Strategic Objectives

Showing comments and forms 1 to 23 of 23

Comment

Preferred Site Allocations 2018

Representation ID: 17950

Received: 21/02/2018

Respondent: Essex Bridleways Association

Representation:

SO17: We would prefer to see the aspiration of access for all within such green infrastructure embedded within the Plan's Strategic Objectives and suggest this objective is worded thus: 'Establish a rich connected network of accessible Green Infrastructure across the Borough...'

SO22: Access for all should be emphasised in the Plan as at present only walking and cycling are catered for. For the Plan to be fully inclusive, we suggest this objective is reworded thus: 'improve cycling, walking and horse riding facilities across the Borough and establish a network of green transport corridors, accessible to all vulnerable user groups...'

Full text:

SO17: We would prefer to see the aspiration of access for all within such green infrastructure embedded within the Plan's Strategic Objectives and suggest this objective is worded thus: 'Establish a rich connected network of accessible Green Infrastructure across the Borough...'

SO22: Access for all should be emphasised in the Plan as at present only walking and cycling are catered for. For the Plan to be fully inclusive, we suggest this objective is reworded thus: 'improve cycling, walking and horse riding facilities across the Borough and establish a network of green transport corridors, accessible to all vulnerable user groups...'

Object

Preferred Site Allocations 2018

Representation ID: 18098

Received: 08/03/2018

Respondent: Mr Gordon Bird

Representation:

S05 states 'Manage development growth to that capable of being accommodated by existing or proposed infrastructure, services or facilities'. This is a misleading statement - much as I would like to see it achieved. At present traffic exceeds capacity on all main roads. There are appear to be no plans to address this - therefore the objective cannot be achieved.
The present Plan (adopted 25th Aug 2005) had a similar objective. There has been no significant road infrastructure introduced in years - Brentwood road network is essentially the same as 45 years ago.

Full text:

S05 states 'Manage development growth to that capable of being accommodated by existing or proposed infrastructure, services or facilities'. This is a misleading statement - much as I would like to see it achieved. At present traffic exceeds capacity on all main roads. There are appear to be no plans to address this - therefore the objective cannot be achieved.
The present Plan (adopted 25th Aug 2005) had a similar objective. There has been no significant road infrastructure introduced in years - Brentwood road network is essentially the same as 45 years ago.

Support

Preferred Site Allocations 2018

Representation ID: 18118

Received: 12/03/2018

Respondent: Sport England

Representation:

Support is offered for including a strategic objective (SO18) which protects and nurtures existing leisure facilities and recreational assets to promote and enhance social inclusion and health and well-being as this recognises the role that sport, recreation and leisure facilities play in meeting this objective.

Support is also offered for the strategic objective (SO19) relating to delivering essential infrastructure including recreation and community facilities in order to support new development growth as this recognises the importance of sport and recreation facilities (which would form part of community facilities) in creating sustainable communities in new developments.

Full text:

Support is offered for including a strategic objective (SO18) which protects and nurtures existing leisure facilities and recreational assets to promote and enhance social inclusion and health and well-being as this recognises the role that sport, recreation and leisure facilities play in meeting this objective.

Support is also offered for the strategic objective (SO19) relating to delivering essential infrastructure including recreation and community facilities in order to support new development growth as this recognises the importance of sport and recreation facilities (which would form part of community facilities) in creating sustainable communities in new developments.

Support

Preferred Site Allocations 2018

Representation ID: 18153

Received: 10/03/2018

Respondent: Malcolm Hepburn

Agent: SJK Planning

Representation:

We are putting forward representations in respect of a proposed village extension at Mountnessing.
The site is in a sustainable location, served by existing and proposed services and facilities.
Please see attached documents.

Full text:

We are putting forward representations in respect of a proposed village extension at Mountnessing.
The site is in a sustainable location, served by existing and proposed services and facilities.
Please see attached documents.

Support

Preferred Site Allocations 2018

Representation ID: 18248

Received: 12/03/2018

Respondent: CODE Development Planners Ltd

Agent: CODE Development Planners Ltd

Representation:

The Promoters of DHGV fully support all the strategic objectives and particularly those strategic objectives which aim to set the policy background to delivering and managing a sustainable (SO6-7), well connected (SO4), high quality designed (SO4) and creation of community (SO19-20) form of development, all set within and contributing to a rich connected network of Green Infrastructure (SO17). Assessments carried out so far by the Promoters, with input from a variety of stakeholders have confirmed confidence that DHGV can deliver against these strategic objectives. Further detail is contained in attached representations.

Full text:

The Promoters of DHGV fully support all the strategic objectives and particularly those strategic objectives which aim to set the policy background to delivering and managing a sustainable (SO6-7), well connected (SO4), high quality designed (SO4) and creation of community (SO19-20) form of development, all set within and contributing to a rich connected network of Green Infrastructure (SO17). Assessments carried out so far by the Promoters, with input from a variety of stakeholders have confirmed confidence that DHGV can deliver against these strategic objectives. Further detail is contained in attached representations.

