Housing Need

Showing comments and forms 31 to 60 of 94

Object

Preferred Site Allocations 2018

Representation ID: 19086

Received: 10/03/2018

Respondent: Mr. & Mrs. James & Sue Fall

Number of people: 2

Representation Summary:

I object to these proposals because this will trash our green belt and provides a major lung effect for this part of Essex. It will detrimentally affect the lives of my young family in this area because of more pollution and lack of appropriate resources and logistics. Moreover Brentwood planning should be for Brentwood.

Full text:

I object to these proposals because this will trash our green belt and provides a major lung effect for this part of Essex. It will detrimentally affect the lives of my young family in this area because of more pollution and lack of appropriate resources and logistics. Moreover Brentwood planning should be for Brentwood.

Object

Preferred Site Allocations 2018

Representation ID: 19115

Received: 27/02/2018

Respondent: Mr Russ Mizen

Representation Summary:

The figures for population expansion are to high and have been recently evaluated to be 15% lower that expected, therefore numbers of houses should be reduced by the same amount.

Full text:

I wish to record my objection to the development of Dunton Hills Garden Village due to its size and impact on the area.

Essex is already full and the infrastructure cannot handle the development proposed.

There are already plans for approximately 90,000 homes in the nearby area and the area is already struggling to cope with the current population.

The site is on green belt land and should be protected - wildlife and ecosystems are being destroyed and restricted all over the county.

The A127 struggles with the current traffic load. It is not a trunk road and is not eligible for government funding so no meaningful improvements will be made to improve the traffic flow. Over the last two weeks local papers have reported ideas for a congestion charge and report pollution issues due to the current traffic load.

Basildon hospital is currently under staffed and underfunded, services are struggling and again local press constantly report serious incidents and mistakes due to over work. Parking is impossible with the current patients. Doctors surgeries have closed in many parts of Essex and Orsett hospital is set to close. New hospitals and resources will take forever and should be in place ready for population expansion, not put in after the event.

Development on the proposed scale will primarily affect other councils and will add further pressures on them.

Train services are currently inadequate and cannot cope with additional passengers. They will also get extra pressure from extra passengers up the line.

The figures for population expansion are to high and have been recently evaluated to be 15% lower that expected, therefore numbers of houses should be reduced by the same amount.

Travellers - Essex is currently blighted by travellers taking advantage and government laws need to be updated to keep them under control. We already have large traveller sites and they are now creating illegal ones more and more often. Brentwood need to put sufficient spaces in, in line with targets but numbers need to be reduced and controlled. Travellers should abide by common law and not be allowed to flaunt it.

Policing, ambulance and fire services are under resourced as it is, they cannot handle the continual increase in population without lives being put in danger.

Flooding is already a concern for the area but more roads drives gardens and roofs will only add to the problem.


ESSEX IS ALREADY FULL AND FURTHER DEVELOPMENT WILL PUT LIVES AT RISK.

Comment

Preferred Site Allocations 2018

Representation ID: 19154

Received: 11/03/2018

Respondent: Mr. & Mrs. ARA & CR Jamieson

Number of people: 2

Representation Summary:

Unclear of what the actual housing numbers are - 7600 or 9000? According to 2011 census information online, Brentwood had 30,600 households at that time. Assuming (generously) that this equates to 30,600 individual homes, this still appears to mean that the Brentwood district will grow over the next 15 years by approximately 25% - 30%, and it is impossible to imagine that this can do other than change the whole character of the area.

Full text:

