We note within the Open Space, Sport and Leisure Needs Assessment (one of the evidence base documents) that there is a recommendation that the Council works with such stakeholders as Essex Bridleways Association to look at opportunities to connect Brentwood District's fragmented network. This we welcome and look forward to discussions with the Council at an appropriate stage in the planning of the new allocations.

Whilst I agree housing is needed in Brentwood it is important each development has social housing. Most youngsters cannot afford 'affordable housing'
And houses for sale should be first for local residents

Why does the evidence base omit references to demographics? The plan must be predicated on population forecasts such as age. It would have been helpful to see these forecasts and how they relate to the number and type of dwellings. Just having a number of dwellings gives no feel for the number and location of say 2 bed flats or 3 bed semis. It is therefore difficult, if not impossible, as a member of the public, to evaluate the environmental, economic and social impact of the plan.

I understand the need for this

ECC advises that the Sustainable Modes of Travel Strategy (SMOTS) produced by ECC should be included within the evidence base. This strategy outlines the steps the authority are taking to enable accessibility to places of employment and education for all, including other neighbourhood services such as retail and leisure; with the associated health, social and economic benefits to them and their communities. The adoption of this Strategy provides the framework for the Council and its partners to co-ordinate the provision of services and infrastructure to achieve its objectives.

ECC recommends that the Essex Design Guide 2018 is referenced within the Draft Plan, and consideration given to embedding its principles into any design policies and supporting text, as the Draft Plan progresses to its pre-submission stage.

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.

Section 12 - Dunton Hills Garden Village (DHGV) "evidence base is increasing including masterplan work" and
Section 64 e - "Developing a comprehensive masterplan for the new garden village at Dunton Hills, to engrain the core garden village design principles"
* how can an objective view be made on site selection before this masterplan detail is presented and made available to the public?

Section 26 - "Commited to growth . . . but in a way that maintains and enhances unique local character"
* wheras DHGV will completely destroy the unique local character of Dunton Village which is right on its border.

Section 28 - Strategic Objectives - S04 "A new well connected community at Dunton Hills"
* Please see fuller comments below - but how can it be well connected when it isolated from the rest of Brentwood, isolated from the railway and bound by already heavily congested roads

Figure 9 - page 26/27 - Proposed Housing Led Allocations
* DHGV is not included in the Green Belt total, effectively masking the extent of Green Belt land being developed
* Out of 381.25 Hectares of land allocated, 342.65 (257 + 85.65) is green belt. That's a staggering 89.8% Green belt land, which does not deliver a sustainable, ecological allocation plan.

Section 67 - Total dwellings
* Figure 9 shows a total allocated dwelling number of 6,154 houses. DHGV makes up 40% of this total. However, section 67 states this figure could increase to 9080 with accelerated growth within DHGV to deliver 3500 dwellings.
* This will add a huge burden to the surrounding infrastructure. With an estimated 9000 residents (section 105), a large level of investment will need to be made regarding roads, health, schools, shopping and work provisions. A sticking plaster approach will just not work given that many of these areas are already stretched to within breaking point.
* It just seems that not enough effort has been put into dispersing these houses across the borough. It is just lazy of the council to allocate it 1) on green belt land and 2) land from a single land owner - just to make the allocation process easier

Figure 13 - page 33 - Provision of traveller sites
* Travellers do not contribute funding in the same way that the general public do through council tax, national insurance etc. and therefore it does not seem appropriate to creating infrastructure specifically for one minority group
* That said, if traveller provisions do need to be created, surely it is better for all concerned to allocate them away from large communities and therefore the 30 allocations at DHGV would seem wholly inappropriate in that regard

Figure 22 - page 57 - New Employment Site Allocations
* The largest proportion of new employment areas are extensions onto green belt land - again along the A127 corridor, further burdening the already gridlocked roadways. The A127 is already experiencing pollution levels above EU allowable levels.
* The erosion of Greenbelt along the A127 means that there is almost no division from the urban sprawl of London and Brentwood / Basildon meaning that there will no longer be any green belt

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?

I object to these proposals, As I live in Ingrave and the A128 would become a major route for construction traffic. This road was not built to take that sort of traffic, you only need to look at it first thing in the morning to see that. It is quite normal for traffic to queue almost from the Halfway House roundabout to the Running waters roundabout. During the spring and summer months, this has a detrimental effect on the air quality. I would like to see the results of (if any) environmental impact study that has been undertaken by BBC to show the impact on health of the increase of traffic. Especially as the majority of the increase would be from large diesel lorries. I moved to Brentwood to get away from poor air quality in London and now you are dead set about going down the same path.

The act states that the Green belt was set up:

* To check the unrestricted sprawl of large built-up areas
* To prevent neighbouring towns from merging into one another
* To assist in safeguarding the countryside from encroachment
* To preserve the setting and special character of historic towns
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Once an area of land has been defined as green belt, the stated opportunities and benefits include:
* Providing opportunities for access to the open countryside for the urban population
* Providing opportunities for outdoor sport and outdoor recreation near urban areas
* The retention of attractive landscapes and the enhancement of landscapes, near to where people live
* Improvement of damaged and derelict land around towns
* The securing of nature conservation interests
* The retention of land in agricultural, forestry and related uses.