Comment

Preferred Site Allocations 2018

Representation ID: 18261

Received: 12/03/2018

Respondent: Essex County Council

Representation:

See above.

Full text:

ECC welcomes the inclusion of a clear set of strategic objectives. It is recognised that BBC is seeking to ensure the strategic objectives are consistent with the national planning guidance through managing growth; creating sustainable communities; seeking economic prosperity; protecting and enhancing the environment; improving quality of life and providing community infrastructure; and addressing transport and movement matters. This is consistent with the PPG. However concern is raised with the increase in objectives from the 2016 Draft Local Plan (13), to the current consultation (23), and whether they reflect the strategic priorities for the Borough, or whether they are providing more detail which should be reserved for the policies within the Plan.

The strategic objectives clearly send the message that the purpose of the new Plan will be to align key infrastructure with sustainable growth, the development and resilience of health and wellbeing, creating a prosperous economy, whilst protecting the environment. ECC welcomes the anticipated benefits of this approach.

ECC seeks clarity on how Objective 13 (protecting the core office market) may be achieved. Recent evidence does not suggest that this is being supported, with existing commercial sites having been, or still being at risk of being lost to residential, including Library House, New North House, and BNY Mellon House.

ECC welcomes the protection and enhancement of the environment through Objective 16.

ECC is supportive of Objectives SO17 and SO22 in terms of BBC's support for enhancing the green infrastructure network and connectivity across the Borough. ECC is also supportive of Objective SO23 regarding supporting a low carbon future and inclusion of electric vehicle charging points.

Objectives S021, S022 and S023 all cover Sustainable Transport and the document makes reference to the fact that sustainable transport is central to their plan making, which is supported in principle by ECC.

ECC acknowledges and supports the need for improvements for sustainable travel and the need for modal shift, however there are areas of the strategic highway network such as the A127 that will require significant mitigation measures if economic growth is to be realised.

ECC is concerned that the Objectives that cover transport and movement (S021, S022 and S023) do not recognise the need for highway infrastructure to facilitate movement of goods / commuters.

As Highway Authority, ECC acknowledges the following strategic objectives, namely SO2 (Growth in transport corridors); SO5 (Growth accommodated by existing or proposed infrastructure), SO19 - (secure delivery of transportation and community infrastructure). ECC also welcomes the addition of the specific transport and movement strategic objectives SO21 (public transport infrastructure and connections), SO22 (cycling, walking and green transport corridors), and SO23 (infrastructure for low carbon future) in the Draft Local Plan.

ECC also recommends that reference be made to ensuring that proposals address the need for strategic and general highways infrastructure.

In order that the strategic objectives are met it is imperative that timely and appropriate highway modelling is undertaken. Further comments relating to highways and transportation matters are provided in the Spatial Strategy section below.

Object

Preferred Site Allocations 2018

Representation ID: 18454

Received: 27/02/2018

Respondent: Mr Andrew Finlay

Representation:

1) Green belt. The ever-increasing pressure for more roads and housing means it is vital the council should do everything it can to protect and invest in the Green Belts that we have. Development on Green Belt land is supposed to be tightly controlled - its purpose is to serve as a buffer between towns and between towns and the countryside. Green Belt land also brings social, environmental and economic benefits. They are responsible for food production, flood prevention, climate change mitigation and more. We should be protecting them and not recklessly building on them.

Full text:

1) Green belt. The ever-increasing pressure for more roads and housing means it is vital the council should do everything it can to protect and invest in the Green Belts that we have. Development on Green Belt land is supposed to be tightly controlled - its purpose is to serve as a buffer between towns and between towns and the countryside. Green Belt land also brings social, environmental and economic benefits. They are responsible for food production, flood prevention, climate change mitigation and more. We should be protecting them and not recklessly building on them. 2) Health. The nearest Health Centre appears full to capacity and can take weeks to obtain an appointment if required. How will this improve if additional houses are built? 3) Education. Blackmore school is full. The parked cars for the school line Nine Ashes road at 8:45 and 15:00 Monday - Friday. The ones that can't fit on the road park down Woollard Way. How will the school accommodate the additional influx whilst striving to achieve the best Ofsted award it can? Will the educational needs of the current pupils be undermined due to the additional pupils? 4) Transport. The bus service is part-time. Is this sufficient? The village is already busy with traffic and parked cars throughout the day - more noticeably in the morning and evening rush hour periods, making parking to access local amenities extremely difficult. Will additional housing improve this already unsatisfactory situation? 5) Disruption. How long will it take to build the additional houses earmarked for Blackmore and is this acceptable to current residents?
6) Land permanent loss of viable agricultural land. The risk of increasing frequency and severity of flooding. The clay soil in the area already makes drainage very difficult and the Green Belt land helps greatly in removing excess rainfall. Will building on this land make the flood risk better or worse?

Object

Preferred Site Allocations 2018

Representation ID: 18498

Received: 15/03/2018

Respondent: Billericay Action Group

Representation:

Object to development in Brentwood due to impact on "overstretched C2C line".