I write on behalf of myself and my wife to register our serious concerns at the potential impact of the proposals embodied in the local plan. Before I begin, I should perhaps apologise if it turns out that I have based what follows on partial information, or on a misunderstanding of what is proposed. To some extent, I assume this must be the case, since in some areas (my first three bullet points below) the plan appears to be contradicting itself. I am assuming that the document of interest is the one headed 'Preferred Site Allocations 2018' - I have trawled through the website looking for other relevant information, and also in the hopes that there might actually be a shorter summary document, but have found neither. Regrettably I have struggled with this document because so much of it is given over to, what is for me, irrelevant minutiae relating to government policy; because different figures appear in different places; because it makes use of jargon and - my apologies - because the earlier portions are given over to meaningless platitudes. Anyway, assuming this is the correct document, I have a number of specific points : The introductory comments suggest state that 'People choose to live and work here because of the excellent transport links connecting us to London and the rest of the country, along with access to the surrounding countryside and green spaces' and also that 'A "borough of villages" will continue to be a defining characteristic of the area.' Green field and Green Belt development: I struggle to see how a plan which envisages significant building upon green-field sites can be reconciled with maintaining the bucolic charms which you see as an essential characteristic of the town; and nor do I see how the notion of a 'borough of villages' is enhanced by concreting over the gaps between them. There was a time - I believed - when the green belt was supposed to be sacrosanct, but I presume this is no longer the case. My concern is not simply the present intention to build within the Green Belt, but the inevitable precedent this sets. I presume the argument runs that we would be building only / mainly on Green Belt sites which are already compromised by existing development. But in so doing, yet more land will be compromised - paving the way for the same argument to be repeated forever, while the Green Belt steadily vanishes under tarmac. Rail links: If we really believe that fast transport links are a major attractor, I cannot understand how a plan to build on the station car park can do anything other than undermine this. You may be able to get to London in twenty minutes from the station, but if your journey time to the station now takes twenty minutes more than before because you can't park there (longer if you have to travel early and there are no buses), surely the fact that the train is fast is irrelevant - and certainly for businesses there must be a temptation to locate elsewhere where possibly property prices are lower? Transport infrastructure: Presumably you must have considered the impact of the plan upon the road and general transport infrastructure of the town, but the plan seems to have nothing to say about the transport infrastructure to support all this development (or if it does, I have failed to find it). As you will know only too well, Brentwood essentially has only one major road east-west, and one north-south, and even without blockages, travel across town can be extremely time-consuming and frustrating, particularly at rush hour - in addition reducing air quality in the town centre; and I know that in towns such as Cambridge, traffic congestion has caused a number of startups to abandon plans to locate in the city, and to move elsewhere. Proposals for significant further building in the town centre cannot but exacerbate the problem - and exacerbate it significantly. Developments on William Hunter Way and on the Wates Way Industrial Estate are particular cases in point, the latter in respect of the awkward junction between Burland Rd and Ongar Rd. I imagine you must have modelled likely capacity requirements and have proposals to address them? What were the outcomes of those investigations, and what specific plans are in place to relieve the congestion which will otherwise inevitably arise? Are you considering further road building (and if so, how much existing property will need to be demolished to make way for new or widened roads, and to what extent will this compromise what you are trying to achieve); and what provision is being made for public transport? Overall growth: I have had difficulty identifying the actual number of dwellings the plan envisages, since different numbers appear in different places in the document. So far as I can see, the plan calls for an additional 7600 houses over the period to 2033 - or possibly it calls for 9080. According to 2011 census information online, Brentwood had 30,600 households at that time. Assuming (generously) that this equates to 30,600 individual homes, this still appears to mean that the Brentwood district will grow over the next 15 years by approximately 25% - 30%, and it is impossible to imagine that this can do other than change the whole character of the area. Car parks: I am concerned at the number of Brentwood town-centre car parks which the plan envisages giving over to housing. What studies have you carried out to investigate the impact of this upon town-centre businesses, and what is the risk that this will simply drive shoppers away from Brentwood altogether? (And in the latter case, what is your estimate of the environmental impact of the additional travel?) Plans by Tesco: I realise that Tesco's plans to redevelop the Hopefield Animal Sanctuary site appear to be outside the scope of the plan. Nonetheless, they would certainly impact upon Brentwood town centre, and therefore upon the developments covered by the plan. Is planning permission likely to be given to Tesco? If so, how is it intended that the new development should be linked to existing roads, given that there are a number of schools along Sawyer's Hall Lane, and the area is already very congested at the start and end of the school day? And what impact would it have upon the council's own plan? Plans for the Ford Offices at Warley: I was unaware that this site might become available. Is Ford planning a closure off its own bat? And if the offices do close, has any assessment been made of the impact upon the local economy? Let us close by thanking you for your time in considering these issues. We look forward to any comments you can make to set our minds at rest.

Comment

Preferred Site Allocations 2018

Representation ID: 19155

Received: 11/03/2018

Respondent: Mr. & Mrs. ARA & CR Jamieson

Number of people: 2

Representation Summary:

I realise that Tesco's plans to redevelop the Hopefield Animal Sanctuary site appear to be outside the scope of the plan. Is planning permission likely to be given to Tesco? If so, how is it intended that the new development should be linked to existing roads, given that there are a number of schools along Sawyer's Hall Lane, and the area is already very congested at the start and end of the school day? And what impact would it have upon the council's own plan?

Full text:

