Plan-Making

Showing comments and forms 1 to 30 of 40

Comment

Preferred Site Allocations 2018

Representation ID: 17918

Received: 12/02/2018

Respondent: Ms Connie Roffe

Representation:

A large document of this size will probably not be read by the majority of people. If planners truly want people to engage and respond then smaller documents containing relevant and detailed information have to be considered. Unless the idea is to ignore the people's wishes.

Full text:

A large document of this size will probably not be read by the majority of people. If planners truly want people to engage and respond then smaller documents containing relevant and detailed information have to be considered. Unless the idea is to ignore the people's wishes.

Object

Preferred Site Allocations 2018

Representation ID: 18099

Received: 08/03/2018

Respondent: Mr Gordon Bird

Representation:

In paragraph 3 it states 'Development needs have been met --'. I do not accept this. For example traffic pollution levels in several areas of Brentwood exceed government limits. People are being poisoned.
There are other examples particularly to do with infrastructure capacity - roads, schools, public transport

Full text:

In paragraph 3 it states 'Development needs have been met --'. I do not accept this. For example traffic pollution levels in several areas of Brentwood exceed government limits. People are being poisoned.
There are other examples particularly to do with infrastructure capacity - roads, schools, public transport

Object

Preferred Site Allocations 2018

Representation ID: 18222

Received: 12/03/2018

Respondent: Mrs Wendy Taylor

Representation:

We need more social housing -affordable housing is not affordable especially for youngsters. When selling the new properties or allocating social housing priority should be given to local people.

Full text:

we need more social housing -affordable housing is not affordable especially for youngsters. When selling the new properties or allocating social housing priority should be given to local people.

Comment

Preferred Site Allocations 2018

Representation ID: 18362

Received: 12/03/2018

Respondent: Essex County Council

Representation:

Plan Making - ECC Interest in the Draft Local Plan Preferred Site Allocations Consultation

Full text:

ECC Interest in the Draft Local Plan Preferred Site Allocations Consultation -

Essex County Council (ECC) supports the preparation of a new Local Plan for BBC. A Local Plan by setting out a specific vision and policies for the long-term planning and development of the borough can provide a platform from which to secure a sustainable economic, social and environmental future to the benefit of residents, businesses and visitors. A robust long-term strategy will provide a reliable basis on which ECC and its partners may plan future service provision and required community infrastructure for which they are responsible. ECC will also use its best endeavours to assist on strategic and cross-boundary matters under the duty to cooperate, including engagement and co-operation with other organisations for which those issues may have relevance.

ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that live, work, visit and invest in Essex. As a result ECC is keen to understand, inform, support and help refine the formulation of any development strategy and policies delivered by Local Planning Authorities. Involvement is necessary and beneficial because of ECC's roles as:
a. a key partner within Greater Essex, promoting economic growth, regeneration, infrastructure delivery, Garden Communities and sustainable new development;
b. provider and commissioner of a wide range of local government services throughout the county;
c. the highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; Local Education Authority including early years and childcare; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health; and adult social care in relation to securing the right housing mix which takes account of the housing needs of older people; and
d. as an infrastructure funding partner, that seeks to ensure that the proposals are realistic and do not place an unnecessary (or unacceptable) cost burden on the public purse, and specifically ECC's Capital Programme.

Comment

Preferred Site Allocations 2018

Representation ID: 18365

Received: 12/03/2018

Respondent: Essex County Council

Representation:

Plan Making - Duty to Co-operate

Full text:

Duty to Co-operate -

The 'duty to cooperate' (the Duty) was introduced by the Localism Act in November 2011. The Act inserted a new Section 33A into the Planning and Compulsory Purchase Act 2004. This placed a legal duty on all local authorities and public bodies (defined in Regulations) to 'engage constructively, actively and on an ongoing basis' to maximise the effectiveness of local and marine plan preparation relating to strategic cross boundary matters, and in particular with County Councils on strategic matters.

The National Planning Policy Framework (NPPF) provides detail on how strategic planning matters should be addressed in local plans (paragraphs 178-181). Local planning authorities are expected to work 'collaboratively with other bodies to ensure that strategic priorities across local authority boundaries are properly coordinated and clearly reflected in local plans' (paragraph 179). 'Strategic priorities' to which local planning authorities should have particular regard are set out in paragraph 156 of the NPPF.

Specific guidance on how the Duty should be applied is included in the National Planning Practice Guidance (PPG). This makes it clear that the Duty requires a proactive, ongoing and focussed approach to strategic matters. Constructive cooperation must be an integral part of plan preparation and result in clear policy outcomes which can be demonstrated through the examination process.

The PPG makes it clear that the Duty requires cooperation in two tier local planning authority areas and states 'Close cooperation between district local planning authorities and county councils in two tier local planning authority areas will be critical to ensure that both tiers are effective when planning for strategic matters such as minerals, waste, transport and education.' (Paragraph: 014, Reference ID: 9-014-20140306)

In accordance with the Duty, as established in the Localism Act 2011, ECC will contribute cooperatively to the preparation of the Brentwood Local Plan, particularly within the following broad subject areas,

* ECC assets and services. Where relevant, advice on current status of assets and services and the likely impact and implications of proposals in emerging plans for the future operation and delivery of ECC services.
* Evidence base. Guidance with assembly and interpretation of the evidence base both for strategic/cross-boundary projects, with a focus on education provision, transport studies and modelling, and economic growth requirements.
* Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for the new Local Plan may impact on areas beyond and vice-versa.
* Policy development. Contributions on the relationship of the evidence base to structure and content of emerging policies and proposals.
* Inter-relationship between planning documents. Including the Essex Minerals Local Plan and the Essex and Southend-on-Sea Waste Local Plan.

BBC has already undertaken work with ECC under the Duty during the preparation of the Draft Local Plan with regards to highway matters, education, minerals and waste, and other areas of responsibility of ECC.

The ECC response identifies where and how BBC need to further engage with ECC to ensure BBC meets its duty to cooperate, and where BBC need to consider additional evidence to further inform and clarify the policies in its new Local Plan.

An Infrastructure Delivery Plan (IDP) will need to be prepared to support the pre-submission Local Plan, to identify the infrastructure required, and how and when it will be funded and delivered. As a provider of key services and subject to statutory responsibilities, for example minerals and waste, highways and education, ECC will need to be involved in the preparation of the IDP.

ECC will continue to contribute cooperatively with BBC in the preparation of the new Local Plan through to examination. To this end, BBC will need to ensure ECC is involved in the further assessment of the impact of growth proposals on the transport and highway network and required mitigation (it is noted that transport modelling is being undertaken by external consultants and not through ECC, therefore ECC will need to review and qualify the external consultants' findings and recommendations); further assessment of the need for additional pupil places and school provision, including early years and childcare; consideration of surface water management; and consideration and planning for minerals and waste management, amongst other relevant matters. ECC will also engage actively with Highways England (HE) on the M25 and A12 to ensure that any strategic impacts arising from growth are considered on their network. The impacts of the preferred route of the Lower Thames Crossing (LTC) will also need to be considered in relation to transport movements within the Borough, and beyond, as well as any potential impact on the proposed spatial strategy.

ECC recommends that BBC ensures that engagement with ECC officers and members takes place collaboratively on an active, regular, and ongoing basis covering all areas of ECC responsibility to ensure the Local Plan is deliverable and viable as it prepares its Regulation 19 Local Plan. This will include seeking to ensure that the emerging Local Plan and the supporting evidence base contain appropriate information concerning the phasing, delivery and funding of infrastructure. Most notably education - primary and secondary schools, early years and child care provision - delivery of sustainable urban drainage (SuDS), transportation mitigation, and infrastructure required for the Dunton Hills Garden Village (DHGV).

This is crucial given that BBC's timetable for Local Plan preparation indicates 'Pre Submission' consultation is scheduled for the third quarter 2018 (July-September) and the Submission Local Plan is anticipated for the fourth quarter of 2018 (October-December). ECC notes this is an ambitious timetable given the need for BBC to address the full range of consultation responses and update the evidence base particularly the IDP and complete transport modelling and mitigation requirements, in order to produce a sound, justified and compliant Local Plan, in what would amount to a few months. ECC advises that other Essex authorities have generally taken 12 months between Regulation 18 to Regulation 19 given the complexity of issues and outstanding matters that need to be resolved.

ECC also recommends significant partnership working will be necessary with BBC, its transport consultants, and Highways England (HE), in reviewing and progressing the highway modelling to support the Local Plan, including the identification of necessary mitigation measures on the strategic (M25/A12/A127) Corridor, local and wider highway network, including sustainable transport measures.

Such partnership working is to include regular joint liaison meetings between PBA (Peter Brett Associates - BBC's transport consultants), HE, BBC and ECC to progress the plan regarding highway matters. It will also be necessary to identify the requirements for infrastructure and other planning mitigation measures with regards to individual sites, and especially those regarded as 'strategic' in nature.

Meetings and working groups should also be established with the other ECC functions, as well as associated external partners, including those relating to public health, education, minerals and waste, flooding and community infrastructure.

ECC draws attention to its response to the Draft Local Plan consultation in 2016, and would advise BBC that its content is still relevant to the current consultation. This is attached as Appendix 2.

In summary ECC re-iterated the need for the Local Plan to be supported by a proportionate evidence base and that all reasonable alternatives for a spatial strategy be considered. Further clarification was sought on a number of matters including:

Spatial Strategy -
* how the A127 Corridor provides more opportunities for growth than the A12 Corridor,
* identification of any cross border implications of the spatial strategy given ECC's role as highway, education, minerals and waste authority,
* identification of what infrastructure is necessary to deliver the spatial strategy, strategic and individual site allocations;

Housing -
* demonstrate that level of growth can be accommodated by the existing and new social and physical infrastructure,
* how Independent Living programme is to be delivered,
* joint working with ECC and partner local authorities to identify and deliver transit sites for Gypsy and Travellers;

Economic Growth -
* additional evidence required regarding the impact of the significant employment land allocation at Brentwood Enterprise Park on the strategic junction, local road network, and necessary mitigation measures, including sustainable transport measures given the location is not favourable to sustainable travel;

Highways -
* joint working should be established between all the relevant partners to identify necessary mitigation at relevant junctions, to consider the cumulative impact of growth within the borough, and to consider the wider planned growth on the local and strategic route network;

Education -
* continued work required by BBC with ECC to ensure education needs are appropriately and adequately assessed as the new Local Plan continues,
* further assessment of potential delivery and resource requirements for accommodating anticipated pupil growth to inform pre-submission plan and Infrastructure Delivery Plan (IDP),
* consider potential cross-boundary issues with Basildon arising from Dunton Hills Garden Village (DHGV),
* early years and childcare requirements should be included.

ECC recommends that all of the matters raised in its 2016 response are addressed as the plan progresses through to pre-submission.

Object

Preferred Site Allocations 2018

Representation ID: 18510

Received: 13/03/2018

Respondent: Mr Geoffrey Town

Representation:

Object to the whole plan as it is quite clear as the whole of the area is already over populated.