Full text:

I'd like to express my objection to de-designation of Green Belt.
Brentwood can meet its own needs and much more without using Green Belt. The OAN goes far beyond that and the Council should therefore use Green Belt and transport constraints as a reason not to meet OAN.
I draw your attention to the study by the SE Essex Action Group Alliance into the overstretched C2C line, the limited potential for improvements and the huge demand growth projections.
The Study also has significant detail on the limitations of the Anglia route but focusses on the Southend Victoria branch.
Executive Summary: http://seeaga.uk/SEEAGA%20-%20Rail%20Topic%20Paper%20-%20Exec%20Summary%20v1.pdf
1. Executive Summary - seeaga.uk
seeaga.uk
SE Essex Action Group Alliance - 2017 1 1. Executive Summary One of the original reasons for establishing the Green Belt around London was to prevent the capital's
Full Paper: http://seeaga.uk/SEEAGA%20-%20Rail%20Topic%20Paper%20v1.pdf
Two Birds in the Hand Topic Paper on SE Essex' commuter ...
seeaga.uk
SE Essex Action Group Alliance - 2017 1 Two Birds in the Hand Topic Paper on SE Essex' commuter rail links SE Essex Action Group Alliance

Support

Preferred Site Allocations 2018

Representation ID: 18514

Received: 13/03/2018

Respondent: Mr Roland Lazarus

Representation:

I agree with and support SO1, SO2 SO3, SO6, SO15, SO16, SO17, SO18 and SO22

Full text:

Strategic Objectives
I agree with and support SO1, SO2 SO3, SO6, SO15, SO16, SO17, SO18 and SO22
I disagree with and object to SO4 and SO7

Housing Need
On page 18 the 2014 DCLG household projections reveals, when converted to dwellings, an increase from 322 to 348 net new dwellings is the starting point for the annual objectively assessed need for housing. This is lower than the 362 dwellings figure in the Draft Local Plan (2016).
Due to the worsening of the affordability ratio in Brentwood and the increased costs of rental levels, I conclude there is a need for a reasonable upwards move in the proportion of new dwellings that are affordable. The higher price of housing implies greater profits from developments. This allows for a higher percentage of affordable housing to be delivered. The exact figure needs to be tested for viability but I expect mixed housing at 50% or above affordable housing should be achievable on sites of 15 or more new homes qualifying for affordable housing delivery. There is a ready supply of housing currently available through estate agents that could be termed unaffordable housing for those on or below average pay. The need for affordable housing, rental and purchase, can more truly be called 'need'. As the proportion of affordable housing delivered through new housing developments increases the total number of new houses required to deliver the needed number of affordable new homes can be reduced. If, as many are predicting and is expected due to leaving the EU, housing costs starts to fall, the proportion of affordable housing delivered from new developments would have to fall but general affordability would be improving at the same time. I reject the DCLG proposed new standard formula for housing need. Government schemes boosting the supply of money for new houses, buy-to-let investment schemes and other investment vehicles (UK and foreign) have distorted the market for housing artificially inflating prices, I therefore reject the adoption of 380 dwellings per annum as the OAHN.
The OAHN of 348 dwellings per annum equates to 6,960 dwellings across the plan period (2013-33).
2,109 or 30% have already been built, have planning permission or are expected to come through windfall delivery.
1,732 or 25% can be built on urban and other brownfield sites.

Green Belt
On page 34 at 74 it says "Government policy states that Traveller sites (temporary or permanent) in the Green Belt are inappropriate development, which by definition is harmful to the Green Belt and should not be approved, except in very special circumstances. The PPTS states that Green Belt boundaries should be altered only in exceptional circumstances." This is the only reference to the need for exceptional circumstances in the document but paragraph 83 of the NPPF says "Once established, Green Belt boundaries should only be altered in exceptional circumstances" but we are not told what these are or if there any. Paragraph 87 makes it even clearer saying "As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."

Green Belt is meant to be a restraint. Paragraph 87 of NPPF states "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." This Draft Plan has lost sight of this. Much of the currently open Green Belt would be lost to housing despite NPPG advise:-
In decision taking, can unmet need for housing outweigh Green Belt Protection? Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the "very special circumstances" justifying inappropriate development on a site within the Green Belt. Planning Practice Guidance, Housing and economic land availability assessment, Methodology - Stage 5: Final evidence base, 6 March 2014. Paragraph 034 Reference ID: 3-034-20141006 from the NPPG

The Council do not have sufficient grounds to believe that the unmet need for housing or any other very special circumstances should apply here or could in combination constitute the very special circumstances required.

Green Belt serves five purposes:
●● to check the unrestricted sprawl of large built-up areas;
●● to prevent neighbouring towns merging into one another;
●● to assist in safeguarding the countryside from encroachment;
●● to preserve the setting and special character of historic towns; and
●● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

To varying degrees at each site, now in Green Belt, there would be harm done to these purposes.