I write on behalf of myself and my wife to register our serious concerns at the potential impact of the proposals embodied in the local plan. Before I begin, I should perhaps apologise if it turns out that I have based what follows on partial information, or on a misunderstanding of what is proposed. To some extent, I assume this must be the case, since in some areas (my first three bullet points below) the plan appears to be contradicting itself. I am assuming that the document of interest is the one headed 'Preferred Site Allocations 2018' - I have trawled through the website looking for other relevant information, and also in the hopes that there might actually be a shorter summary document, but have found neither. Regrettably I have struggled with this document because so much of it is given over to, what is for me, irrelevant minutiae relating to government policy; because different figures appear in different places; because it makes use of jargon and - my apologies - because the earlier portions are given over to meaningless platitudes. Anyway, assuming this is the correct document, I have a number of specific points : The introductory comments suggest state that 'People choose to live and work here because of the excellent transport links connecting us to London and the rest of the country, along with access to the surrounding countryside and green spaces' and also that 'A "borough of villages" will continue to be a defining characteristic of the area.' Green field and Green Belt development: I struggle to see how a plan which envisages significant building upon green-field sites can be reconciled with maintaining the bucolic charms which you see as an essential characteristic of the town; and nor do I see how the notion of a 'borough of villages' is enhanced by concreting over the gaps between them. There was a time - I believed - when the green belt was supposed to be sacrosanct, but I presume this is no longer the case. My concern is not simply the present intention to build within the Green Belt, but the inevitable precedent this sets. I presume the argument runs that we would be building only / mainly on Green Belt sites which are already compromised by existing development. But in so doing, yet more land will be compromised - paving the way for the same argument to be repeated forever, while the Green Belt steadily vanishes under tarmac. Rail links: If we really believe that fast transport links are a major attractor, I cannot understand how a plan to build on the station car park can do anything other than undermine this. You may be able to get to London in twenty minutes from the station, but if your journey time to the station now takes twenty minutes more than before because you can't park there (longer if you have to travel early and there are no buses), surely the fact that the train is fast is irrelevant - and certainly for businesses there must be a temptation to locate elsewhere where possibly property prices are lower? Transport infrastructure: Presumably you must have considered the impact of the plan upon the road and general transport infrastructure of the town, but the plan seems to have nothing to say about the transport infrastructure to support all this development (or if it does, I have failed to find it). As you will know only too well, Brentwood essentially has only one major road east-west, and one north-south, and even without blockages, travel across town can be extremely time-consuming and frustrating, particularly at rush hour - in addition reducing air quality in the town centre; and I know that in towns such as Cambridge, traffic congestion has caused a number of startups to abandon plans to locate in the city, and to move elsewhere. Proposals for significant further building in the town centre cannot but exacerbate the problem - and exacerbate it significantly. Developments on William Hunter Way and on the Wates Way Industrial Estate are particular cases in point, the latter in respect of the awkward junction between Burland Rd and Ongar Rd. I imagine you must have modelled likely capacity requirements and have proposals to address them? What were the outcomes of those investigations, and what specific plans are in place to relieve the congestion which will otherwise inevitably arise? Are you considering further road building (and if so, how much existing property will need to be demolished to make way for new or widened roads, and to what extent will this compromise what you are trying to achieve); and what provision is being made for public transport? Overall growth: I have had difficulty identifying the actual number of dwellings the plan envisages, since different numbers appear in different places in the document. So far as I can see, the plan calls for an additional 7600 houses over the period to 2033 - or possibly it calls for 9080. According to 2011 census information online, Brentwood had 30,600 households at that time. Assuming (generously) that this equates to 30,600 individual homes, this still appears to mean that the Brentwood district will grow over the next 15 years by approximately 25% - 30%, and it is impossible to imagine that this can do other than change the whole character of the area. Car parks: I am concerned at the number of Brentwood town-centre car parks which the plan envisages giving over to housing. What studies have you carried out to investigate the impact of this upon town-centre businesses, and what is the risk that this will simply drive shoppers away from Brentwood altogether? (And in the latter case, what is your estimate of the environmental impact of the additional travel?) Plans by Tesco: I realise that Tesco's plans to redevelop the Hopefield Animal Sanctuary site appear to be outside the scope of the plan. Nonetheless, they would certainly impact upon Brentwood town centre, and therefore upon the developments covered by the plan. Is planning permission likely to be given to Tesco? If so, how is it intended that the new development should be linked to existing roads, given that there are a number of schools along Sawyer's Hall Lane, and the area is already very congested at the start and end of the school day? And what impact would it have upon the council's own plan? Plans for the Ford Offices at Warley: I was unaware that this site might become available. Is Ford planning a closure off its own bat? And if the offices do close, has any assessment been made of the impact upon the local economy? Let us close by thanking you for your time in considering these issues. We look forward to any comments you can make to set our minds at rest.

Object

Preferred Site Allocations 2018

Representation ID: 19192

Received: 12/03/2018

Respondent: Jason Davis

Representation Summary:

I Object to these plans because of the additional congestion and pollution this will cause and the additional pressure on the public services. There would also be large destruction to the local wildlife.

Full text:

I Object to these plans because of the additional congestion and pollution this will cause and the additional pressure on the public services. There would also be large destruction to the local wildlife.

Object

Preferred Site Allocations 2018

Representation ID: 19239

Received: 05/04/2018

Respondent: Ms Julie Landragin

Representation Summary:

6,000 new homes in bentwood will put an intolerable strain on the already creaking infrastructure in Brentwood.

Full text:

6,000 new homes in bentwood will put an intolerable strain on the already creaking infrastructure in Brentwood. The traffic jams especially along the Ongar road at Peak times are already unacceptable. The planning of housing on the Hopefield Animal Sanctuary site which has one road in and out, cannot have been carefully considered because the impact on the traffic when there are already Four schools along this road, will cause chaos. Parking in Brentwood at peak times is difficult. All the car parks are full. I cannot understand why then houses are going to be built on the William Hunter Way car park, so where are shoppers expected to park, this has to be a terrible decision. Brentwod is a small town! Most of the housing will be unaffordable for young people when flats are being sold currently for at least £350,000.!

Green belt land will be disappearing, traffic jams worse which in turn will lead to a decline in air quality, our open spaces we currently enjoy will be lost and our wildlife under threat which means a destruction in the quality of life for Brentwood's inhabitants. The only reason I can see for this badly planned housing strategy is that someone is going to be making a lot of money out of it.

I have no reservations in expressing my anger at Brentwood councils housing plans, they need to be rethought as a matter of urgency.