Full text:

My general comment is that I object to the lack of both time and constructive consultation given for such an important proposal; to the extent I get the impression it is a deliberant attempt to result in negative result. How one can be expected to form an intelligent opinion on a 100-page document and supporting documents, the informing letter received Feb. 2 and comments to be submitted by 12 March I consider quite unreasonable.
At the Council`s drop-in on 19 Feb. I and many others hoped to receive specific answers to questions relating to Blackmore but due to large number of people attending and few officers in attendance, and the latter either not able or apparently or unwilling to answer specific questions it was a waste of time.
Summing up it the Local Plan `drop in` was a political exercise to enable a tick to be placed in the Consultation carried out box.

I object to the whole plan as it is quite clear as the whole of the area is already over populated.
Specifically, as far as Blackmore is concerned the infrastructure is already overload particularly traffic wise not just local but from adjacent areas. As far the extra houses are concerned the plan only states numbers not what is important is types i.e. are they 2,4,5, bedroomed and how many storeys?
There are too few affordable properties now and the number reducing as properties have been and are being extended with planning permission, also all the new build locally has been unaffordable; who permitted these; the planning department.
This is of personal interest to me as we have a large four-bedroom property and since we retired we have been looking for a smaller property we could afford but as time goes on it gets increasingly less possible. We know of several others in the parish in this predicament or nearing it.

I also support the Parish Council`s objections so I will not bore you repeating or paraphrasing them.

Object

Preferred Site Allocations 2018

Representation ID: 18513

Received: 13/03/2018

Respondent: Mr Geoffrey Town

Representation:

The Local Plan `drop in` was a political exercise to enable a tick to be placed in the Consultation carried out box.

Full text:

My general comment is that I object to the lack of both time and constructive consultation given for such an important proposal; to the extent I get the impression it is a deliberant attempt to result in negative result. How one can be expected to form an intelligent opinion on a 100-page document and supporting documents, the informing letter received Feb. 2 and comments to be submitted by 12 March I consider quite unreasonable.
At the Council`s drop-in on 19 Feb. I and many others hoped to receive specific answers to questions relating to Blackmore but due to large number of people attending and few officers in attendance, and the latter either not able or apparently or unwilling to answer specific questions it was a waste of time.
Summing up it the Local Plan `drop in` was a political exercise to enable a tick to be placed in the Consultation carried out box.

I object to the whole plan as it is quite clear as the whole of the area is already over populated.
Specifically, as far as Blackmore is concerned the infrastructure is already overload particularly traffic wise not just local but from adjacent areas. As far the extra houses are concerned the plan only states numbers not what is important is types i.e. are they 2,4,5, bedroomed and how many storeys?
There are too few affordable properties now and the number reducing as properties have been and are being extended with planning permission, also all the new build locally has been unaffordable; who permitted these; the planning department.
This is of personal interest to me as we have a large four-bedroom property and since we retired we have been looking for a smaller property we could afford but as time goes on it gets increasingly less possible. We know of several others in the parish in this predicament or nearing it.

I also support the Parish Council`s objections so I will not bore you repeating or paraphrasing them.

Object

Preferred Site Allocations 2018

Representation ID: 18541

Received: 12/03/2018

Respondent: Mr and Mrs Williams

Number of people: 2

Representation:

A local planning authority should submit a plan for examination which is "sound", in respect of how it is prepared, whether proposals are properly justified, whether it can be delivered, and whether it is consistent with national policy. The plan clearly has fundamental shortcomings. It is not therefore sound or robust.

Full text:

I am writing to express my total opposition to Honeypot Lane being proposed as a preferred site under the local plan and wish to see the site removed as a preferred site for additional homes.

My reasons are as follows:
For years Honeypot Lane has been used as a rat run. The Lane - note a Lane not a road - would not cope with the significant extra traffic that 200 homes plus a Care Home would bring if it were used as an access to/from the proposed site. It is narrow and has been designated a 20-mph limit area for good reason.

There is a major safety issue - there have been accidents in Honeypot Lane due to the speed of traffic, even though it is a restricted speed area.

In addition, any such development would put lots of extra pressure on the pinch point in Weald Road, which at the moment is too narrow for two cars to pass each other on route to or from the High Street.

If cars cannot reach the High Street via Weald Road, the traffic will then impact on other cut-through roads, e.g. Sandpit Lane, Park Road etc. to Ongar Road or London Road, bringing major congestion and the increased probability of accidents. In the case of vehicles heading for the A12/M25, Honeypot Lane will grind to a halt and the Homestead estate will also be swamped with vehicles. In fact, all surrounding roads that provide access will be affected.
When there are problems on the A12/M25, which occur with great regularity, the resulting extra traffic trying to avoid the town centre is already a problem; these extra cars will just exacerbate the chaos and will add to the impact on Brentwood.

The impact of the additional movements of a possible 500 extra cars, together with parcel/shopping delivery and other vehicles, from the proposed development to Brentwood/Shenfield stations, local schools, access to the A12 and M25, together with its effect on all the surrounding roads, which were not built for this volume of traffic, will bring even more disruption at crucial times of the day. Any construction traffic will make the resultant traffic chaos unimaginably worse.

There have already been a significant number of houses built in the vicinity of Brentwood town centre in recent years; this further proposed development will add to the over-development.

The noise and pollution resulting from the A12 is already a problem; further building would only exacerbate the problem.

Our nearest local schools, St. Peter's and Holly Trees, are already oversubscribed. Therefore, this will add to the traffic chaos surrounding Brentwood when parents have to travel further afield to take their children to schools out of area.
Our local doctors' surgeries are already at capacity - in fact, it already takes 3 to 4 weeks to obtain an appointment.

The proposed site is already subject to flooding. In fact, there is a stream that runs through it, which flows from the higher ground around the High Street/London Road.
If any new development were built on this proposed area, then it would increase the risk of flooding to other nearby areas - water will always find a way out. The houses would have huge problems obtaining buildings insurance, if indeed it were possible at all, in light of Insurance companies reviewing their stance due to an increase in flooding claims and the effects of climate change. It seems totally irresponsible to consider building homes on land that will flood, especially in light of the
effects of previous planning disasters which have seen residents forced out of their homes in places like Cumbria, Somerset and in the Thames Valley.

It is to be pointed out the Brook Road, Talbrook, etc.- nearby roads - have their names for a reason! Drainage has always been a problem in Honeypot Lane, which I am sure even your own records will confirm.

Wildlife, such as bats, badgers, pheasants, foxes, newts, etc. use the proposed site and nearby area.
In addition to the above, I would draw your attention to the following further arguments against the suggested development at Honeypot Lane.
You are suggesting a major development on greenfield site on the edge of the built up area. When the site was originally put forward the Council, rejected it because it did not meet the Spatial Strategy.
The spatial strategy states that:
"To meet local needs fully there will be limited release of Green Belt for development within transport corridors, in strategic locations to deliver self-sustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries to avoid further sprawl and
provide development swiftly."

And that all development sites will be identified having regard to whether they:
a) are accessible to public transport, services and facilities;
b) will have no significant impact on the Green Belt, visual amenity, heritage, transport and environmental quality including landscape, wildlife, flood-risk, air and water pollution; and
c) are likely to come forward over the Plan period.
The plan provides no details to support the proposal, only the boundaries and location of the proposed site, and the number of dwellings it might accommodate. There is no explanation as to why the site is thought to be suitable for this scale of development.
The proposal makes reference to an evidence base and infrastructure but is only able to say that an "Infrastructure Delivery Plan is forthcoming". No other evidence is put forward. National guidance states that Local Planning Authorities should assess the quality and capacity of infrastructure, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, and flood risk, and its ability to
meet forecast demands. This has not been done.

Local residents are being asked to comment on a major proposal, having been presented with only an outline of what is proposed. It is not known the refore what benefits, if any, there might be for the area, or how the scheme might seek to mitigate against the many harmful impacts.
The Borough Council are therefore attempting a consultation exercise on a proposal which is at best sketchy, is poorly researched, and premature in terms of an evidence base. Overall therefore it is illconceived. The National Planning Policy framework says that local planning authorities should aim to involve all
sections of the community in the development of Local Plans and in planning decisions, which should facilitate neighbourhood planning.

It also says that: "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable
development of the area, including those contained in any neighbourhood plans that have been made."

In passing the Localism Act the Government has said that: "Too often, power was exercised by people who were not directly affected by the decisions they were
taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them."

The plan and the consultation process have so far been a top down process, with little regard for the involvement of the local community.

The National Planning Policy Framework states that:
"The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."

The proposal is within the Green Belt. National planning guidance is clear that development in the Green Belt is by definition inappropriate and harmful.
Exceptional circumstances must exist to justify the loss of Green Belt land. The Government has clarified that housing demand is unlikely to constitute the exceptional circumstances to justify such loss.

The site would project out into open Green Belt land, bounded only by narrows lanes, with open fields beyond.

Whether new development can be proved to be sustainable is central to planning policy. Sustainable is defined as "ensuring that better lives for ourselves don't mean worse lives for future generations". In practice the essential requirement is that new homeowners will not be over dependent on the car for journeys to work, school, shops, leisure activities, and other services and amenities.

The proposed site is on the western edge of the town, over 1 kilometre from the centre of the town and further still from Brentwood railway station and access to the A12/M25. If the residents of the new development have no choice but to make most journeys by car, the site does not offer a sustainable location.
A development of some 200 houses would increase traffic levels on roads and junctions that are already inadequate.

There is no indication as to where the main access to the site would be located, or what improvements to Honeypot Lane and Weald Road might be necessary, if indeed they are feasible, or how they will be funded.

The Council's website indicates that the impact and the need for infrastructure supporting new development will be considered in greater detail by the Infrastructure Delivery Plan and the Local Plan.

Council have only just on (29th January) launched an infrastructure Delivery Plan website. There is no information about Honeypot Lane. The proposals are not clear on the mix and proportion of land uses, with what appears to be a leaning
towards an almost wholly residential scheme. There is no question that a development of the scale proposed will greatly increase the volume of
traffic passing through the surrounding residential streets. Overall the concern is that the people of the local community are most likely to suffer the harmful
impacts of the development by way of increased traffic, overlooked gardens and properties, loss of rural character, without any discernible benefits.

There is no evidence that the Council has carried any assessment of drainage in the area. National guidance states that: "Local Plans should develop robust and comprehensive policies that set out the quality of developments that would be expected of the area, responding to local character and being visually attractive."
A local planning authority should also submit a plan for examination which is "sound", in respect of how it is prepared, whether proposals are properly justified, whether it can be delivered, and whether it is consistent with national policy.

Given the level and extent of the concerns as set out above, the plan clearly has fundamental shortcomings. It is not therefore sound or robust.
In view of the aforementioned, we contend that the posited development of Honeypot Lane be scrapped and that the faceless land owners, who are not part of the local community, are informed that their speculative venture has failed, as a result of overwhelming location opposition and for the many reasons referred to above.