Green Belt is meant to direct development elsewhere. In this Draft Plan 4,327 new homes, or 70% of the 6,154 to be built, are to be directed to former Green Belt land. On top of this, employment site 187 south of East Horndon Hall, would also be lost from Green Belt. This is unrestrained growth, it negates the aim and purposes of Green Belt.

That said, the harm done to Green Belt is different at different sites. Brownfield development in Green Belt may not be inappropriate. It is true that many of the chosen sites are already compromised by some buildings on site or around it or proximity of the railway or A12.

I object to the 2,500 (potentially rising to 3,500) new homes at Dunton Hills.

I object to sites 076 and 077 at Blackmore and 075B and 194 at Kelvedon Hatch.

Object

Preferred Site Allocations 2018

Representation ID: 18545

Received: 13/03/2018

Respondent: Mr Roland Lazarus

Representation:

I disagree with and object to SO4 and SO7.

Full text:

Strategic Objectives
I agree with and support SO1, SO2 SO3, SO6, SO15, SO16, SO17, SO18 and SO22
I disagree with and object to SO4 and SO7

Housing Need
On page 18 the 2014 DCLG household projections reveals, when converted to dwellings, an increase from 322 to 348 net new dwellings is the starting point for the annual objectively assessed need for housing. This is lower than the 362 dwellings figure in the Draft Local Plan (2016).
Due to the worsening of the affordability ratio in Brentwood and the increased costs of rental levels, I conclude there is a need for a reasonable upwards move in the proportion of new dwellings that are affordable. The higher price of housing implies greater profits from developments. This allows for a higher percentage of affordable housing to be delivered. The exact figure needs to be tested for viability but I expect mixed housing at 50% or above affordable housing should be achievable on sites of 15 or more new homes qualifying for affordable housing delivery. There is a ready supply of housing currently available through estate agents that could be termed unaffordable housing for those on or below average pay. The need for affordable housing, rental and purchase, can more truly be called 'need'. As the proportion of affordable housing delivered through new housing developments increases the total number of new houses required to deliver the needed number of affordable new homes can be reduced. If, as many are predicting and is expected due to leaving the EU, housing costs starts to fall, the proportion of affordable housing delivered from new developments would have to fall but general affordability would be improving at the same time. I reject the DCLG proposed new standard formula for housing need. Government schemes boosting the supply of money for new houses, buy-to-let investment schemes and other investment vehicles (UK and foreign) have distorted the market for housing artificially inflating prices, I therefore reject the adoption of 380 dwellings per annum as the OAHN.
The OAHN of 348 dwellings per annum equates to 6,960 dwellings across the plan period (2013-33).
2,109 or 30% have already been built, have planning permission or are expected to come through windfall delivery.
1,732 or 25% can be built on urban and other brownfield sites.

Green Belt
On page 34 at 74 it says "Government policy states that Traveller sites (temporary or permanent) in the Green Belt are inappropriate development, which by definition is harmful to the Green Belt and should not be approved, except in very special circumstances. The PPTS states that Green Belt boundaries should be altered only in exceptional circumstances." This is the only reference to the need for exceptional circumstances in the document but paragraph 83 of the NPPF says "Once established, Green Belt boundaries should only be altered in exceptional circumstances" but we are not told what these are or if there any. Paragraph 87 makes it even clearer saying "As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."

Green Belt is meant to be a restraint. Paragraph 87 of NPPF states "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." This Draft Plan has lost sight of this. Much of the currently open Green Belt would be lost to housing despite NPPG advise:-
In decision taking, can unmet need for housing outweigh Green Belt Protection? Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the "very special circumstances" justifying inappropriate development on a site within the Green Belt. Planning Practice Guidance, Housing and economic land availability assessment, Methodology - Stage 5: Final evidence base, 6 March 2014. Paragraph 034 Reference ID: 3-034-20141006 from the NPPG

The Council do not have sufficient grounds to believe that the unmet need for housing or any other very special circumstances should apply here or could in combination constitute the very special circumstances required.

Green Belt serves five purposes:
●● to check the unrestricted sprawl of large built-up areas;
●● to prevent neighbouring towns merging into one another;
●● to assist in safeguarding the countryside from encroachment;
●● to preserve the setting and special character of historic towns; and
●● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

To varying degrees at each site, now in Green Belt, there would be harm done to these purposes.

Green Belt is meant to direct development elsewhere. In this Draft Plan 4,327 new homes, or 70% of the 6,154 to be built, are to be directed to former Green Belt land. On top of this, employment site 187 south of East Horndon Hall, would also be lost from Green Belt. This is unrestrained growth, it negates the aim and purposes of Green Belt.

That said, the harm done to Green Belt is different at different sites. Brownfield development in Green Belt may not be inappropriate. It is true that many of the chosen sites are already compromised by some buildings on site or around it or proximity of the railway or A12.

I object to the 2,500 (potentially rising to 3,500) new homes at Dunton Hills.

I object to sites 076 and 077 at Blackmore and 075B and 194 at Kelvedon Hatch.