Comment

Preferred Site Allocations 2018

Representation ID: 19286

Received: 09/03/2018

Respondent: Ms. Isobel McGeever

Representation Summary:

The development potential of the land at Brentwood Community Hospital, and the benefits the removal of the site from the Green Belt through the Local Plan process could bring. Site plan and attached report outline a possible site which could be ready to come forward within 5-10 years of the plan. Site is currently within the greenbelt. The location of the site - close to the town centre - would allow for intensification within the area, assisting with the Brentwoods five-year land supply and overall housing targets.

Full text:

See Attached.

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 19287

Received: 10/03/2018

Respondent: Mr James Sullivan

Representation Summary:

1. Continued erosion of the green belt which can never be replaced. 2. The strain that over development will create for not only Brentwood but due to the location, for Basildons schools, roads,GPs and hospitals. 3. The increase in congestion to the A127 which is already a pollution hot spot.

Full text:

I object to these plans for the following reasons: 1. Continued erosion of the green belt which can never be replaced. 2. The strain that over development will create for not only Brentwood but due to the location, for Basildons schools, roads,GPs and hospitals. 3. The increase in congestion to the A127 which is already a pollution hot spot.

Object

Preferred Site Allocations 2018

Representation ID: 19302

Received: 03/03/2018

Respondent: Ms Liz Donald

Representation Summary:

The predicted increase in population of the area may well have slowed significantly since the result of the EU referendum in 2016. Net migration to the UK in 2017 showed the largest annual fall since records began. Therefore the predicted growth may not be necessary.

Full text:

Dear Council Leader,

I am a resident of Basildon Borough, a close neighbour to Brentwood, which will be affected by whatever local plan is adopted by Brentwood Council.

As such, I wish to object to your proposed ideas for the Local Plan as follows:

1. Building on Green Belt land. The Green Belt MUST always remain as such, and be protected, with no housing allowed. It is the lungs around Brentwood, Basildon and surrounding areas, but is also part of the lungs of the London metropolitan area.

National planning policy is clear that the Green Belt boundaries should only be altered in exceptional circumstances, and the need for housing does not constitute an exceptional circumstance.

Our local Green Belt is a haven for many varieties of wildlife. To name a few, there are hedgehogs, badgers, foxes, frogs, toads, newts, dormice, slow worms, bats, owls, birds of prey and smaller birds, all of which depend on the undisturbed country areas. They can migrate and inter-breed through the Green Belt corridor, but if parts of it are taken away for housing, populations will become isolated and, only able to inter-breed within a small area, will die out.

2. Any building allowed on Green Belt land will constitute a precedent for the future, and once built on, the Green Belt can never be replaced.

3. Green Belt is also required for peoples' leisure pursuits and for the education of our children. To be able to get out into the local countryside is to improve mental health. The more growth there is in the town, the more these are needed.
There have to be facilities for children to play: There have to be parks, sports facilities, community centres. Not enough of these exist at present, and with land being taken up by housing, where are they to go?

4. All brownfield sites must be used before any Green Belt is even considered - and there are plenty of brownfield sites around London and around the country as a whole. London has a much greater capacity to absorb population increases than the towns and villages around South Essex.

5. The predicted increase in population of the area may well have slowed significantly since the result of the EU referendum in 2016. Net migration to the UK in 2017 showed the largest annual fall since records began. Therefore the predicted growth may not be necessary.

6. I see that a new school is proposed for Dunton Hills, but this would not be sufficient to accommodate the total influx of children and local schools and colleges are already full.

7. A large percentage of workers from Brentwood commute into London to work. Where are you going to find the extra capacity on the already overcrowded trains? How will you create the extra parking needed at the station? What new employment opportunities will there be locally?

8. The influx of people will require at least one new hospital, and GP surgeries and dentists are already overstretched. How is this going to be addressed and where are you going to build the new hospital?
Care homes and retirement homes will need to be built. The current facilities will not be sufficient for any influx.

9. Putting all new migrants to the area in one place, i.e. a housing estate, could create ghettoes and cause conflict.

10. A large increase in population of the borough will irrevocably change the character of the town. Expansion will see all the towns and villages merging into one huge connurbation and we will end up as just another suburb of London.

Comment

Preferred Site Allocations 2018

Representation ID: 19318

Received: 06/03/2018

Respondent: Mr Geoff Sanders

Representation Summary:

The 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 a market signal uplift of 30% plus a contingency of 6% should be accepted, raising the annual build to 380. 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?

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: 19363

Received: 07/03/2018

Respondent: Mr John Berry

Number of people: 2

Representation Summary:

The effect of the UK leaving the EU has not been factored. We have yet to discover the number of residents in Brentwood who are dual nationals and entitled to reside in countries outside the UK. Taking into account medical, health and pharmacy workers, care home personnel and members of the professions together with retail outlet owners and their employees we estimate the number at between 3,000 and 4,000. If negotiations with the EU lead to an adverse effect on the UK economy dual citizens will leave.

Full text:

Dear Sirs,

Thank you for your letter of the 2nd February. We have carefully considered all documents relating to the Brentwood Development Plan.

The Plan which is fatally floored (for numerous reasons) must be re-visited we respectfully suggest to rectify errors and omissions.

