Dear Sir/Madam

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

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

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

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

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

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

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

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

Kind regards.

Dear Sir/Madam

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

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

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

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

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

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

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

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

Kind regards.

Dear Sir/Madam

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

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

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

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

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

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

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

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

Kind regards.

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

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

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

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

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

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

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

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

I look forward to hearing from you.

Having a consultation, I wish to object to the amount of housing that you are planning to build accessing Chelmsford Road, Shenfield.

An amount of 845 dwellings are planned which is totally disproportionate for the existing infrastructure.

This is made up of 510 on Officers Meadow (misleading by saying that it is off Alexander Lane which is a country lane),
Land east of Chelmsford Road which is nothing more than an extention of Officers Meadow.215
Land north of Chelmsford Road 100
Eagle and Child, Chelmsford Road 20
Total 845

This is totally excessive for this Road to take, as you know the A1023 which is the Chelmsford Road is considered by ECC as a trunk road.
When an Accident/ Incident occurs on the A12, London bound, traffic diverts onto this road and brings the town centre to a halt at Wilsons corner, now add to all the traffic that will be accessing onto this Road particularly during both rush hours and you will have gridlock. Add to this the increase of cars sales year on year by about 5% and what do you have but chaos.

You also plan to build 55 dwellings in Crescent drive, again some of these will be accessing Shenfield Road a continuation of the A1023.

You have just built 91 dwellings at Mountnessing roundabout and if you build 161 dwellings at/next to Ingatestone garden centre, residents from their will want to access Brentwood.

This is far too many dwellings all in one place and is just not acceptable.

Please look at this again, the existing road struggles every week day to cope as it is and their is no mention of improving the infrastructure.

Yours sincerely.

Object. Site at Penny Pots, Ongar Road, Stondon Massey, Essex CM15 0EA was not included for housing development. Site is suitable as:
- it is adjacent to an existing built up area of Stondon Massey
- it would form a natural boundary to the existing settlement
- it was considered in the SHLAA as "suitable" and "achievable"
- it would provide much needed housing provision for Stondon Massey
- it would not change the character of the Green Belt or cause any damage to it.

See attached.

See attached.

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

See attached.