Comment

Preferred Site Allocations 2018

Representation ID: 18632

Received: 20/03/2018

Respondent: Wycombe Council

Representation:

Confirm on behalf of Wycombe District Council that we have no comments to make on this consultation.

Full text:

Thank you for your email informing us of your consultation. I can confirm on behalf of Wycombe District Council that we have no comments to make on this consultation.

Object

Preferred Site Allocations 2018

Representation ID: 18748

Received: 12/03/2018

Respondent: Ms Lise Spicer

Representation:

The council has deliberately misled residents . Why did our councillors blatantly lie to us with seemingly no repercussions about protecting the green belt?

Full text:

I object to these proposals because

Infrastructure

The road infrastructure is already under severe strain currently if there are any incidents on the surrounding roads our villages of Herongate and Ingrave grind to a halt.
Our children are regularly late for school because the school bus is caught up in the traffic. The current level of fuel emissions from the cars in stationary traffic are already detrimental to the environment and have health implications how can you possibly consider adding to this.

The roads are currently poorly maintained with huge pot holes along the A128 if you cannot maintain these with the current levels of traffic how do you propose to maintain these with the significant increase in traffic.

Have c2c been approached to outline how they will cope with the impact of increased number passengers at either West Herndon or Upminster station or adding another station? Both station car parks are already at bursting point I cannot see evidence of consultation with the rail network on your plans


Affordable Housing

I am concerned the houses will not be affordable for first time buyers but will simply be priced at market rate so in reality there will be a proportion of affordable or social housing amongst houses in excess of £750k


Strain on NHS

Orsett hospital is closing, several hospital trusts are merging, given most of the hospitals were declaring black alert due to shortage of beds in a&e how do you propose they will cope with several thousand extra people in the area?


The council has deliberately misled residents

Why did our councillors blatantly lie to us with seemingly no repercussions about protecting the green belt?

Object

Preferred Site Allocations 2018

Representation ID: 18803

Received: 12/03/2018

Respondent: Carolyn Harris

Representation:

I am writing this with no doubt in my mind that this is futile, as I am sure all the other objections are. This is merely a tick box exercise. Those who should represent the needs of the local residents have not so for many years.

Full text:

The number of dwellings proposed for each site around the centre of Brentwood suggests small dwellings with increased population requirements. Flats seem to be a common theme and there is a proliferation of them already. While I recognise people need to live somewhere, there is little evidence that due consideration has been given to the infrastructure. Living the experience, it is impossible to get a GP appointment; dentists are equally difficult to access, many refusing to take on more patients. The roads are increasingly impassable due to the sheer weight of traffic and it is likely that many of the flats put up will have limited parking which means increased parking on pavements and local roads, adding to the problem. The roads and pavements are in poor repair already without the additional numbers proposed for Brentwood.
There is little said about the retail needs of the town. It is increasingly obvious, that Sainsburys is not coping with the demand and the retail in Brentwood offers little choice to the local residents. The Bay Tree Centre has been largely neglected and the move to remove BM and eventually Wilkinsons so more flats can be built will force residents to shop elsewhere, further destroying the community and will go against the needs of vulnerable residents who may not have the option. The suggestion that William Hunter Way site will provide retail space as well as housing has already been proposed before with huge wastes of public money after the whole plan collapsed. Are we really to believe that there will be good retail provision? Added to this if you remove all the car parks, the suggestion is we do not need them, as there will be no shops to visit! The Government focus is solely on housing at all costs and not the living experience or quality of life of those who have to live there. The plans suggest to me that this has not been considered for those who live close to the centre and I know from bitter experience, how poorly the Brentwood Borough Council function, with poor processes, lack of transparency, and generally ignoring the needs of the local residents.
I am writing this with no doubt in my mind that this is futile, as I am sure all the other objections are. This is merely a tick box exercise. Those who should represent the needs of the local residents have not so for many years.

Object

Preferred Site Allocations 2018

Representation ID: 18841

Received: 05/02/2018

Respondent: Sue Marigold

Representation:

The consultation for the semi-pedestrianisation of the High Street was largely ignored, resulting in an expensive disaster. Please do not make the same mistake of ignoring public opinion.

Full text:

I am re-emailing my previous comments as I feel that they are still relevant.


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 Brentwood workers park, long-stay? Its difficult enough at present.

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. Unsurprisingly, 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.
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?

* 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. There is always Lakeside. Or, I would drive further afield for a much wider choice of niche shops, for example to Tunbridge Wells, or Cambridge.

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 (if smaller or larger units are desired) 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. We still don't have a cinema in the town, which is a great shame. 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. This requires development so that it is both attractive and useful.

6. 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.

7. 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.

kind regards
Susan Marigold

Object

Preferred Site Allocations 2018

Representation ID: 19073

Received: 04/04/2018

Respondent: Mr Ian Atkinson

Representation:

I expect there will be less responses to this plan than previous ones. You should not conclude from this that this means there is less concern or opposition to it. People have simply become weary of being asked to repeatedly comment on similar proposals and also do not believe that their representations are listened to or taken into account.

Full text:

As requested I am providing feedback on the Brentwood Draft Local Plan, in terms of its impact on West Horndon village.

Like the vast majority of West Horndon residents, I would like West Horndon to remain the small village it is today. My wife and I moved here 22 years ago and it was a conscious decision to choose to live somewhere with a sense of community and with plenty of green space. We enjoy village life and it is a pleasant, safe place in which to raise our son.

I do however accept that some changes are necessary and have got reasonably comfortable with the residential development planned for the industrial estate. Although this would considerably increase the size of the village, it would also bring benefits, not least of which would be an end to the vast number of lorries thundering through the village, albeit many of these would be replaced by cars.

I disagree that this site is suitable for high density housing. The housing built on this site should be similar to and consistent with the existing housing in the village. There are also a lot of elderly people living in the village. Consideration should be given to building senior citizen housing. This would enable our senior citizens, when they reach the point when they cannot live entirely independently, to move to this accommodation. This would provide them with the support they need whilst enabling them to stay within their community. It would then free up their existing bungalows for new families.

I do not agree that the village has excellent transport links and was astonished to be told at a recent drop-in event that this was the main reason this area has been chosen for development. Yes we have a railway station and are close to the A127 and M25 but our trains and our roads are already extremely overcrowded and will not be able to cope with the extra amount of people. Your plan seems to ignore the equally important A12 and Crossrail opportunities. The impact on West Horndon also does not appear to have been taken into account regarding the plan to build Dunton Garden Village right next door to our village.

Whilst I appreciate that you need to come up with a viable plan to deliver the amount of housing required, I would urge you to consider the impact of any proposals you make on the lives of the people it will affect. The residents of West Horndon chose to live in a village, not a large town and our way of life should be respected as much as anyone else.

Finally, what I oppose most strongly in the plan is the proposal for us to have over 50% of the new gypsy and traveller sites. This is a step too far. We should not have to accept over 60% of the housing, over 80% of the employment land allocations and over 50% of the new gypsy and traveller sites. This is too much for one small village and these sites would not be compatible with our community and way of life. An alternative site should be found elsewhere in the Borough.

I expect there will be less responses to this plan than previous ones. You should not conclude from this that this means there is less concern or opposition to it. People have simply become weary of being asked to repeatedly comment on similar proposals and also do not believe that their representations are listened to or taken into account.

Object

Preferred Site Allocations 2018

Representation ID: 19085

Received: 21/02/2018

Respondent: Miss Dale Rutherford

Representation:

Despite being a wealthy council, money seems not to be spent where necessary. For example wheelchair users cannot get to anywhere unaided due to the massive potholes in the pavement.

Full text:

Brentwood cannot cope at peak times with the traffic it already has. Similarly, parking is already a problem in and around the town, both in Brentwood and in Shenfield.

Crescent drive, on a school day morning is a solid traffic jam from London road to Middleton road, putting 55 family houses with multiple cars on top of that, when people need to get to the hospital is madness.

Priests lane has a similar issue and the local area cannot sustain this many houses, people or cars.

Despite being a wealthy council, money seems not to be spent where necessary, for example I am a wheelchair user and cannot get to the end of my road unaided due to the massive potholes in the pavement.

7000 homes over 5 years in the Brentwood and Shenfield area is insanity.

Object

Preferred Site Allocations 2018

Representation ID: 19107

Received: 23/02/2018

Respondent: J. S. and R. Mack

Number of people: 3

Representation:

I was amazed to hear one of the councilors mention that the inclusion of sites in the draft plan had not been considered previously by councilors. The inclusion of sites within the plan it would seem is officer led. Unfortunately officers had previously recommended a back garden development for approval on the Homesteads Estate that was rejected unanimously by all planning committee members and also rejected at a subsequent appeal. Hopefully officers will listen to the significant objections of local residents and remove the site (Honey Pot Lane) from the plan.

Full text:

I would wish to record the objections of my wife, my son and myself to the above-proposed site being included within the Local Plan. The reasons for my objection are noted below:

The proposed development will ruin the rural environment in which I have lived for over 20 years. The development will create a huge housing estate almost equal in size to the Homesteads estate with more than double the density. It will destroy the character of the whole area. Even though the site is constrained and adjacent to the A12 the green open space is highly valued by local residents in terms of the environment and significantly contributes to the quite rural setting. You state in the plan that sites are also selected to prevent sprawl, however because of the restriction of he A12, traffic from the development can only disperse via Honey Pot and adjoining roads. A housing development of 200 homes will totally destroy the character of the whole area; create increased traffic related issues including noise nuisance and concerns related to safety and rat running.

The new St Charles development has created additional traffic nuisance through Honey Pot Lane and in particular Hill Road and the Homesteads estate. This is as a result of motorists having difficulties exiting at the junction of Honey Pot Lane and London Road; motorists now use Hill Road as a rat run. Indeed Councilor Will Russell admitted to me himself at a previou road show event at South Weald Parish Hall that he uses the estate as a through route taking his children to St Peters school. This will be made worse by increased traffic from the proposed development site and the inevitable widening of Honey Pot Lane next to the site.

Highway improvements although funded by the developer will not improve this situation regardless of how achieved, roundabout or traffic lights introduced at the junction of London Road and Honeypot Lane. London Road is an extremely busy Principle Road and will always be given traffic priority, increased traffic using Honey Pot Lane will not readily exit onto London Road and as a result will divert down Hill Road. Hill Road is a privately owned road, non adopted and should not be used as a through route to the M25 and London Road. Indeed the access into Hill Road should be closed if you permit this development to take place.

Access to the proposed site will have to be made via Honey Pot lane and as such, the narrow road adjacent to the site will I assume be widened this will make the use of the route from Weald Road to London more attractive as it will be easier to access and will further create increased traffic nuisance in Honey Pot Lane and again resulting in Hill Road and the Homesteads being used as a rat run and short cut to avoid the junction of Honey Pot Lane and London Road.