The vast majority of building will be on Green Belt and we consider that the majority of houses will not be required in this area. Our observations and objections include the fact that more than 50% of the sites can be deemed de minimis development (where homes to be constructed total less than 5% of total development). Homes on these sites will be marketed in the price band of £1.5million to £2million pounds. Stratospherically beyond the reach of first time buyers or even purchasers assisted by the Bank of Mum and Dad.

Also, one might say fatally, the effect of the development termed Dunton Garden is misdescribed. It should be titled Dunton Pollution for the subsequent increase in vehicle numbers entering the A127 at the junction of the A 128 Brentwood Road. So close to a junction on that arterial road that is already so heavily polluted that Basildon Council intended to introduce a congestion charge. It is patently obvious that the two Councils concerned (Brentwood and Basildon) are in conflict. Basildon says too many vehicles use the A127 that there is a danger to health and Brentwood says let us allow another 10,000 vehicles or so onto this road. We would suggest that to endeavour to reduce the conflict you triple number of medical facilities in the Dunton development , this should assist in meeting demands caused by the dramatic increase in the number of vulnerable people, children and the elderly who will suffer asthma and respiratory disease.

Nobody of course knows when the vehicles arrive at the junction onto the A127 whether they will head left right or continue along the A128. However, this increase in traffic coupled with traffic from other sites including industrial/employment areas along the stretch of road leading to the junction with the M25 will no doubt increase levels of health harming pollutants that will overtake the whole area to include villages of Herongate and Ingrave and possibly even Brentwood town itself. It should be remembered that Schools and Care Homes are sited along the A128. The proposed development at Dunton completely ignores 2 critical facts (a) unless ALL housing is zoned as social housing the whole development will b unaffordable to first time purchasers.
Having tracked house prices in the Horndon area since the year 2000 a conservative estimate of house prices by 2030 would project to be £ 1million to £ 1.5 million pounds. Importantly (b) the only way these properties could be occupied by first time buyers would be through shared or joint ownership viz : with an aged parent or relative living in the property with a young couple which leads to further potential pollution additional victim and probably additional car owner , together with added strain on medical facilities.

Also and just as importantly the effect of the UK leaving the EU has not been factored into the Plan. We have yet to discover the number of residents in Brentwood who are dual nationals and entitled to reside in countries outside the UK. Taking into account medical, health and pharmacy workers, care home personnel and members of the professions together with retail outlet owners and their employees we estimate the number at between 3,000 and 4,000 (including dependents). The number for the whole of the UK exceeds five million(and rising). If negotiations with the EU lead to an adverse effect on the UK economy dual citizens will leave and settle in EU member states or indeed other countries of the World.

The Plan to concrete over the Green Belt and Farmland will have been proven to have been unnecessary yet lasting harm will have been inflicted on the people and their environment.

It is a fact that Developers are guilty of land banking, sitting on land where Planning Permission has been granted but failing to build, purely to increase profit through increase in land values.. Within the last 10 years these sites, if built upon, would have provided in excess of 800,000 homes in this Country. How many would have been affordable homes is a matter of conjecture, because the developers often inform Councils that they cannot afford to develop a site with the number of social units imposed, Councils are pressured to reduce the number of social dwellings planned originally.

Even when sites are developed the Builders are ensuring there are hardly any affordable houses built (see Report Guardian 5th March 2018). In Manchester none of the 14,667 homes in big developments granted Planning Permission in the last 2 years are set to be "affordable", Planning documents show - in direct contravention of its own rules and the Government's definition. In Sheffield where house prices grew faster last year than in any other UK city (but we would suggest Brentwood and Ingatestone would be closely behind). Only 97 out of 6,943 approved by Planners in 2016 and 2017 met the Government's affordable definition. That says homes must either be offered for social rent (often known as Council housing), or rented at no more than 80% of the local market rate. In Nottingham where the Council aims for 20% of new housing to be affordable just 3.8% of the units given the green light by Council Planners meet the definition. If Brentwood is not strict with developers the results will be the same as those mentioned (supra).

The Development Companies are responsible for shortage of housing in certain area, by drip feeding dwellings onto the market to increase house prices. This prevents , in particular, first time buyers from gaining a foot on the housing ladder. The dramatic decline in home ownership amongst the young does not lie with Parents or Grandparents but with people who control the supply of social housing.

The reasons set out in this communication should, we hope, send the Council (indeed all Councils) to review their respective Plans. They might consider halving the intended housing units to be built whilst leaving in position all infrastructure planned with medical facilities doubled to ensure all citizens timely access to health care and other amenities.

Yours faithfully,

Object

Preferred Site Allocations 2018

Representation ID: 19364

Received: 07/03/2018

Respondent: Mr John Berry

Number of people: 2

Representation Summary:

It is a fact that Developers are guilty of land banking, sitting on land where Planning Permission has been granted but failing to build, purely to increase profit through increase in land values. Developers also often inform Councils that they cannot afford to develop a site with the number of social units imposed, Councils are pressured to reduce the number of social dwellings planned originally. Even when sites are developed the Builders are ensuring there are hardly any affordable houses built. If Brentwood is not strict with developers new housing won't be affordable.