Comment

Preferred Site Allocations 2018

Representation ID: 18707

Received: 05/03/2018

Respondent: Mr Darren Williams

Representation:

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.

Full text:

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

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 19060

Received: 11/03/2018

Respondent: Mrs Hedy Lai

Representation:

SO5: Development of the Priests Lane site would add 1,000 houses in the Shenfield area, increasing congestion at the junction of Priests Lane/Middleton Hall Lane. It would also increase demand for surgeries within the Shenfield area. SO22: It is already terribly difficult and dangerous to cycle along Priests Lane, with very restricted space for vehicles and extremely narrow pavement for pedestrians. More vehicles from the new development would only exacerbate the current situation. Additional vehicles will increase air and noise pollution in the area.

Full text:

The Draft Local Plan sets out 'the spatial strategy continues to focus upon the
sequential use of land, which prioritises using brownfield first', but the Priests Lane
site is greenfield land and is the only greenfield site proposed in the plan. In SO5: 'Manage development growth to that capable of being accommodated by existing or proposed infrastructure, services and facilities.' Development of the Priests Lane site would add 1,000 houses in the Shenfield area, increasing congestion at the junction of Priests Lane/Middleton Hall Lane. It would also increase demand for surgeries within the Shenfield area. In SO22: 'Improve cycling and walking facilities across the Borough and establish a grid or network of green transport corridors.' It is already terribly difficult and dangerous to cycle along Priests Lane, with very restricted space for vehicles and extremely narrow pavement for pedestrians. More vehicles from the new development would only exacerbate the current situation. Additional vehicles will increase air and noise pollution in the area.

Comment

Preferred Site Allocations 2018

Representation ID: 19067

Received: 04/04/2018

Respondent: Helen Jackman

Representation:

I acknowledge the commitment to providing powering stations for the electric cars of the future. I do hope the facilities will predate the necessary influx of theses eco cars!

Full text:

I note that the committee has worked hard to identify potential development sites for housing inter alia.
My concerns lie within your "site constraint" paragraphs. While you identify very serious constraints such as parking, wildlife and woodland sites, conservation areas, and surface water flood risk, the implication is that you will, nevertheless, need to use these sites in order to meet your targets.
There is barely sufficient convenient parking space at present to attract people into the town centre rather than driving to out of town shopping sites, so, attractive as the current parking sites are for potential housing development, you need to retain town centre parking areas.
As for building on the station parking area, with its recognised danger of causing railway line flooding, unless the solution is extensive subterranean parking with subway access to the station, and a built-in drainage reservoir, I fail to see how Brentwood's potential and existing rail travellers are going to find Brentwood an attractive proposition.
I will also mention that your primary school predictions are already out of date as it has been acknowledged that Holly trees primary school cannot grow and that Warley primary school will need to grow to 420 pupils to account for the shortfall. I also understood that there was a need to build another primary school within the town in order to accommodate the growing and potential pupil numbers but I can find no site allocation for such a school with its requisite recreation grounds and fields.
Finally, I acknowledge the commitment to providing powering stations for the electric cars of the future. I do hope the facilities will predate the necessary influx of theses eco cars!

Support

Preferred Site Allocations 2018

Representation ID: 19159

Received: 12/03/2018

Respondent: JTS Partnership LLP

Representation:

Support is given to Strategic Objective 1 (SO1 - sustainable development / development of brownfield sites), 2 (SO2 - growth of the boroughs transport corridors), 19 (SO19 - secure the delivery of essential infrastructure to support new development), 21 and 22 (SO21 and SO22 - Transport & Movement Strategies).

Full text:

Support is given to Strategic Objective 1 (SO1) which seeks to maximise sustainable growth opportunities within the built-up areas and on brownfield sites. The Borough's built up areas are tightly constrained by Green Belt and all opportunities to meet housing and employment need within built up areas, and where possible, on brownfield land, should be considered and exploited before consideration is given to the release of green belt for new development. A key element of Sustainable Development is environmental role which contributes to protecting and enhancing our built, natural and historic environment through, inter alia, the use of natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change including moving to a low carbon economy. The focus of SO2 in directing growth to the Boroughs transport corridors and urban areas in locations well served by existing and proposed local services and facilities is essential in achieving the environmental role of sustainable development, and is supported. This is also linked to the Transport & Movement Strategic Objectives SO21 and SO22 which seek to ensure development sites are well connected to the public transport network and are linked to the walking and cycling facilities across the Borough. Sites which are well located within identified urban areas and transport corridors, well served by public transport and accessible by foot or bike to services, facilities and employment opportunities should continue to be the primary focus in identifying sites for development. Support is given to SO19 which seeks to secure the delivery of essential infrastructure to support new development, in particular education and community facilities which cannot compete in value terms when seeking to secure land to create of expand provision.
Paragraph 72 makes reference to the potential for larger site options to integrate new C2 facilities, including at (d) Honey Pot Land / Priests Lane (small to medium 40 bed scheme). While this is a worthy aspiration, it should be acknowledged that the providers of such uses will have their own specific locational requirements which will determine whether such land is appropriate or attractive to that sector.
Support is given to the need to Special Education Needs and in particular the ability to ease the considerable physical capacity constraints of the Endeavour School, and the aspiration to provide a 6th form function. Support will be given by the landowner of Site Ref: 044 to the Council and the Endeavour School to masterplan the proposed housing site at Priest Lane to incorporate land set aside for use by the Endeavour School.