An additional concern related to the wider road network relates to motorists using a route from Ongar Road, Sandpit Lane, Weald Road to London Road this will inevitably result in increased traffic movement North - South if widening of Honey Pot Lane is carried out and the junction of Honey pot Lane and London road redesigned. Any increase in traffic using Honey Pot Lane will have a significant impact on Hill Road a private development of individually designed houses. Hill Road and the Homesteads Estate should not be a through route or rat run for traffic at any time.

Other proposed development sites within the draft plan will also have traffic implications in regards to Honey Pot Lane.

Unfortunately I was not able to attend the council meeting where our local Petition was discussed and I understand the council agreed to include the petition as part of the consultation process. However having viewed the video of the meeting I was amazed to hear one of the councilors mention that the inclusion of sites in the draft plan had not been considered previously by councilors. The inclusion of sites within the plan it would seem is officer led. Unfortunately officers had previously recommended a back garden development for approval on the Homesteads Estate that was rejected unanimously by all planning committee members and also rejected at a subsequent appeal. Hopefully officers will listen to the significant objections of local residents and remove the site from the plan.

A new huge housing development on the scale proposed in Honey Pot Lane will totally destroy the character and environment of the area, create increased local highway problems and add to problems associated with the North - South route created to access London Road and the M25. This development and density will be double the size of the existing estates of the Homesteads and surrounding properties and will totally transform the whole area for the worse for the existing community.

I strongly object to the proposed site being used for Housing Development and would hope that officers and councilors will take note of residents objections and also the petition presented to the council some time ago. I also do not believe you have considered the full potential of land adjacent to the A12 from Shenfield heading East to the A12. This land if at all is better suited particularly as it is also fronted by a principal road and the associated public transport link.

Comment

Preferred Site Allocations 2018

Representation ID: 19126

Received: 27/02/2018

Respondent: Mrs s Powell

Representation:

I tried to reply on the consultation but the links do not appear to be working correctly. I assume this is to discourage feedback or objections.

Full text:

To whom it may concern.

Please note my consultation regarding the Brentwo0d Local Plan. I tried to reply on the consultation but the links do not appear to be working correctly. I assume this is to discourage feedback or objections.

I have grave concerns about the lack of infrastructure ie Doctors, Health facilities and Schools included in this plan.

There are way too many houses being built and I believe It will have to rely on services outside the borough to sustain it, therefore making it difficult for local residents to obtain services and pushing cost on to other local boroughs.

I was on the understanding that now the consortium of boroughs had been agreed in this area they were all going to work together to keep housing, growth and employment flowing. I feel this plan just promotes the housing giving nothing back to the community.

Comment

Preferred Site Allocations 2018

Representation ID: 19138

Received: 11/03/2018

Respondent: Mr Ian Atkinson

Representation:

I expect there will be less responses to this plan than previous ones. You should not conclude from this that this means there is less concern or opposition to it. People have simply become weary of being asked to repeatedly comment on similar proposals and also do not believe that their representations are listened to or taken into account.

Full text:

As requested I am providing feedback on the Brentwood Draft Local Plan, in terms of its impact on West Horndon village.

Like the vast majority of West Horndon residents, I would like West Horndon to remain the small village it is today. My wife and I moved here 22 years ago and it was a conscious decision to choose to live somewhere with a sense of community and with plenty of green space. We enjoy village life and it is a pleasant, safe place in which to raise our son.

I do however accept that some changes are necessary and have got reasonably comfortable with the residential development planned for the industrial estate. Although this would considerably increase the size of the village, it would also bring benefits, not least of which would be an end to the vast number of lorries thundering through the village, albeit many of these would be replaced by cars.

I disagree that this site is suitable for high density housing. The housing built on this site should be similar to and consistent with the existing housing in the village. There are also a lot of elderly people living in the village. Consideration should be given to building senior citizen housing. This would enable our senior citizens, when they reach the point when they cannot live entirely independently, to move to this accommodation. This would provide them with the support they need whilst enabling them to stay within their community. It would then free up their existing bungalows for new families.

I do not agree that the village has excellent transport links and was astonished to be told at a recent drop-in event that this was the main reason this area has been chosen for development. Yes we have a railway station and are close to the A127 and M25 but our trains and our roads are already extremely overcrowded and will not be able to cope with the extra amount of people. Your plan seems to ignore the equally important A12 and Crossrail opportunities. The impact on West Horndon also does not appear to have been taken into account regarding the plan to build Dunton Garden Village right next door to our village.

Whilst I appreciate that you need to come up with a viable plan to deliver the amount of housing required, I would urge you to consider the impact of any proposals you make on the lives of the people it will affect. The residents of West Horndon chose to live in a village, not a large town and our way of life should be respected as much as anyone else.

Finally, what I oppose most strongly in the plan is the proposal for us to have over 50% of the new gypsy and traveller sites. This is a step too far. We should not have to accept over 60% of the housing, over 80% of the employment land allocations and over 50% of the new gypsy and traveller sites. This is too much for one small village and these sites would not be compatible with our community and way of life. An alternative site should be found elsewhere in the Borough.

I expect there will be less responses to this plan than previous ones. You should not conclude from this that this means there is less concern or opposition to it. People have simply become weary of being asked to repeatedly comment on similar proposals and also do not believe that their representations are listened to or taken into account.

Object

Preferred Site Allocations 2018

Representation ID: 19152

Received: 06/04/2018

Respondent: Mr John Lester

Representation:

As I and neighbours have been ignored by the planning committee previously and our objections have proved to be correct, I have little faith in the consultation process. It appears to be a paper exercise and another 'that box is ticked'.

Full text:

In respect of the above plan I am writing my objections to it. It seems that only yesterday I took part in a 10 year plan consultation process that was supposed to be the way forward. What a waste of time and energy.

As I and neighbours have been ignored by the planning committee previously and our objections have proved to be correct, I have little faith in the consultation process. It appears to be a paper exercise and another 'that box is ticked'.

I object in general to the proposals that impact on the villages and parishes, as if built, they will become towns. My main objection is to the planned sites at 076 and 077 as well as 075B. The objections range from the infrastructure, to primary school, doctors surgery, extra traffic, congestion, parking, road safety, local facilities, air and noise pollution, vandalism and the loss of community spirit where residents look out for each other to the loss of green belt land. I exercise by using Red Rose Lane as part of a circuitous route as I and other residents run around the village, dog walk and walk. The impact of this number houses on this community will be detrimental to the current residents.

The only winners in this plan are the developers and residents will have to pickup the cost of sustaining the other houses after they have taken their profits and run.

I know this will not be read but hope it will add another 1 to the number of those who oppose the development plan.

Thank you

John Lester

Object

Preferred Site Allocations 2018

Representation ID: 19172

Received: 09/03/2018

Respondent: Mr Lawrence Allum

Representation:

The Council has neither responded to residents concerns nor those of the
Priests Lane Neighbourhood Residents Association and yet readily responded to
the land owner's comments requesting removal from the 2016 LDP of the
recommendation to keep part of the land open and available for community use.
This consultation process gives the impression of just following required planning
procedure without giving due consideration to official standards or residents'
concerns?

Full text:

Objection is made to the proposed allocation of site 044/178 - Priests Lane,
Brentwood, on the following grounds:
1. Last year Hogarth primary school not only had its car park but also its buildings
significantly extended onto its playing field. This serves to double the school's
pupil numbers at the expense of halving its playing field. The Priests Lane sites
are the only open land adjoining the two schools of Hogarth Primary and The
Endeavour. Developing these sites will involve the permanent loss of land last
used as playing fields and deny the schools the opportunity to not only replace
their lost playing field space but also to provide for future extension. Building on
these sites is contrary to the Government's priority on physical education to
address the obesity and mental health needs of our children and future
generations, thereby reducing the burden of cancer, diabetes, cardiovascular
disease and dementia in our community.
2. In addition to the need for local school playing fields, this site may offer
potential for meeting community playing field needs. The loss of this site would be
contrary to Sport England's playing fields policy and Government planning policy
on playing fields set out in paragraph 74 of the National Planning Policy
Framework.
3. Access for this development is suggested via Bishop Walk and yet, following
concern by the Highways Agency over 22 years ago during the planning
application, the number of houses in Bishop Walk was reduced from 8 to 5 on the
grounds of safety, even though traffic was less then. How can it now be justified,
with the increased traffic, to allow increase of not just three houses but ninety-five!
4. Traffic congestion in the area is already at an intolerable level and added to by
the doubling of pupils to Hogarth Primary School. This will be exacerbated with
the associated danger and pollution along the narrow Priests Lane with its single
narrow footpath limited to one side and being a main pedestrian conduit for school
children and families leading to Brentwood schools and town. This development
would add both vehicular and pedestrian traffic volume to this street network, way
beyond its design and capability. The vulnerability already experienced by cyclists
and pedestrians at busy periods will be compounded by the increased traffic risks.
Such planning is not only dangerous but would result in serious detriment to the
area and is irresponsible. Priests Lane is too narrow for public transport; the
distance to buses and stations is not likely to reduce reliance on cars.
5. Priests Lane is a major traffic flow capillary connecting Shenfield to Brentwood
and vice versa. As such it serves as a busy conduit to the A12, A127, A128 and
the M25. It is historically and actually a lane that is poorly served by alternating
narrow footpaths and does not meet many national highway criteria nor
acceptable health and safety standards. This highly unsatisfactory situation will
only be worsened by the likely increased traffic coming from the central Brentwood
developments and Officers Meadow. Priests Lane is not suited to serve any
increased traffic levels.
6. These sites only provide for the smallest proportion (1.15%) of homes in the
local plan and even then the high density of 95 dwellings on this site, as stated in
the plan, appears way out of keeping with the character of the area. This once
more will result in serious detriment to the area and should be accommodated
where it is more appropriate to locate such housing developments on edge of
town or out-of-town sites where provision can be made for adequate
infrastructure, pedestrian/cyclist routes and provide for new links to main trunk
roads, such as the A127 and A12. Not to add to already congested residential
areas, such as Priests Lane, where there is no space for these provisions.
7. The land concerned borders the busy main railway linking London to the Anglia
Region, to which the addition of the London Crossrail Scheme is imminent. Such
land should be allowed to provide a residential-free corridor for reasons of noise,
pollution and safety.
8. Access by emergency services would be further restricted by the added
congestion with concomitant effects on health, property and crime.
9. The dirt and atmospheric pollution associated with the construction of this
development would be intolerable within the confines of the area. This area
cannot absorb the construction traffic that will exceed the capability of the
neighbouring street network and will cause an unacceptable level of danger.
10. Our concerns demonstrate how the LP proposal for Priests Lane is not only
unfeasible but contravenes Government and the Council's own standards as well
as those of Sport England and disregards the needs of neighbouring schools.
Despite this the Council has neither responded to our concerns nor those of the
Priests Lane Neighbourhood Residents Association and yet readily responded to
the land owner's comments requesting removal from the 2016 LDP of the
recommendation to keep part of the land open and available for community use.
This consultation process gives the impression of just following required planning
procedure without giving due consideration to official standards or residents'
concerns? Will our justified concerns continue to be ignored this time round?