Full text:

Dear Sirs,

Thank you for your letter of the 2nd February. We have carefully considered all documents relating to the Brentwood Development Plan.

The Plan which is fatally floored (for numerous reasons) must be re-visited we respectfully suggest to rectify errors and omissions.

The vast majority of building will be on Green Belt and we consider that the majority of houses will not be required in this area. Our observations and objections include the fact that more than 50% of the sites can be deemed de minimis development (where homes to be constructed total less than 5% of total development). Homes on these sites will be marketed in the price band of £1.5million to £2million pounds. Stratospherically beyond the reach of first time buyers or even purchasers assisted by the Bank of Mum and Dad.

Also, one might say fatally, the effect of the development termed Dunton Garden is misdescribed. It should be titled Dunton Pollution for the subsequent increase in vehicle numbers entering the A127 at the junction of the A 128 Brentwood Road. So close to a junction on that arterial road that is already so heavily polluted that Basildon Council intended to introduce a congestion charge. It is patently obvious that the two Councils concerned (Brentwood and Basildon) are in conflict. Basildon says too many vehicles use the A127 that there is a danger to health and Brentwood says let us allow another 10,000 vehicles or so onto this road. We would suggest that to endeavour to reduce the conflict you triple number of medical facilities in the Dunton development , this should assist in meeting demands caused by the dramatic increase in the number of vulnerable people, children and the elderly who will suffer asthma and respiratory disease.

Nobody of course knows when the vehicles arrive at the junction onto the A127 whether they will head left right or continue along the A128. However, this increase in traffic coupled with traffic from other sites including industrial/employment areas along the stretch of road leading to the junction with the M25 will no doubt increase levels of health harming pollutants that will overtake the whole area to include villages of Herongate and Ingrave and possibly even Brentwood town itself. It should be remembered that Schools and Care Homes are sited along the A128. The proposed development at Dunton completely ignores 2 critical facts (a) unless ALL housing is zoned as social housing the whole development will b unaffordable to first time purchasers.
Having tracked house prices in the Horndon area since the year 2000 a conservative estimate of house prices by 2030 would project to be £ 1million to £ 1.5 million pounds. Importantly (b) the only way these properties could be occupied by first time buyers would be through shared or joint ownership viz : with an aged parent or relative living in the property with a young couple which leads to further potential pollution additional victim and probably additional car owner , together with added strain on medical facilities.

Also and just as importantly the effect of the UK leaving the EU has not been factored into the Plan. We have yet to discover the number of residents in Brentwood who are dual nationals and entitled to reside in countries outside the UK. Taking into account medical, health and pharmacy workers, care home personnel and members of the professions together with retail outlet owners and their employees we estimate the number at between 3,000 and 4,000 (including dependents). The number for the whole of the UK exceeds five million(and rising). If negotiations with the EU lead to an adverse effect on the UK economy dual citizens will leave and settle in EU member states or indeed other countries of the World.

The Plan to concrete over the Green Belt and Farmland will have been proven to have been unnecessary yet lasting harm will have been inflicted on the people and their environment.

It is a fact that Developers are guilty of land banking, sitting on land where Planning Permission has been granted but failing to build, purely to increase profit through increase in land values.. Within the last 10 years these sites, if built upon, would have provided in excess of 800,000 homes in this Country. How many would have been affordable homes is a matter of conjecture, because the developers often inform Councils that they cannot afford to develop a site with the number of social units imposed, Councils are pressured to reduce the number of social dwellings planned originally.

Even when sites are developed the Builders are ensuring there are hardly any affordable houses built (see Report Guardian 5th March 2018). In Manchester none of the 14,667 homes in big developments granted Planning Permission in the last 2 years are set to be "affordable", Planning documents show - in direct contravention of its own rules and the Government's definition. In Sheffield where house prices grew faster last year than in any other UK city (but we would suggest Brentwood and Ingatestone would be closely behind). Only 97 out of 6,943 approved by Planners in 2016 and 2017 met the Government's affordable definition. That says homes must either be offered for social rent (often known as Council housing), or rented at no more than 80% of the local market rate. In Nottingham where the Council aims for 20% of new housing to be affordable just 3.8% of the units given the green light by Council Planners meet the definition. If Brentwood is not strict with developers the results will be the same as those mentioned (supra).

The Development Companies are responsible for shortage of housing in certain area, by drip feeding dwellings onto the market to increase house prices. This prevents , in particular, first time buyers from gaining a foot on the housing ladder. The dramatic decline in home ownership amongst the young does not lie with Parents or Grandparents but with people who control the supply of social housing.

The reasons set out in this communication should, we hope, send the Council (indeed all Councils) to review their respective Plans. They might consider halving the intended housing units to be built whilst leaving in position all infrastructure planned with medical facilities doubled to ensure all citizens timely access to health care and other amenities.

Yours faithfully,

Object

Preferred Site Allocations 2018

Representation ID: 19365

Received: 07/03/2018

Respondent: Mr John Berry

Number of people: 2

Representation Summary:

The Development Companies are responsible for shortage of housing in certain area, by drip feeding dwellings onto the market to increase house prices. This prevents , in particular, first time buyers from gaining a foot on the housing ladder. The dramatic decline in home ownership amongst the young does not lie with Parents or Grandparents but with people who control the supply of social housing.