Comment

Preferred Site Allocations 2018

Representation ID: 19316

Received: 06/03/2018

Respondent: Mr Geoff Sanders

Representation:

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? SO6 - What precisely does this mean for Priests Lane, one of the highest value housing areas in the borough? SO20 - What precisely does this mean? Which locations? Safeguards against blight?

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.

Object

Preferred Site Allocations 2018

Representation ID: 19511

Received: 11/03/2018

Respondent: Mr Richard Romang

Representation:

In regards to SO 3,5 and 6: The proposed development is not sustainable growth but is increasing the village housing stock by 28.6%, putting additional pressure on existing services and facilities which have been reduced over recent years and cannot be accommodated by existing infrastructure which is already failing.

Full text:

I am a resident of the Village of Blackmore and object to the proposed Local Development Plan for the following reasons. The plan does little to resolve the boroughs long standing infrastructure problems especially in terms of addressing public transport links to the outlying rural communities. It also appears to have no consideration for the problems facing the outlying rural communities other than use them as sites for affordable housing, that cannot be guaranteed, other than to meet the quota for new housing. As a resident of Blackmore I am shocked that no mention of additional housing was made in the proposal from 2009 but find that in the new document the village has been earmarked as a proposed site for an additional 90 dwellings to be built in two fields on the periphery of the village. I would agree that some affordable housing is required in the village however this density of housing would be unsustainable, cannot be of benefit to the community, will add to the congestion already suffered by the village and will exasperate the chronic parking issues that already exist. I note from the consultation document that the Blackmore site Ref:076 which is earmarked for 40 additional dwellings notes that road access is poor and that the area suffers from surface water flooding. There is no mention of how these issues will be resolved. The flood and SuDs plans displayed at the community consultation event at Tipps Cross had no information for Blackmore which was left blank. Local Authority representatives at the event had little knowledge of the area and were vague when answering questions relating to Blackmore. Areas of hedging towards the top of Red Rose lane show a high mix of species indicating ancient hedgerow of high bio-diversity and a valuable wildlife corridor which will be lost if road widening and development takes place. The section of the proposed LDP, titled Managing Growth, lists in its strategies S03 - Support the sustainable growth of our existing larger villages to provide improved housing choice and protect services and facilities. S05 - Manage development growth to that capable of being accommodated by existing or proposed infrastructure, services and facilities. In the case of development proposal in Blackmore neither of these statements can be supported as exiting infrastructure is insufficient for current needs. The proposed development is not sustainable growth but is increasing the village housing stock by 28.6%, putting additional pressure on existing services and facilities which have been reduced over recent years and cannot be accommodated by existing infrastructure which is already failing. Under the heading Sustainable Communities SO6 - Plan for housing that meets the needs of the Borough's population and contributes creating inclusive, balanced, sustainable communities. Again an increase in housing as proposed for Blackmore is not helping to create a sustainable community but is doing the opposite under current circumstances. Under the heading Spatial Strategy the proposed LDP states 48 - 49 Brentwood has a reasonably modest Gypsy and Traveller need requirement for the period 2016-2033 I would point out that Blackmore has a large illegal travellers site near the proposed development site which has put pressure on existing infrastructure and facilities especially the village school. This site has not been dealt with by the local authority and has been in existence for over 10 years. This fact has been ignore in the LDP document. 66 : The proposed housing allocations for the more sustainable villages are limited in size and scale but will at a local level provide a valuable role in enhancing the housing mix, introducing new affordable housing and help support local shops and services. As smaller greenfield sites they are likely to be attractive to smaller builders and have the possibility of being built out relatively quickly to support housing delivery within the early stages of the Plan being adopted. As with all current Green Belt sites, the Council is keen to ensure that edges of the sites are defendable and the revised village envelopes will be retained for the lifespan of the local plan and beyond. There is no evidence that the statement above will be met by the proposed development. The loss of amenities, poor public transport links and bad planning development decisions within the village boundary have seen Blackmore develop the characteristics of a dormitory village. Adding an additional 90 houses in two fields on the village boundary is not small scale development especially when considering maximum housing density. I also do not believe that affordable housing can be guaranteed under the current NPPF and development regulations especially as the NPPF is under review and will most likely favour housing development. Under the current system developers can state a lack of viability for building affordable housing, providing SuDs and improving infrastructure. I would also suggest that other development in the future is a possibility extending the village edge if the current government develops its ideas on house building. The document states that Blackmore Village Primary School has capacity for more children but does not show how many children from the village cannot go to their local school as places are taken by children from outside the village. As an ex-governor of the school I'm astonished that this argument has even been made. Under the heading Transport and Movement SO21 : Improve public transport infrastructure and ensure development sites are well connected to bus and/or rail connections. SO22 : Improve cycling and walking facilities across the Borough and establish a grid or network of green transport corridors. SO23 : Secure the delivery of new infrastructure to support a lower carbon future including electric vehicles charging points and other measures. No solid evidence in the document is presented into how the existing village infrastructure can be improved. In terms of public transport links the bus service in recent years has been reduced and a previous service provider stopped running buses as it was considered unprofitable due to Blackmores subsidised elderly and school aged population. The village is reliant on the car hence the villages current parking and congestion issues. I would also state that the bridge leading from Chelmsford Road has been weakened by heavy vehicle traffic. You also only have to visit Blackmore at weekends to know it is a popular hub for the South Easts cyclist and the roads are congested with parked cars and clogged by the cyclists riding in large groups sometimes 5 to 6 abreast. Much is made in the planning system of enhancing existing character, ensuring tranquillity in rural areas and in the LDP document of the need to facilitate and support stronger and vibrant town and village centres. How will this be applicable to Blackmore where the village centre is in a conservation area. Surely development and additional works traffic can only be detrimental to the fragility of this space. The village infrastructure which has had little investment in my XX years living in Blackmore is already insufficient, we have poor public transport, continuous flooding on the Chelmsford Road and in Red Rose Lane next to the proposed development site. The village suffers from regular power cuts, roads and public walkways are often in a state of disrepair and there are regular questions about sewage capacity. To add another 90 homes with the possibility of 200 additional vehicles shows a distinct ignorance of the problems facing our rural communities. It is also fair to point out the degrading of amenities in the village such as the loss of library services, a dedicated post office and reduced transport services have reduced the character and community cohesion of the village having an especially detrimental effect on elderly residents. This is far from the vibrant and sustainable picture painted in the LDP document which does little to address the issue. It is also worth pointing out that a new development of semi-detached housing was recently built in Nine Ashes, there is also an ongoing development at the site of the Norton Heath Equestrian Centre both of which add to existing infrastructure issues. Bad planning decisions within the village itself have allowed large sites previously occupied by single bungalows to be developed as large individual houses rather than encouraging the building of smaller dwellings. This has not only reduced the housing stock in the village but has also reduced the number of dwellings available for elderly residents that the building of affordable housing is supposedly trying to resolve. Although the plan states it guarantees the building of affordable housing for the village of Blackmore due to government policy there is no guarantee that affordable housing will actually be built. Due to the way developers use viability assessments and the poor use of available land in terms of housing density and vehicular parking I do not believe that any guarantee can be made that affordable homes and a workable SuDs system will be provided on the proposed sites. Generally I feel the proposed LDP process started as being well intentioned and agree that there is an obvious need for affordable housing. Unfortunately the current proposals appear to attempt to burden the outlying rural villages with large increases in housing showing a lack of research into current community needs, existing infrastructure, flood risk and sustainable capacity. The number of proposed houses is, I believe unsustainable and without guarantee and appears to be a desperate attempt to meet housing quotas for political expediency.