Object

Preferred Site Allocations 2018

Representation ID: 19232

Received: 03/03/2018

Respondent: Mr Mark Phillips

Representation:

The council has failed to give the development plan the careful consideration its duty bound to do. This council is used to getting its own way and it is clear it has become lazy in its approach.

Full text:

I am writing to object to the above proposed development being included in the Local Development Plan for the following reasons:

1. Honeypot lane already has an issue with dangerous speeding traffic. 20mph limit signs were erected a few years ago, but it has not been policed despite repeated requests. It is reasonable therefore, to assume that speeding will continue for the foreseeable future.
2. Much of developed part of Honeypot lane only has a pedestrian path on one side of the road because it is so narrow.
3. The lane narrows down still further before reaching the proposed development site.
4. Development of this proposed area has been turned down by the council before, as it did not meet the government's "Spacial Strategy" requirements. It is clear from the government's guidelines, this site still does not meet these requirements.
5. This development is proposed on green belt land. The government still stresses the importance of protecting green belt land. National planning guidelines state that only in exceptional circumstances can development take place on greenbelt land, and housing is not considered exceptional circumstances.
6. There are 2 significant developments planned, which are within ¼ mile of Honeypot Lane.
One is on the site of the Police station (70 units), and a large office block in Hubert Road which is being converted to flats. Both developments will have access to London Road. I'm pretty sure nobody in Planning has considered the extra traffic flow that these new developments will create in addition to any as a result of a development in Honeypot lane.
7. The proposed development is a mile from the town centre. There is no bus service in Honeypot Lane, and it wouldn't be practical (see points 1-3). Residents at the proposed development would have no alternative other than to use their cars. This does not meet the governments sustainability targets. If there are infrastructure solutions suggested, I for one no nothing about them.

In Summary, the council has failed to give the development plan the careful consideration it is duty bound to do. The proposed site is wholly unsuitable for development anyway. It has severe flooding issues, and has a stream running through it. This council is used to getting its own way and it is clear it has become lazy in its approach. I wholeheartedly object to the proposed Honeypot Lane development.

Comment

Preferred Site Allocations 2018

Representation ID: 19312

Received: 06/03/2018

Respondent: Mr Geoff Sanders

Representation:

Whilst there may have been a review of representations, there has been no formal, detailed response to representations made by PLNRA since March 2016.

Full text:

Page 3 Para. 5: While this document is primarily a consultation on sites, we have also updated our vision, strategic objectives and spatial strategy to reflect progress made on the technical evidence and review of representations. Comment/Objection: Whilst there may have been a review of representations, there has been no formal, detailed response to representations made by PLNRA since March 2016. Page 4 Para. 7: Evidence in its broadest sense means anything that informs the plan-making process, including the Sustainability Appraisal, Duty to Cooperate discussion, consultation responses, and technical evidence. Comment/Objection: There is no evidence in any section of the Draft Local Plan that PLNRA responses to the plan have been taken into account and that detailed sustainability and technical evidence submitted have been analysed and given appropriate consideration. Page 4 Para. 8: A Consultation Statement detailing previous representations has been published alongside this document. Comment/Objection: There are various references to previous historic consultation exercises undertaken, but an up-to-date document detailing the 2016 representations has not been found yet, other than reference to the numbers of responses made. Page 4/5 Para 9: Support for protecting the Green Belt and environmental assets, and building upon brownfield land only were strong themes in the consultation feedback. A number of stakeholders objected to the Dunton Hills Garden Village in principle and the extent of development along the A127 corridor. A wide range of comments were also raised on the need for additional plan evidence. Comment/Objection: Sites 044/178 are greenfield protected urban space sites. The Dunton Hills development is mentioned specifically, but the Priests Lane sites, which attracted a high proportion of objections, are not mentioned. Page 6 Para 14: In arriving at a list of preferred site allocations, we have developed a site assessment process. This is robust, balanced and wide-ranging in terms of technical evidence material for each allocated and discounted site. Comment/Objection: There is no evidence as to why sites 044/178 are preferred sites other than, presumably, they are available. The site assessment (Page 72) is shallow and weak. There is no evidence of robustness or balance. Page 6 Para 15: A key part of the evidence base is the Sustainability Appraisal (SA)...Its role is to promote sustainable development...The SA allows us to consider opportunities to improve environmental, social and economic conditions in the local area and identify how to mitigate the impact of development. Comment/Objection: To what extent is there a specific Sustainabilty Appraisal of sites 044/178? How will environmental, social and economic conditions be improved in Priests Lane and how will the impact of development be mitigated? There is no evidence provided as answers to these questions. Page 6 Para 17: Refers to a Habitats Regulations Assessment screening that has been undertaken for Local Plan sites. Comment/Objection: What does it say regarding sites 044/178? It is not mentioned in the preferred site statement. Page 7 Para 18a: delivering the right infrastructure at the right time: ensuring that infrastructure to support new housing and employment opportunities, such as schools, health and transport are delivered at an appropriate scale and in a timely manner. Comment/Objection: Mere verbiage with no detail, although statistics on schools and local surgeries do appear later. Page 7 Para 18c: supporting high quality design...helping to minimise the impact of new infrastructure on local character and enhancing areas through innovative design which positively responds to local heritage and environments. Comment/Objection: No evidence presented as to how this might be achieved. What is meant by 'innovative design' that would be in keeping with the Priests Lane environment? What design strategies are profit-making developers likely to adopt? Page 7 Para 18d: enhancing green infrastructure networks: improving the quality, range and connectiveness of the Borough's natural green assets. Comment/Objection: How will this will be helped by removing a protected greenfield site? Page 7 Para 19: refers to the Draft Infrastructure Plan that is being continually updated. Comment/Objection: What is this? Page 11 Inset: The Borough will continue to thrive with a high-quality network of green infrastructure, parks and new connected green corridors, providing cycling and walking opportunities for all.....Brentwood will grow sustainably with new development directed to urban brownfield opportunity sites, well planned urban extensions. Comment/Objection: Except for Priests Lane, presumably, since we are targeted to lose a green space and have a highway that is conducive neither to cycling nor walking, but a connecting 'rat-run between Shenfield and Brentwood traversed by high speed traffic. Page 12 Para 28 SO1: maximise sustainable growth opportunities within our built-up areas and on brownfield sites. Page 12 Para 28 SO2: direct development growth in locations well served by existing and proposed local services and facilities. Page 12 Para 28 SO5: manage development growth to that capable of being accommodated by existing or proposed infrastructure, services and facilities. Comment/Objection: What represents 'sustainable' growth? Why are sites 044/178 the only identified greenfield sites? What evidence is identified for sites 044/178 being well served by existing infrastructure, local services and facilities - a set of statistics about schools and surgeries does not equal appropriate services? What proposals are there to enhance services? Page 12 Para 28 SO6: Plan for housing...creating inclusive, balanced, sustainable communities. Comment/Objection: What precisely does this mean for Priests Lane, one of the highest value housing areas in the borough? Page 13 Para 28 SO16: Protect and enhance valuable landscapes and the natural and historic environments. Page 13 Para 28 SO17: Establish a rich connected network of Green infrastructure across the Borough and reaching beyond. Comment/Objection: Developing sites 044/178 is clearly contrary to both the above objectives. Page 13 Para 28 SO19: Secure the delivery of essential infrastructure, including education, health, recreation and community facilities to support new development growth throughout its delivery. Comment/Objection: There is no evidence to confirm that education and health facilities will be delivered, given that the expansion of Hogarth School is to meet current need, whilst there is no evidence to support any view that surgeries can and will meet any substantial increase in demand - statistics do not often equate to reality. Page 13 Para 28 SO20: support self-build housing in sustainable locations across the Borough. Comment/Objection: What precisely does this mean? Which locations? Safeguards against blight? Page 13 Para 28 SO21: Improve public transport infrastructure and ensure development sites are well connected to bus and/or rail connections Page 13 Para 28 SO22: Improve cycling and walking facilities across the Borough and establish a grid or network of green transport corridors. Comment/Objection: Priests Lane is too narrow for public transport; the distance to buses and stations is not likely to reduce reliance on cars. Priests Lane is poorly served by pavements, which are too narrow and situated on alternate sides of the road. Any improvements are likely to narrow the width of the road below national guidelines that the Lane hardly meets now and actually transgresses in some places. Cycling in Priests Lane is almost suicidal and is rarely in evidence!! Page 14 Para 31The spatial strategy continues to focus upon the sequential use of land which prioritises using brownfield first and then considers growth in settlements in terms of their relative sustainability linked to services and facilities. This approach is in line with government guidance and best practice. The release of Green Belt land should only be considered after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. Comment/Objection: Again we have to ask - why sites 044/178, given their denotation? There is no evidence presented about their sustainability and likely required links to services and facilities. Which sites have been discounted as alternatives to these 2 sites? Pages 18/19 Paras 41/42: However, importantly due to the worsening of the affordability ratio in Brentwood and the increased costs of rental levels, conclusions identify the need for a reasonable upwards market signal adjustment. Compared to most of Essex, the borough is much less affordable, homes are more expensive, and now less affordable than the last housing boom. The degree of market signal uplift is a matter of professional judgment and evidence indicates a 30% uplift above the new 280 dwellings per annum baseline, plus a small contingency of 6% should new official projections indicate a slightly different position to that forecasted. 42. In summary, using the minimum revised net dwelling baseline figure (280) plus combined market signal adjustment and contingency adjustment of 36%, this leaves an objectively assessed housing need of circa 380 dwellings per annum or 7,600 dwellings across the plan period (2013-33). The revised housing need from 362 per annum to 380 per annum across the plan period (20 years) equates to a total dwelling increase of 360 additional units.'. The updated SHMA is published as part of this consultation. Comment/Objection: I am not qualified to analyse the Housing Need statistics and hence assume them to be accurate. However, what are concerning are the admissions that housing and rental costs in Brentwood are high and less affordable, that projections suggest that perhaps only 280 dwellings are required per annum and that, therefore, a market signal uplift of 30% plus a contingency of 6% should be accepted, raising the annual build to 380. The statisticians amongst us will correct me, but am I to assume that the increased build per annum (which is substantial) is to do with increasing supply in the hope of reducing house/rental prices? This would actually be insane if the projected demand does not, and was never meant to, meet supply. Page 22 Para 55: The Council received a number of representations on the Draft Local Plan (2016) suggesting that there was a lack of information about the site assessment methodology and overall process. A summary of the site assessment process undertaken is detailed in Figure 7, with a detailed site assessment methodology technical note available alongside this consultation. This work is based upon best practice and is considered to provide a robust framework for site assessment and selection. NPPF Footnote: To be considered deliverable, sites should be available now, offer suitable location for development now,..be achievable... delivered within five years and in particular that development of the site is viable; to be considered developable, sites should be in a suitable location for housing development. Site options will be assessed in terms of their impact on a number of primary factors, including flood risk, Green Belt, landscape and highways....impact on historic assets, ecological designations, utilities, education and health facilities. All sites that have passed stages1 and 2 (site selection) will be appraised using objective (WHERE POSSIBLE) site selection criteria. This stage will identify any significant negative effects THAT MAY REQUIRE MITIGATION (my capitals) if a site is subsequently put forward for allocation. This study will identify whether proposed areas/sites/types of sites are viable and deliverable in the plan period. If evidence cannot give this confidence then it may be necessary to revise draft local plan policies and/or go back a stage and find alternative sites. This approach attempts to maximise brownfield redevelopment opportunities and support growth within sustainable locations. Comment/Objection: We need to review the technical note, given that the assessment of sites 044/178 is so weak. Note there is no comment in this revised plan Site Assessment of 044/178 referring to flood risk, landscape, highways, ecology, utilities, whilst the statistical references to Hogarth School and surgeries are questionable. Furthermore, if the process is so robust, why should site selection criteria not be objective? Why should a site that does not meet suitable selection criteria receive mitigation? With regard to Page 22 Para 55 we could conclude that there is a change of attitude here compared to that we have encountered in meetings with Louise McKinley and other councillors/representatives. Previously we have been told the entire Plan would be rejected by inspectors/government if sites 044/178 were not included as available sites. Para 55 implies this may no longer be the case and that sites that fail to meet development criteria could be discounted. Alternatively, we could interpret Para 55 as meaning that if sites 044/178 failed to meet the criteria, alternative reasons will be found to force development of the sites!! Page 25 Para 59: Brownfield Land within Brentwood Urban Area/Settlement Boundary 1,152 net homes / 13.94% of total build. Greenfield Land within Brentwood Urban Area/Settlement Boundary 95 net homes / 1.15% of total build Overall total build 8263 (100%) - Allocation total 6154 (74.48% of overall total). Comment/Objection: Whilst the net homes allocation at Priests Lane appears small taken as a total of planned building across Brentwood, the actual percentage of net build (Brentwood Urban Area Greenfield) at sites 044/178 compared to Brentwood Urban Area (Brownfield) net build is 8.25% which is a much higher percentage of net build in the Urban Area net build category, bearing in mind that the Priests Lane sites are the only identified greenfield sites in the entire plan/Borough. Furthermore, whilst comment on the planned 36% uplift on required housing has been made earlier, it is now clear this represents an net uplift of 2109 dwellings over the life of the plan, much of which would be expected to be built within 5 years of granted planning permission. These 2109 dwellings would then be built in the hope of driving down house/rental prices. Consequently, Priests Lane would be paying a rather high environmental price for the sake of an economic demand/supply house price lottery. Page 29 Para 64d: Work is progressing on....providing further design, layout and land use direction for the sites at Priests Lane and Honeypot Lane Comment/Objection: There is no detail provided about this and hence its meaning is unknown. Page 37 Para 77: For the year 2016/17, the net capacity of non-independent primary schools in the Borough was 6,032 pupils across 24 schools[11]. In the immediate future (2017/18) the net capacity of non-independent primary schools will increase to 6,222 pupils mainly driven by expanding Hogarth Primary School to a two-form entry (2FE) with 420 pupil capacity. Comment/Objection: The plan admits that the expansion of Hogarth Primary School will deal with predicted increased enrolments in 2017-18. It will then have a surplus capacity of 61 places by 2021-22. However, the Development Plan predicts a shortfall of places at Long Ridings Primary School of 217 places and Larchwood Primary School of 55 places - a total shortfall of 272 places. Since there is no mention of any further expansion at these 2 schools and given their relative proximity to Hogarth Primary School, it could be suggested that some of the need for places will be met by Hogarth. In this scenario further vehicle movements can be predicted in Priests Lane, increasing the danger to children that already exists. We should also recognize the notorious difficulty in predicting school place demand year-on-year (especially in areas of new housing - 95 homes could generate 30 children or 150, the number is unpredictable), the sudden inability of schools to meet demand and the unexpected frailty of schools where demand falls away. Page 45 Para 96: The Council will be looking to support the further development of the Endeavour School to provide facilities for sixth form students. This education requirement will need to be built into the detailed layout and masterplanning for the proposed housing site at land at Priests Lane (044/178). Comment/Objection: No detail is provided. What is clear is that expansion of Endeavour School, which is to be welcomed, is at odds with a sizeable housing development that will aggravate the health and safety obligations to already vulnerable children. Page 48 Paras 103 (stats) and 104: Current infrastructure services improvements alone are unlikely to address the significant patient pressures that may occur through housing growth in the Borough during the lifetime of the plan. Comment/Objection: If we only count forecast new patients at the nearest surgeries to Sites 044/178 - Rockleigh Court, Mount Avenue, The New Surgery and Tile House, they number 1023+1025+779+782 = 3609 respectively ( or a 34.46% increase). The average UK occupancy of each dwelling is 3.7; 95 houses could generate an additional population of 352 residents requiring medical services, i.e. 9.75% of the additional forecast new patients. It is well known that obtaining appointments at these surgeries is currently difficult or involves lengthy wait times, so the problems experienced by Priests Lane residents will only be exacerbated, a fact further aggravated by the local age profile. Page 50 Para 107: Brentwood is an attractive business location with a high quality environment .... and good transport links. Comment/Objection: Many local businesses have struggled to survive in a high rent and rates environment. Vacant sites at the Baytree Centre bear this out, along with the proliferation of food outlets in Brentwood and Shenfield High Streets. Brentwood High Street is mainly beset by fast food chains, hairdressers and charity shops - the recipe for High Street decline. As for travel to London, the current cost of a train season ticket from Shenfield is £3000. If the commuter wishes to go on from Liverpool Street to central London, the cost rises to £4000 and car parking is an extra £1000. Who exactly will be able to afford to live in Brentwood, commute to London and pay a mortgage for an affordable house in the borough, which is currently calculated at £440,000? Page 52 Para 110: The updated economic evidence...considers a number of evaluation factors including travel to work areas, commuting flows...and strategic transport routes. Comment/Objection: Priests Lane is a major traffic flow capillary connecting Shenfield to Brentwood and vice versa. As such it serves as a busy conduit to the A12, A127/A128 and the M25. It is historically and actually a lane that is poorly served by alternating narrow pavements and does not meet many national highway criteria nor acceptable health and safety standards. This highly unsatisfactory situation will only be worsened by the likely increased traffic coming from the central Brentwood developments and Officers Meadow (the need for which is understood). Priests Lane is not suited to serve increased traffic levels. (Included site plan for sites 178 and 044). Comment/Objection: The problems with access onto Priests Lane are not mentioned. The reference to secondary access via Bishop Walk is not supportable, given the nature/width of the road is only sufficient for the few houses it serves. The references to contextual analysis, informing typologies, scale, materiality and landscaping are not explained and are, hence, meaningless. There is a brief reference to traffic problems (but these are viewed cursorily as 'localised' - surely all traffic could be defined as localised!!) . All other myriad objections to sites 044/178, often highly technical and evidenced, relating to the LDP issued in January 2016 have been ignored, as they have been for the whole of the intervening period to date. The only mantra we have received is that the land 'must' be developed for the sake of the Plan - which has now been disproved. The current designation of the sites as Protected Urban Open Space is acknowledged.