1. We are instructed by our clients, Sue Harrison and Matthew Dunn, to submit
representations to the Brentwood draft Local Plan, preferred site allocations,
January 2018 in respect of land at Sandpit Lane, Pilgrims Hatch, Brentwood.
2. Our position is that the Plan is currently unsound but would be made sound by
the deletion of the representation site from the Green Belt and associated
allocation for residential development.
3. We introduce the site, housing context and conclude with the justification for this
allocation as sought.
4. The site is outlined in red on the screenshot below, plus we also enclose an OS
base: (see attached)
5. The site lies to the west of Sandpit Lane, just to the south of Danbury Close, a
small cul-de-sac of bungalows which we assume were purpose-built for specialist
housing for the elderly. This road concludes with a turning head alongside the
representation site, albeit there is no connectivity.
6. Traffic calming measures are installed on the main road in the form of a
constricted carriageway, just to the south of this cul-de-sac with priority to
traffic travelling west.
7. The site itself is largely open with mature planting on all sides. There is a
footpath across the site, however this is informal and is not a prescriptive right
of way.
8. The site is in a sustainable location as it is clearly very close to Pilgrims Hatch.
There is a direct route via a public pathway from the representation site to all the shops and services provided by Pilgrims Hatch. The Blue Crown public house
is a very short walk along the pathway on the eastern side of Sandpit Lane.
Moreover Pilgrims Hatch provides easy access to the town centre via an
established network of public transport infrastructure.
9. We have already confirmed that the site open and access is deliverable without
reliance upon third-party land and we enclose a screenshot of an initial access
arrangement prepared by Highway Consultants below: (see attached)
10. We are therefore dealing with a site which is deliverable, well screened and in a
sustainable location.
11. In respect of the housing context the local planning authority has not been able
to deliver a 5-year housing land supply (5HLS) for a prolonged period of time:
this is also its current position.
12. The emerging Local Plan fairly presents a recognition that there has been a step
change in the development needs of the Country as a whole and that the need
of Brentwood as a Borough are now significantly different from when the Local
Plan was adopted in 2005.
13. There is equally a recognition that Brentwood is a "borough of villages" and that
this character should be retained.
14. The Local Plan sets the context of the importance of transport corridors to
include the A12 as well as the Ongar Road.
15. The current consultation document Local Plan also sets out the housing position
and the obligation upon the Borough to provide a significant number of new
homes over the Plan period. Taking into account a series of factors to include
anticipated demographic changes there is now a housing figure of 380 dwellings
per annum which equates to 7,600 across the Plan period which runs from 2013
to 2033.
16. Paragraph 43 of the emerging Plan reads as follows:
For the purposes of plan-making and allocations it is considered prudent at this stage to plan for housing numbers slightly above the 380 dwellings per annum figure to create some degree of flexibility and contingency should some housing sites fail to come forward as expected.
17. Paragraph 44 notes that this is a challenging figure for the borough as 380
dwellings per annum compares to an earlier figure of 132 dwellings per annum and this readily illustrates the stepped change in the obligation from providing
new housing.
18. The Plan recognises this means that there is almost a tripling in the annual
delivery rate of new homes.
19. The Plan publishes 31 housing-led allocations across a variety of sites and within
the urban area, some of which are small sites which would yield between 5 and
50 units.
20. Part 2 of the Plan then deals with the preferred site allocations.
21. We note in respect of the immediate context to our representation site "A12
corridor-urban extension site" 010 is allocated in the drfat plan for residential
purposes; namely the Sow and Grow garden centre along Ongar Road, Pilgrims
Hatch which is seen as a brownfield development opportunity to provide an
indicative figure of 38 units.
22. We logically refer to this is as it is in very close proximity to our representation
site and indeed the screenshot below taken from page 73 of the emerging Plan
shows our site just to the west of blue allocation 010, with the words "Sandpit
Lane" just about legible. (see attached)
23. There are a number of important factors which underlie the case of our
representation site. The first is that the step change in the need for housing is
significant. The context is that the local planning authority has not had and does
not currently have, at the time of writing, a 5HLS.
24. The Local Plan should be robust and sound and there should be no room for
failing to provide housing to meet needs.
25. If the local planning authority is not able to provide a robust 5 HLS then
applicants can invoke paragraph 14 of the Framework which takes a level of
control away from the local planning authority, and the local planning authority
has suffered the consequences of this in recent years.
26. The National Planning Policy Framework is clear as to these points and
paragraph 159 states that local planning authorities should meet household and
population projections.
27. Within this context, the land off Sandpit Lane will contribute towards housing
figures and ensure that the Plan is sound.
28. The local planning authority is inevitably reliant upon a multiplicity of sites and it
is impossible at this stage to conclude that all are deliverable and that they will
meet the anticipated capacity within the Plan period. A further contingency will
underlie the robust nature of the emerging Plan. There will inevitably (as is the
case with all Local Plan processes) be evidence presented in due course that a
number of these sites will not come forward or in the capacity envisaged.
29. We note that there are a number of allocations in respect of existing car parking
land and there may be real issues in terms of bringing these sites forward.
30. With regard to the description of the current representation site at Sandpit Lane
it is clearly sustainable being an easy walk to shops and services which they will
play a role in sustaining.
31. There is a clear and sufficient footpath link from the site to the services.
32. This link also takes residents to Ongar Road where they can pick up a bus into
town.
33. This site is also deliverable. It is largely open with the exception of mature
vegetation on the periphery which will be retained in the context of any
residential scheme. The access has already been investigated and we refer to
the screenshot embedded earlier from an initial design to show that the site is
deliverable within reliance upon any third-party land.
34. The site is already well screened. It is a logical and sensible addition to the
urban area of Pilgrims Hatch and consistent with the general pattern of
development in the local area to include that on the western site of Ongar Road.
35. For these reasons the application will contribute towards the soundness and
robustness of the Plan and assist the local planning authority in meeting the step
change in housing delivery which, quite alarmingly, equates to a tripling of
current provision.
36. We therefore seek the allocation of the site for residential purposes on this basis.

See attached.

See attached.

See attached.

I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards

I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards

See attached.

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

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

see attached representations and appendices

See attached.

See attached.

See attached.

See attached.

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