As someone who has a great knowledge of the building industry, I know that developers would rather build on virgin land that carry the cost of decontaminating brownfield sites. So please make this development a last result and not a first choice, for the sake of generations to come.

I object to the proposed housing development on sites 044 & 178 at Priests Lane for the following reasons: 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: there seems to be no concrete technical evidence to support Priest Lane as a preferred site. Page 11: '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.' Comment: Priest Lane is really quite a narrow road with narrow pavements. It is already quite challenging to cyclers and motorists particularly during peak hours. With the additional homes to be built in Priest Lane site, resulting in additional cars using Priest Lane, it will be even more difficult to cycle safely. 'Brentwood will grow sustainably with new development directed to urban brownfield opportunity sites, well planned urban extensions and key transport corridors. Comment: The Priest Lane site is the ONLY greenfield site in the plan

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.

Thank you for allowing Persimmon Homes the opportunity to comment on

1. Brentwood Local Plan: Preferred Site Allocations Local Plan (to 2033)
2. Supporting evidence base

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the Essex and wider Eastern region. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a 'user' of the Development Plan.

Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales. Persimmon Homes, together with other Members, have inputted into the HBF's representations.

The below comprises Persimmon Homes representation to the Preferred Site Allocations Local Plan.

Duty to Co-operate & London

Despite the Emerging London Plan expectation that London will deliver 65,000 each
year from 2019-2029, there will be a need for LPAs with strong commuting and
migratory links with London, such as Brentwood, to consider how it can address
unmet housing needs arising from the capital. It is considered that further evidence is needed in regard to the exercising of the Duty to Co-operate and the extent to which Brentwood should assist London meet its needs both prior and post 2029.

Essex

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

Housing Needs

We agree with the HBF that Brentwood should look at the implications of the Governments published draft standard methodology. It is the intention of Government to introduce the standard methodology for housing needs. To advance a sound plan and one that seeks to address the Housing Crisis, the draft Plan should factor in the emerging government advice and policies. We consider it appropriate that given the significant affordability issues that the Council applies an uplift of at least 40%.

The Government's proposed standardised objectively assessed housing needs methodology indicates a need for Brentwood to deliver a capped figure of 454 dwellings per annum. It is considered that the plan should seek to address this figure. This would give rise to an extra 1,480 homes during the plan period.

Housing delivery

There is presently a distinct lack of published supporting technical studies in relation to the Dunton Hills Garden Village as proposed in the Local Plan. Furthermore, there is insufficient evidence of co-operation with and a joint vision Basildon & Thurrock Council's with regards the Garden Village, how it will be delivered having regards to the neighbouring authorities aspirations for growth in this area.

It is noted that the Council are exploring whether Dunton Hills Garden Village could increase delivery from 2500 to 2033 to c4,000. It is considered that this work should have been undertaken in advance of the consultation and the findings inform the Preferred Options.

The draft plan is heavily reliant upon sites that currently have beneficial uses,
including;
* Ford Offices 117A / 117B,
* Railway Station car park ref: 002,
* William Hunter Way car park ref 102,
* West Horndon Industrial Estate 020, 021 152.

Whilst Local Plans need to be aspirational, they also need to be realistic. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. Sites with current beneficial uses, if deliverable, are likely to be more difficult and therefore slower to deliver. They will have established use values that will influence whether they are brought forward for residential development. In addition, brownfield site are likely to be subject to additional costs in terms of relocating businesses, demolition, and remediation that may impact viability. The Council need to robustly assess its assumptions with regard the extent to which sites with current beneficial uses will be deliverable and can viably contribute towards meeting housing need, including that for affordable housing.

We are concerned that the Local Plan is too heavily reliant upon sites that may not deliver and if they do, may not assist in terms of boosting housing land supply or deliver the levels of affordable housing needed.

We hope these representations are of assistance in taking the plan forward to the
next stage of plan preparation.

See attached.

See attached.

See attached.

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached a representation made on behalf of Barnoaks Management Ltd for Land South of the B1002, Ingatestone. The representation consists of the following:
- Representation
- Consultation Form
- Appendix A : Location Plan
- Appendix B : Proposed Site Plan
- Appendix C : Landscape and Visual Issues Report
- Appendix D : Landscape and Advisory Report
- Appendix E : Site Access Appraisal

Please find attached representations made on behalf of S & J Padfield and Partners for Land at Codham Hall North. The representations consist of the following:
- Representation
- Consultation Form
- Green Belt Assessment
- Appendix A and Appendix B of the Green Belt Assessment

Please find attached representations made on behalf of S & J Padfield and Partners for Land at Codham Hall North. The representations consist of the following:
- Representation
- Consultation Form
- Green Belt Assessment
- Appendix A and Appendix B of the Green Belt Assessment

See attached.

See attached.

See attached.