Comment

Preferred Site Allocations 2018

Representation ID: 19329

Received: 27/02/2018

Respondent: Mr & Mrs John and Marian Long

Number of people: 2

Representation:

There are spelling mistakes in the Plan: "accomodation", "equaled", "endeavoring". This may seem a minor point compared with our comments above, but it is indicative of the lack of care and attention to detail of the Plan overall.

Full text:

We have lived in Brentwood since 1965 and moved to our present address in June, 1968. We consider that if the draft plan is put into effect it will ruin Brentwood.

Shortly after we moved to Nags Head Lane, an application was submitted to build 38 houses / bungalows between the existing houses and the railway line, as "in-fill". Quite rightly, Planning rejected the application, largely on the grounds that the site was in Green Belt. Now the Council itself is proposing that 1,827 dwellings should be constructed in Green Belt. Such a cavalier suggestion reveals not only an appalling lack of concern for the importance of the Green Belt, but also would also provide a very dangerous precedent for future possible proposals.

Of the proposed 1,827 dwellings, 125 are in Nags Head Lane: an increase of more than 200%. The proposed site access is close to the dangerous double bend under the railway bridge. Normal traffic is now at times heavy; when there are problems on the motorway or at the M25 roundabout (not uncommon) the Lane quickly becomes heavily congested. The proposal is a recipe for chaos. Yet "Site Constraints" for this site does not mention traffic flow, nor does it consider Green Belt a constraint.

Both this site and the one in Honeypot Lane are in the parish of St Peter South Weald and thus the local school is in South Weald village. This is an outstanding school that is already very over-subscribed and has been refused permission to expand. If the Draft Plan goes ahead, not only will more and more parents be disappointed, but children will face problems reaching schools to which they have been allocated elsewhere in increasingly congested Brentwood.

A considerable increase in the amount of traffic in the town centre is inevitable, but under this plan most of the surface car parks would be built upon. How is it possible to reconcile the removal of so much car parking with the encouragement of more cars? The only acknowledgement of this problem is the glib statement: "...sufficient levels of car parking will need to be provided." This begs a vital question - sufficient for what? Certainly not sufficient to make up for the amount of parking space that will be destroyed.

Provision of health care is dealt with in an equally sketchy manner. We will give three quotations on this extremely important subject. "...it is not always an easy task to analyse the impact of new housing on the current healthcare infrastructure and indeed plan for new infrastructure." (page 46); "The proposed range of housing growth is likely to further intensify the number of patients per GP." (p. 47); "...a number of practices may be under pressure in terms of patient numbers and potential healthcare issues.)" (p. 47). At least there is a realisation of a problem here. But on such a vital matter a delay in addressing these issues is not acceptable; it certainly does not fill the residents of Brentwood with optimism! There is no indication that anything constructive has been done.

In addition to lack of protection for the Green Belt, there is other evidence of little concern for the environment. Three of the sites are in or next to Conservation Areas: 041, 040 and 039. There are even more bordering on Local Wildlife Sites: 034, 081, 117A, 117B, 194 and 263.

Regarding other aspects of the proposed sites: there are three with water courses crossing them, and no fewer than nine that the Plan admits are subject to flooding.

We would be ashamed to submit to the public a formal document containing spelling mistakes: "accomodation", "equaled", "endeavoring". This may seem a minor point compared with our comments above, but it is indicative of the lack of care and attention to detail of the Plan overall.

Object

Preferred Site Allocations 2018

Representation ID: 19494

Received: 12/03/2018

Respondent: Ms Linda Hurlock

Representation:

Concerned about the lack of publicity and communication on the part of the Council regarding these plans.

Full text:

As this appears to be the best kept secret in Brentwood and was only brought to my attention yesterday evening, I have not had time to read the 104 page document. I would like to say, however, how concerned I am about a lack of publicity and communication on the part of the council regarding these plans. We are seeing a steady erosion of green spaces in Brentwood which is resembling an urban sprawl in the manner of Romford and Harold wood. Whilst we all understand the need for housing, there appears to be a complete lack of consultation with residents.