Full text:

Dear Sirs,

Thank you for your letter of the 2nd February. We have carefully considered all documents relating to the Brentwood Development Plan.

The Plan which is fatally floored (for numerous reasons) must be re-visited we respectfully suggest to rectify errors and omissions.

The vast majority of building will be on Green Belt and we consider that the majority of houses will not be required in this area. Our observations and objections include the fact that more than 50% of the sites can be deemed de minimis development (where homes to be constructed total less than 5% of total development). Homes on these sites will be marketed in the price band of £1.5million to £2million pounds. Stratospherically beyond the reach of first time buyers or even purchasers assisted by the Bank of Mum and Dad.

Also, one might say fatally, the effect of the development termed Dunton Garden is misdescribed. It should be titled Dunton Pollution for the subsequent increase in vehicle numbers entering the A127 at the junction of the A 128 Brentwood Road. So close to a junction on that arterial road that is already so heavily polluted that Basildon Council intended to introduce a congestion charge. It is patently obvious that the two Councils concerned (Brentwood and Basildon) are in conflict. Basildon says too many vehicles use the A127 that there is a danger to health and Brentwood says let us allow another 10,000 vehicles or so onto this road. We would suggest that to endeavour to reduce the conflict you triple number of medical facilities in the Dunton development , this should assist in meeting demands caused by the dramatic increase in the number of vulnerable people, children and the elderly who will suffer asthma and respiratory disease.

Nobody of course knows when the vehicles arrive at the junction onto the A127 whether they will head left right or continue along the A128. However, this increase in traffic coupled with traffic from other sites including industrial/employment areas along the stretch of road leading to the junction with the M25 will no doubt increase levels of health harming pollutants that will overtake the whole area to include villages of Herongate and Ingrave and possibly even Brentwood town itself. It should be remembered that Schools and Care Homes are sited along the A128. The proposed development at Dunton completely ignores 2 critical facts (a) unless ALL housing is zoned as social housing the whole development will b unaffordable to first time purchasers.
Having tracked house prices in the Horndon area since the year 2000 a conservative estimate of house prices by 2030 would project to be £ 1million to £ 1.5 million pounds. Importantly (b) the only way these properties could be occupied by first time buyers would be through shared or joint ownership viz : with an aged parent or relative living in the property with a young couple which leads to further potential pollution additional victim and probably additional car owner , together with added strain on medical facilities.

Also and just as importantly the effect of the UK leaving the EU has not been factored into the Plan. We have yet to discover the number of residents in Brentwood who are dual nationals and entitled to reside in countries outside the UK. Taking into account medical, health and pharmacy workers, care home personnel and members of the professions together with retail outlet owners and their employees we estimate the number at between 3,000 and 4,000 (including dependents). The number for the whole of the UK exceeds five million(and rising). If negotiations with the EU lead to an adverse effect on the UK economy dual citizens will leave and settle in EU member states or indeed other countries of the World.

The Plan to concrete over the Green Belt and Farmland will have been proven to have been unnecessary yet lasting harm will have been inflicted on the people and their environment.

It is a fact that Developers are guilty of land banking, sitting on land where Planning Permission has been granted but failing to build, purely to increase profit through increase in land values.. Within the last 10 years these sites, if built upon, would have provided in excess of 800,000 homes in this Country. How many would have been affordable homes is a matter of conjecture, because the developers often inform Councils that they cannot afford to develop a site with the number of social units imposed, Councils are pressured to reduce the number of social dwellings planned originally.

Even when sites are developed the Builders are ensuring there are hardly any affordable houses built (see Report Guardian 5th March 2018). In Manchester none of the 14,667 homes in big developments granted Planning Permission in the last 2 years are set to be "affordable", Planning documents show - in direct contravention of its own rules and the Government's definition. In Sheffield where house prices grew faster last year than in any other UK city (but we would suggest Brentwood and Ingatestone would be closely behind). Only 97 out of 6,943 approved by Planners in 2016 and 2017 met the Government's affordable definition. That says homes must either be offered for social rent (often known as Council housing), or rented at no more than 80% of the local market rate. In Nottingham where the Council aims for 20% of new housing to be affordable just 3.8% of the units given the green light by Council Planners meet the definition. If Brentwood is not strict with developers the results will be the same as those mentioned (supra).

The Development Companies are responsible for shortage of housing in certain area, by drip feeding dwellings onto the market to increase house prices. This prevents , in particular, first time buyers from gaining a foot on the housing ladder. The dramatic decline in home ownership amongst the young does not lie with Parents or Grandparents but with people who control the supply of social housing.

The reasons set out in this communication should, we hope, send the Council (indeed all Councils) to review their respective Plans. They might consider halving the intended housing units to be built whilst leaving in position all infrastructure planned with medical facilities doubled to ensure all citizens timely access to health care and other amenities.

Yours faithfully,

Object

Preferred Site Allocations 2018

Representation ID: 19379

Received: 12/03/2018

Respondent: Karen Jordan

Representation Summary:

I object to these proposals because they will impact upon and destroy much needed Green Belt land and add congestion and pollution to an area suffering in those departments already and do not wish to see unneeded developments built.