Object

Preferred Site Allocations 2018

Representation ID: 19646

Received: 12/03/2018

Respondent: JTS Partnership LLP

Representation:

General support of the strategic objectives the evidence base execpt in regards to Dunton Hills Garden Village as they do not 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 number of topics, and objectives, as set out in the Interim Sustainability Appraisal Report

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

Support

Preferred Site Allocations 2018

Representation ID: 19663

Received: 12/03/2018

Respondent: Childerditch Properties

Agent: Strutt & Parker LLP

Representation:

Economic prosperity forms a key part of the objectives and this links to our proposals
for the Childerditch Industrial Park. SO2 - This approach is supported and has potential to provide for employment growth in locations where there is strong market demand, and to minimise environmental impacts on the wider Borough. SO8 and SO14 - This Objective is supported and, in particular, the Plan's recognition that attracting new commercial investment will be crucial in fostering a prosperous, vibrant and diverse economy, to maintain high and stable levels of economic and employment growth for the Borough.

Full text:

See attached.

Support

Preferred Site Allocations 2018

Representation ID: 19775

Received: 12/03/2018

Respondent: S & J Padfield and Partners

Agent: Strutt & Parker LLP

Representation:

The Strategic Objectives identified within part one of the draft Local Plan are supported. Economic prosperity forms a key part of the objectives. Objectives SO8 to SO14 cover economic prosperity in particular and we support the prominence given to this issue in the consultation document. Objective SO8 is supported and in particular the draft Local Plan's recognition that attracting new commercial investment will be crucial in fostering a prosperous, vibrant and diverse economy with high and stable level of economic and employment growth.