Object

Preferred Site Allocations 2018

Representation ID: 19559

Received: 12/03/2018

Respondent: Ms Linda Cearns

Representation:

It appears that the understandable wish to avoid government intervention in the LDP has led to a seemingly sudden review of Greenbelt land and the requisitioning of sites not formerly considered suitable for development.

Full text:

The sites specified are in the Parish of Blackmore, Hook End and Wyatts Green and are all in long-established Green Belt zones. These latest proposals are contrary to the intention of Greenbelt legislation to permanently provide and protect open space and do not appear to meet the requirements of exceptional need.

Even if it will be necessary to withdraw some Green Belt designation to meet the Borough's housing requirements, the proposed building of 116 dwellings in this parish is disproportionately high in comparison with the majority of other comparable rural parishes/villages in the Borough. (It is also concerning to note in supporting documents to the LDP that other large areas of Green Belt in the parish have been identified as alternative building sites.)

In Blackmore alone, the proposed building of 96 dwellings represents a 28.6% increase in the number of homes in the village. It should be noted that building developments planned by Epping Forest District Council in locations just outside the village boundaries e.g., at the Norton Heath Equestrian Centre, will also have a considerable impact on the parish and its infrastructure and should be taken into account.

There is very real concern regarding the provision of essential utilities, transport, schools and medical facilities to cope with this additional housing. In particular, the road infrastructure in and around the parish, which already suffers from dangerously wide heavy goods vehicles travelling on its narrow roads, is likely to be inadequate to cope with the increased levels of traffic.

It appears that the understandable wish to avoid government intervention in the LDP has led to a seemingly sudden review of Greenbelt land and the requisitioning of sites not formerly considered suitable for development. For the reasons stated above, I object to the proposals relating to the Site Allocations in this parish and trust they will be reconsidered.

Comment

Preferred Site Allocations 2018

Representation ID: 19587

Received: 11/03/2018

Respondent: Lisa Atkinson

Representation:

I expect there will be less responses to this plan than previous ones. You should not conclude from this that this means there is less concern or opposition to it. People have simply become weary of being asked to repeatedly comment on similar proposals and also do not believe that their representations are listened to or taken into account.

Full text:

Dear Sir/Madam

As requested I am providing feedback on the Brentwood Draft Local Plan, in terms of its impact on West Horndon village.

Like the vast majority of West Horndon residents, I would like West Horndon to remain the small village it is today. My husband and I moved here 22 years ago and it was a conscious decision to choose to live somewhere with a sense of community and with plenty of green space. We enjoy village life and it is a pleasant, safe place in which to raise our son.

I do however accept that some changes are necessary and have got reasonably comfortable with the residential development planned for the industrial estate. Although this would considerably increase the size of the village, it would also bring benefits, not least of which would be an end to the vast number of lorries thundering through the village, albeit many of these would be replaced by cars.

I disagree that this site is suitable for high density housing. The housing built on this site should be similar to and consistent with the existing housing in the village. There are also a lot of elderly people living in the village. Consideration should be given to building senior citizen housing. This would enable our senior citizens, when they reach the point when they cannot live entirely independently, to move to this accommodation. This would provide them with the support they need whilst enabling them to stay within their community. It would then free up their existing bungalows for new families.

I do not agree that the village has excellent transport links and was astonished to be told at a recent drop-in event that this was the main reason this area has been chosen for development. Yes we have a railway station and are close to the A127 and M25 but our trains and our roads are already extremely overcrowded and will not be able to cope with the extra amount of people. Your plan seems to ignore the equally important A12 and Crossrail opportunities. The impact on West Horndon also does not appear to have been taken into account regarding the plan to build Dunton Garden Village right next door to our village.

Whilst I appreciate that you need to come up with a viable plan to deliver the amount of housing required, I would urge you to consider the impact of any proposals you make on the lives of the people it will affect. The residents of West Horndon chose to live in a village, not a large town and our way of life should be respected as much as anyone else.

Finally, what I oppose most strongly in the plan is the proposal for us to have over 50% of the new gypsy and traveller sites. This is a step too far. We should not have to accept over 60% of the housing, over 80% of the employment land allocations and over 50% of the new gypsy and traveller sites. This is too much for one small village and these sites would not be compatible with our community and way of life. An alternative site should be found elsewhere in the Borough.

I expect there will be less responses to this plan than previous ones. You should not conclude from this that this means there is less concern or opposition to it. People have simply become weary of being asked to repeatedly comment on similar proposals and also do not believe that their representations are listened to or taken into account.

Kind regards.

Object

Preferred Site Allocations 2018

Representation ID: 19598

Received: 10/03/2018

Respondent: Mr George Tuck

Representation:

The Conservatives who are in charge of the Development Plan need to clearly address this to the public in a debate.
Furthermore, be open to any concerns and change the plan accordingly around the ideas and input from Brentwood residents. Please Brentwood Council hear our ideas as we are not all in a wealthy position like many Conservatives and their supporters. We need diversity in our housing system again and how we put forward plans that involve us the residents.

Full text:

I am writing to you in regard of the Local Development Plan and how I myself and others feel it will affect not only the future of Brentwood but also the residents itself. Brentwood has understandably grown to become a commuter town over the last hundred years and positively affected the community in many ways.

However there are many points that need to be considered carefully and delicately. Firstly I would like to address the number of homes that are being built across Brentwood. Many of them, if not all are profit based houses that will cause a great deal of alienation with a vast majority of the towns working and middle class polulation.

It is essential that the Conservative party take a good look at their history over the last 30-40 years in regards to the number of Council homes sold off with the Right to buy with ex Council tenants. Additionally, none of these homes were ever replaced.

Furthermore with the creeping coalition of Brentwood and Basildon Council it raises a slight concern that many of those who are of the younger working class will be moved out of the town and into Basildon should they require a Council home. This may come across as a form of Social dense move by the Conservatives.

Furthermore with less and less Council homes being replaced by unaffordable homes, much of the lower paid are being pushed out and/or into a stranded position financially. These unaffordable homes made the town unaffordable for the working and middle class, matching it for those with a higher salary.

Ultimately developing these profits and homes on Green Belt land is a prohibited and defiant move. The countryside is a huge attraction of why many residents stay in Brentwood as well as attracting new residents.

The Conservatives who are in charge of the Development Plan need to clearly address this to the public in a debate.

Furthermore, be open to any concerns and change the plan accordingly around the ideas and input from Brentwood residents. Please Brentwood Council hear our ideas as we are not all in a wealthy position like many Conservatives and their supporters. We need diversity in our housing system again and how we put forward plans that involve us the residents.

I look forward to hearing from you.

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 19644

Received: 12/03/2018

Respondent: JTS Partnership LLP

Representation:

Whilst there is an imperative on the Council to progress, and adopt, a new Local Plan as quickly as is practicably possible - and the publication of the Preferred Site Allocations document is, therefore, welcomed - a general concern has to be raised that, in its attempt to progress matters as quickly as possible, much of the evidence base, upon which the spatial strategy and individual site allocations are based, are still a 'work in progress' and have yet to be made public, in anything but a draft summary form. The absence of key 'evidence base' difficult to comment.

Full text:

