reference is made to either of the RBMPs as part of the evidence base.

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Comment

Draft Local Plan

Representation ID: 15529

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

In reference to paragraph 10.46 of the plan, even where a site is constrained due to its urban nature or for other reasons, environmental gains can still be achieved through de-culverting, creation and management of ecological buffer strips, or new wetland areas. Even these smaller gains can help to reduce pollution and help to reconnect people to nature.

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Comment

Draft Local Plan

Representation ID: 15530

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

We would recommend that more detail is included in the Local Plan with regards to the rivers within the borough, their ecological status and potential opportunities for improving these through drivers such as the Water Framework Directive (WFD) and Eel Regulations. Several of the water bodies are all currently at less than good ecological status (e.g. Wid) and need to be a good status or potential status by 2027 in order to meet the requirements of the WFD. Any development proposals need to be compliant with the WFD in ensuring no deterioration and where possible seek enhancements.

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Comment

Draft Local Plan

Representation ID: 15531

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

The plan is very land centric and only mentions water bodies or waterways in passing. We would like to see further detail regarding the rivers within the Borough and specifically the headwaters of the Rivers Wid and Mardyke for our area. Given the improvements suggested above, we consider that this could be addressed through a completely separate policy, which should address water quality, the requirements of the WFD and RBMP objectives. We would like to see a new policy on the protection, enhancement and buffering of watercourses to help in the achievement of WFD objectives. This should include the provision of ecological buffer strips and corridors, native tree planting and the new wetland areas to help manage flood risk and reduce diffuse pollution whilst connecting people to nature. This could also include de-culverting, removal of redundant structures, alien species removal where appropriate. The need for this is supported in paragraph 21.1.4 of the Interim Sustainability Appraisal.

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Comment

Draft Local Plan

Representation ID: 15532

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

We support this policy but consider it would benefit from a reference to applying a sequential approach within sites, as well as them passing the requirements of the Sequential Test. This will ensure that more vulnerable development is directed to lower risk areas of a site, especially on mixed use development sites. It also can direct open space to higher risk areas, allowing an integrated approach to open space, recreation and flood risk management. More emphasis should be placed on enhancing existing flood management systems rather than focussing purely on managing flood risk to and from new development. We would encourage you to liaise with Essex County Council as Lead Local Flood Authority to identify potential opportunities to reduce and manage surface water flooding.
This policy could be improved by having some supporting text that further explains what is meant by resistant and resilient design means.
It could also benefit from mentioning (if not within a new policy) the need to ensure that development does not prevent flood risk management now or in the future. This is particularly important to us, as we often access to watercourses for example to exercise our permissive powers. In addition, space should be safeguarded for future defence raising.

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