Full text:

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

Support

Preferred Site Allocations 2018

Representation ID: 19799

Received: 12/03/2018

Respondent: St Modwen Properties PLC

Agent: Strutt & Parker LLP

Representation:

Objectives SO2 sets out the Council's aspiration to direct development growth to the
Borough's transport corridors. This approach is supported and has potential to provide
for employment growth in locations where there is strong market demand, and to
minimise environmental impacts on the wider Borough. We also support SO8 to SO14 which cover economic prosperity. SO8 is supported and in particular the draft Local Plan's recognition that attracting new commercial investment will be crucial in fostering a prosperous, vibrant and diverse economy with high and stable level of economic and employment growth.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19952

Received: 14/03/2018

Respondent: Rochford District Council

Representation:

The Council supports Brentwood's identified strategic objectives, in principle,
however would like to highlight the need to ensure that the impacts of the planned
growth and wider strategy on other authorities in South Essex, including Rochford
District, are considered in detail. It is expected that the collaborative work currently
being undertaken at the sub-regional level, which includes both Rochford District
Council and Brentwood Borough Council, will help to facilitate these cross-boundary
considerations.

Full text:

Thank you for inviting Rochford District Council to make comments on the Brentwood Borough Council Preferred Site Allocations consultation. Please find the Council's comments below. Could you please confirm receipt and acceptance of these comments in due course. Strategic Objectives The Council supports Brentwood's identified strategic objectives, in principle, however would like to highlight the need to ensure that the impacts of the planned growth and wider strategy on other authorities in South Essex, including Rochford District, are considered in detail. It is expected that the collaborative work currently being undertaken at the sub-regional level, which includes both Rochford District Council and Brentwood Borough Council, will help to facilitate these cross-boundary considerations. Approach to Housing and Objectively Assessed Need Rochford District Council supports, in principle, Brentwood's approach to meeting its housing needs, but would like to raise the need to consider the impact of its proposed housing allocations within the wider context of South Essex. This is particularly pertinent in relation to the Dunton Hills garden village which could potentially be sited close to other proposed housing locations in the neighbouring authorities of Basildon and Thurrock. Rochford District Council would advocate a joined up approach to fully consider the potential impacts of this growth, and in particular, would like to highlight the need for Brentwood Borough Council to consider the impacts of this growth on the authorities and communities beyond it boundaries, including Rochford District. Approach to Gypsy and Traveller Accommodation Rochford District Council supports Brentwood's approach to meeting its Gypsy and Traveller accommodation needs in full and continues to support the close working of the Essex Planning Officer's Association towards effective planning for Gypsy and Traveller provision into the future across Essex. Approach to Infrastructure Planning Rochford District Council raises no objection to Brentwood's approach to infrastructure planning at this time but would like to highlight the need to carefully consider the impact of planned growth on the A127, A130 and A13, which all form part of the strategic road network for South Essex. The Council highlights the need to consider the impact of developments on these roads, as well as the wider strategic network, and would support further exploration of the mitigation and improvement measures needed to make such growth sustainable. The impact of the Lower Thames Crossing proposals should also be considered. Approach to Economic Development and Jobs Rochford District Council raises no objection to Brentwood's approach to economic development and growth but would highlight the need to carefully consider the impact of the planned growth on neighbouring authorities and the strategic highway network. Again, the Council would support further exploration of the mitigation and improvement measures needed to make such growth sustainable. Approach to Duty to Co-operate Rochford District Council raises no objection to Brentwood's fulfilment of the Duty to Co-operate, but would highlight the need to continue to work collaboratively with all other South Essex authorities on cross-boundary strategic planning matters, further to the intentions of the South Essex 2050 Memorandum of Understanding.

Comment

Preferred Site Allocations 2018

Representation ID: 20058

Received: 12/03/2018

Respondent: London Borough of Havering

Representation:

The document includes three new strategic objectives for transport and movement (page13) but these do not appear to be considered or explained elsewhere in the document nor for the specific allocations. It is unclear how they are relevant to the specific allocations nor how they have been taken into account. It's also unclear how Strategic Objective SO2 which sets out that growth will be directed to transport corridors has been considered. The document should explain how these have been addressed in the development of specific allocations given the importance of ensuring convenient movement in Brentwood and adjoining areas (including Havering).

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 22026

Received: 13/03/2018

Respondent: Miss Sophie Skinner

Representation:

The idea of new shops seems attractive, but Brentwood High Street is already struggling, so how will more shops make it better?

Full text:

I disagree with the development of a protected open urban space. I do not think the site should be developed because there is already a lot of traffic along the road, which travels very close to pedestrians on the single pavement. There will be much more traffic with all the other developments, and the development will cause even more traffic problems and the new roads onto the sites are likely to be dangerous. Also, the town is losing too many green spaces, there are very few areas within the town. It is difficult to get to the county parks without a car, and the cost of parking is expensive for people like me with no car, and on low income (I am a student). We should be trying to keep the green spaces and playing fields, especially next to schools, and try to get more use for the community. Also, the Plan puts a lot of traffic into the town centre, but there is already too much traffic. The idea of new shops seems attractive, but Brentwood High Street is already struggling, so how will more shops make it better?