INTRODUCTION: Paras 1 To 9. Object In November 2017, the Department for Communities and Local Government wrote to the Council expressing its concern about the lack of progress being made towards the adoption of a 2004 Act Local Plan, and putting it on notice that the Borough was on a short list of councils where Government intervention, in the local plan, process was being considered. Whilst there is an imperative on the Council to progress, and adopt, a new Local Plan as quickly as is practicably possible - and the publication of the Preferred Site Allocations document is, therefore, welcomed - a general concern has to be raised that, in its attempt to progress matters as quickly as possible, much of the evidence base, upon which the spatial strategy and individual site allocations are based, are still a 'work in progress' and have yet to be made public, in anything but a draft summary form. In this respect, it is particularly noted that: The Housing and Economic Land Availability Assessment (HELAA) has yet to be published. The Site Assessment Methodology and Summary of Outcomes (SAMSO) January 2018 document remains a 'working draft', with only a brief summary, as to the reasons why potential sites have been rejected, having been published (there is no detailed breakdown or analysis available setting out how sites have been scored / ranked in accordance with the assessment criteria). The Green Belt study, which should underpin and inform all potential Green Belt releases, has not yet been completed, with 'working drafts' only currently being available in respect of Part 1 and 2 assessments. The important Part 3 and 4 assessments (individual sites and review of Green Belt boundaries) do not appear to have been commenced. In the absence of key 'evidence base' documents, it is difficult to comment on the merits, or otherwise, of any of the proposed site allocations. It is also difficult to make a comparison between the respective merits of sites rejected by the Council and those put forward in the Preferred Site Allocations document. This is a fundamental weakness in the Council's approach and the publication of the Preferred Site Allocations document is premature until more progress has been made in respect of the underlying evidence base. As a result, a general objection has to be made to the timing, and content, of the Preferred Site Allocations document and, in particular, to all proposed Green Belt releases. Whilst it is undoubtedly the case that significant Green Belt land will need to be released, in order to meet the development needs of the Borough up to 2033, the Council is not yet in a position to make a meaningful comparative assessment of the merits, or otherwise, of potential Green Belt sites.PART 1: VISION - Paras 26 and 27. Object Whilst the Council's vision for the Borough is generally supported, the evidence base (for the reasons identified above) does not yet support the conclusion that the Dunton Hills Garden Village is the most sustainable way of meeting the development needs of the Borough up to 2033 (and beyond). It is particularly noted that the 'Garden Village' strategy scores poorly in respect of a General Support The Council's decision to revise housing need, from 362 dwellings per annum to 380 dwellings per annum, is consistent with the latest population data and best practice guidance and is generally welcomed. This section of the document does not, however, explain how the Borough Council has, either explicitly or implicitly, taken into account the requirements of Paragraph 47 of the NPPF (e.g. the 5% and 20% buffers). Whilst Paragraph 43 notes the DCLG's recent consultation on producing a standardised methodology for calculating local housing need (a matter which is also set out in the recent consultation on proposed changes to the NPPF), which could increase Brentwood's need to 455 dwellings per annum, or by 1,480 units over the Plan Period, the proposed way of dealing with this (bringing forward the development of Dunton Hills Garden Village earlier in the local plan period, is not considered adequate. The Borough Council either needs to commit to allocating additional sites (in this emerging Local Plan) or to undertaking an early review (immediately after the Plan has been adopted). PART 1: HOUSING SUPPLY - Paras 51 to 56 and Figure 7. General Comment Paragraph 55 notes that the Council received a number of representations, in relation to the 2016 Draft Local Plan, to the effect that there was a lack of information about the site assessment methodology and overall SHLAA / HELAA. As identified above, this situation has not changed, such that it is not possible, on the basis of the information published on the Council's website, to make a meaningful assessment of the merits of the proposed site allocations or the sites which have been rejected by the Council. PART 1: SUMMARY OF PROPOSED HOUSING LED ALLOCATIONS - Paragraphs 57 to 68 and Figure 8. Object Again, the main criticism of this part of the Preferred Site Allocations document, relates to the lack of information, in the evidence base, to support the various figures, and assumptions, set out therein. In particular, there is little information to back up the figures for 'completions', 'extant permissions', 'forecasts forward' and 'windfalls' as set out in Figure 8 - Housing Growth. PART 1: SETTLEMENT HIERARCHY AND ACCOMMODATING GROWTH - Paragraph 75 and Figure 14. Support The proposed settlement hierarchy and, in particular, the classification of Doddinghurst and Kelvedon Hatch as Large Villages / Village Service Centres is supported. For the reasons set out above, however, the position regarding Dunton Hills and West Thorndon has to be reserved although, it is accepted, that if these sites do come forward, as strategic allocations, then they should be Village Service Centres. PART 1: INFRASTRUCTURE PLANNING - Para 76. Support The need to plan for the level of infrastructure, needed to support housing and economic growth, is fully supported. PART 2: HOUSING SITES Object The Council's 'sequential approach' to the identification of housing sites is, for the reasons set out above, generally supported, as is the identification of those sites, as set out in Figure 9: Proposed Housing-Led Allocations, which fall within the following categories:- 1. 'Brownfield' land. 2. 'Greenfield' land within the Brentwood Urban Area and other Settlement Boundaries. However, and because of the paucity of the evidence base, and the fact that work on the HELAA and Green Belt Study (Parts 3 and 4) is still ongoing, it is difficult to make an assessment as to the merits of the proposed Green Belt releases and / or the comparative merits of the sites which the Borough Council has discounted. Whilst the 'sequential approach' to the release of Green Belt sites is supported, a holding objection has to be made to those allocations falling within the following categories: 3. Sites on the edge of the Main Settlements. 4. Sites on the edge of Village Service Centres and Larger Villages. 5. Strategic Allocations. Indeed, and until the evidence base has progressed further, and, in particular, until the drafts of Parts 3 and 4 of the Green Belt study are available, the Borough Council cannot be certain that a strategic Green Belt release is needed, or, if it is, how much development it needs to deliver within the local plan period. Accordingly, and at this stage, a holding objection has to be made in respect of all potential Green Belt releases. PART 2: HOUSING SITES - FAILURE TO INDENTIFY LAND AT ASHWELLS LODGE, BLACKMORE ROAD, DODDINHURST AS A HOUSING ALLOCATION. Object An objection is raised to Part 2 of the Preferred Site Allocations document, as it fails to identify Land at Ashwells Lodge, Blackmore Road, Doddinghurst (Site Ref: 188) as a potential housing allocation. Appendix 6, of the Site Selection Methodology and Summary of Outcomes: Working Draft (SSMSO:WD) document indicates that the site has been discounted because of its potential 'Green Belt impact'. The SSMSO:WD does not, however, quantify, for any site (whether a draft allocation or discounted site) potential impacts and it is, therefore, impossible to draw any conclusions as to the merits of any particular site and / or whether the Council's decision is 'sound'. Ashwells Lodge lies adjacent to the northeast boundary of Doddinghurst (see attached plan) and fronts Blackmore Road (opposite Dill Tree Farm and Dill Tree Health Centre). It comprises the main house, with outbuildings to the rear, and two small paddocks. It extends to some 1,85 ha and there are substantial tree and hedge lines to all boundaries. The settlement of Doddinghurst lies to the east, Dill Tree Farm and Dill Tree Health Centre lie to the north. A farm complex lies to the west, across a small field, with a copse bounding to the southwest. The site is visually contained by existing development and landscaping. The attached plan shows how the site could be developed to provide in the region of 32 residential units, at a density of 17.2 dwellings per hectare. Access would be taken via Blac The site does not occupy an isolated position in the Green Belt. Indeed, it fronts one of the main thoroughfares - Blackmore Road - in this part of the Borough, with there being bus stops, served by frequent services, some 50m to the east. This is a sustainable, accessible, site. Stage 3 - Sustainability Appraisal Appendix 3 of the Draft Local Plan Interim Sustainability Appraisal - January 2018 scores potential sites against a criteria based methodology in relation to 17 categories which are:- 1. AQMA. 2. SSSI. 3. Nature Reserve. 4. Ancient Woodland. 5. Local Wildlife Site. 6. Woodland. 7. GP Surgery. 8. Primary School. 9. Secondary School. 10. Conservation Area. 11. Scheduled Ancient Monument. 12. Registered Park or Garden of Historic Interest. 13. Listed Building. 14. Flood Zones 2 and 3. 15. Special Landscape Area. 16. Green Belt. 17. Agricultural Land. The sites are then put into 5 categories:- Dark Green - site performs particularly well. Light Green - site performs well. No shading - no issue in terms of the relevant criterion. Amber - site performs poorly. Red - site performs particularly poorly. As to be expected, every site (of the 300+ that were considered) performed poorly, or particularly poorly, in respect of one or more categories. The subject site is rated as having no impact upon a particular issue, or as performing well in 9 of the 17 categories (i.e. over 50%). It performs poorly in relation to 7 categories (SSSI, Ancient Woodland, Local Wildlife Site, Primary School, Listed Building, Green Belt and Agricultural Land) and only 'particularly poorly' in respect of 1 category (access to a Secondary School). The site performs as well as many other sites, including a number which have been identified in the Preferred Site Allocations document for Development. The Appraisal, as set out in the Draft Sustainability Appraisal, indicates that the site should move forward for detailed Stage 4 assessment. Stage 4 - Detailed Assessment The main criteria used in this stage of the assessment are described at paragraph 3.22 of the SSMSO:WD document. In this respect:- Flood Risk. The site lies within Flood Zone 1 and is not at risk of flooding. Green Belt. The site currently lies within the Green Belt and, therefore, it's development will lead to a loss of openness. However, the site is visually contained by existing development and landscape features and, therefore, the impact on the Green Belt outside of the site, itself, will be limited and can be mitigated through boundary landscaping. The Green Belt Study Working Draft (GBSWD) document includes the subject site within Parcel 41A. It assesses the contribution that each Parcel makes to the first four purposes of Green Belt which are:- 1. To check the unrestricted sprawl of large built up areas; 2. To prevent neighbouring towns merging into one another; 3. To assist in safeguarding the countryside from encroachment; and 4. To preserve the setting and special character of historic towns. In order to assess the contribution that each Parcel makes to Purpose 1, the GBSWD considers the 'containment' of the Parcel in terms of how well the land, or the features within it, contain existing settled areas and prevented urban sprawl. The Parcels are then put into three categories - 'Well-Contained', 'PartlyContained' and 'Not Contained' - with Parcel 41A falling within the middle, 'Partly-Contained', category. In terms of Purpose 2, the Parcels are put into four categories - 'Critical Countryside Gap', 'Import Countryside Gap', 'Minor Countryside Gap' and 'Non Critical Countryside Gap'. Parcel 41A falls in the highest category - 'Critical Country Gap'. Two categories were used in respect of Purpose 3 - these being 'Mixed Functions within Countryside' and 'Functional Countryside'. All Green Belt land to the north of A12, in the Borough, is defined as falling into the latter category. Finally, and in respect of Purpose 4, three categories were used - 'Limited Relationship with Historic Town', 'Moderate Relationship with Historic Town' and 'Strong Relationship with Historic Town'. Parcel 41A has a 'Limited Relationship with Historic Town'. Overall, Parcel 41A is deemed to make a moderate / high contribution to the first four Purposes of the Green Belt. This ranking is primarily due to the fact that the Parcel includes all that land between Doddinghurst and Kelvedon Hatch and thus helps to separate the two settlements (Purpose No. 2). The Green Belt Study Working Draft is, due to its very nature, a high level analysis dealing with large parcels of land and cannot take full account of the fact that, within each parcel, the contribution made by individual sites will vary. The main Purpose which the subject site serves is to restrict the extension of Doddinghurst to the east (Purpose 1). Whilst Parcel 41A (of which it forms a part) does maintain the gap between Doddinghurst and Kelvedon Hatch (Purpose 2), the loss of the subject site to the Green Belt, would not significantly harm that function. This is because the site forms a natural extension to Doddinghurst and is well-contained. Boundaries of the Green Belt in this location are ill-defined on the ground and there is large farmstead to the west. The site is well-contained, its development would create a logical, and defensible, boundary and its loss would not cause any significant diminution of the gap between the two settlements. Landscape: The site is not subject to any landscape designation and, being visually self-contained, it would not have a significant impact upon the character of the open countryside or surrounding area. Highways: The site lies in an accessible location on a major transport artery and bus route through this part of the Borough. Visibility, in both directions, from the access is good. There are pavement links (going east) into Doddinghurst and the speed limit, on this part of the road, is 30mph. Historic Assets: Dill Tree Farm, which lies opposite the site, is a listed building. The site could, however, be developed in a manner which causes no material harm to its setting. The are no registered parks or conservation areas in the vicinity. Ecology Designations: Church Wood, which lies adjacent to the southwest corner of the site, is designated as a County Wildlife Site. The nearest SSSI lies to the north of Kelvedon Hatch (The Coppice). Utilities: There are no known utility constraints in the Doddinghurst area. Education: The subject site has good access to Doddinghurst Church of England Junior School, with Secondary Schools being located in the main urban areas of Brentwood and Shenfield. Health Facilities: The site lies opposite the modern Dill Tree Health Centre. A detailed Site Assessment demonstrates that the site is suitable, available and deliverable for housing and should be allocated in the forthcoming Submission Draft Local Plan. See attached

Object

Preferred Site Allocations 2018

Representation ID: 19699

Received: 08/03/2018

Respondent: West Horndon Parish Council

Representation:

WHPC also notes that once again responses to previous consultations have not been acted on; in particular 84% of people who responded to the consultation in 2015 opposing Dunton Garden Village.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19730

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation:

The Draft Plan Preferred Site Allocations does not provide any information on detailed planning policies, which are in the process of being reviewed and updated in the light of consultation representations made to the emerging Local Plan to date. This raises the question of how preferred land allocations have been identified when the guiding detailed planning policies have not yet been finalised.

Full text:

Object to
* Draft local plan preferred site allocations
* Sustainability appriasal
* Evidence base

see attached representations and appendices

Object

Preferred Site Allocations 2018

Representation ID: 19882

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

The LPA's reply set out four main reasons to explain why it has taken so long to produce a
Local Plan:
Brentwood's Green Belt location
Historic completion rates
Revisions of the OAHN
Dunton Hills Garden Village proposal
The LPA's full response mentions the need for public consultation on a Green Belt Assessment following recent legal advice. There was nothing to stop the LPA from carrying out such an assessment when the local plan process started. Given Borough's location entirely within the Metropolitan Green Belt, it is surprising that this was not one of the very first evidence collecting operations.

Full text:

See attached.