Full text:

I object to these proposals because they will impact upon and destroy much needed Green Belt land and add congestion and pollution to an area suffering in those departments already and do not wish to see unneeded developments built.

Object

Preferred Site Allocations 2018

Representation ID: 19404

Received: 09/03/2018

Respondent: Mr Paul Hawkins

Representation Summary:

The proposals, for housing, predominantly cater for many people that do not reside on this borough. BBC acknowledge that 80% of Brentwood population growth will be from people moving into the borough upto 2033.

Full text:

Please register my objection to this current consultation for the following reasons;

1. The proposals, for housing, predominantly cater for many people that do not reside on this borough. BBC acknowledge that 80% of Brentwood population growth will be from people moving into the borough upto 2033

2. There is absolutely no need to build on greenbelt and greenbelt is a constraint for housing targets.

3. Green Belt is a material constraint 'which may restrain the ability of an authority to meets its need'. As perhttp://planningguidance.communities.gov.uk/blog/guidance/housing-and-economic-land-availability-assessment/stage-5-final-evidence-base/

Object

Preferred Site Allocations 2018

Representation ID: 19416

Received: 12/03/2018

Respondent: Sinead Cleaves

Representation Summary:

I object to these proposals based on the reasons listed below: We should not be building on green belt and in doing so is setting precedent moving forward. Area is already congested. There is not the infrastructure to support such a large development such as schools, GPs etc. Safety and security fears over gypsy site.

Full text:

I object to these proposals based on the reasons listed below: We should not be building on green belt and in doing so is setting precedent moving forward. Area is already congested. There is not the infrastructure to support such a large development such as schools, GPs etc. Safety and security fears over gypsy site. I strongly object based on the above reasons

Object

Preferred Site Allocations 2018

Representation ID: 19426

Received: 11/03/2018

Respondent: Mr. Scott Fisher

Representation Summary:

Brentwoods infrastructure will not cope with the proposed development. The police station has closed, drug taking and mental health are on the increase. I travel to London daily and despite having trouble with my knee can never get a seat. This is due to overcrowding. Without major infrastructure investment, new school, police, transport changes this will not cope with additional housing. This will lead to higher crime, more drug taking and potential issues with our youth.

Full text:

I reject to these proposals not because of change but due to an infrastructure that will not cope. The police station has closed, drug taking and mental health are on the increase and further children will be affected. This is a danger that we would struggle to reverse. I also travel to London daily and despite having trouble with my knee can never get a seat, even as early as 5.47am, the trains coming out of London this year as well are becoming unsafe. This is due to overcrowding. Without major infrastructure investment, new school, police, transport changes this will not cope with additional housing. This will lead to higher crime, more drug taking and potential issues with our youth.

Object

Preferred Site Allocations 2018

Representation ID: 19429

Received: 14/03/2018

Respondent: Miss Ruth Robinson

Representation Summary:

The Council should look at the empty homes within the borough as a means of fulfilling the Councils housing needs.

Full text:

I totally understand the housing situation, but i would like to understand why the council and government doesn't do more with all the run down houses around Brentwood that are laying empty and an eyesore. I have 2 houses just doors down from my property and the environmental health told me there are many more. Surely if we paid attention to these and there are many, we would have places for people. Instead of cramming more houses in, which in turn takes away parking and will result in shops closing. Maybe the council should consider fixing some of the root cause, instead of adding more complexity.

Object

Preferred Site Allocations 2018

Representation ID: 19430

Received: 11/03/2018

Respondent: Mr and Mrs Simons

Representation Summary:

What is the use of a Plan that does not provide any infrastructure. With a large number of houses, there is an obvious need for shops, schools and other local amenities. In this case there e are no adequate access roads and no planned transport services. It needs a careful think to avoid a very poor development.

Full text:

What is the use of a Plan that does not provide any infrastructure. With a large number of houses, there is an obvious need for shops, schools and other local amenities. In this case there e are no adequate access roads and no planned transport services. It needs a careful think to avoid a very poor development.

Object

Preferred Site Allocations 2018

Representation ID: 19465

Received: 11/03/2018

Respondent: Mr. Ronald Gough

Representation Summary:

Object 1) because they do not take sufficient account of the extra infrastructure needs of roads, schools and medical amenities. 2) because they will have a detrimental effect on cherished green belt.

Full text:

I object to these proposals: 1) because they do not take sufficient account of the extra infrastructure needs of roads, schools and medical amenities. 2) because they will have a detrimental effect on cherished green belt.

Object

Preferred Site Allocations 2018

Representation ID: 19501

Received: 11/03/2018

Respondent: Mr. Ross McGill

Representation Summary:

I object to these proposals because traffic on the A127 is already far too congested at major points during the day- additional housing will only exacerbate the problem. The emissions are already illegal. Local services are few and far between- how will they cope with the additional influx of residents? Our primary schools are fully subscribed, with catchment areas diminishing year on year. Additional housing will only make this situation more untenable. Our schools cannot cope. The destruction of greenbelt land is unnecessary.

Full text:

I object to these proposals because traffic on the A127 is already far too congested at major points during the day- additional housing will only exacerbate the problem. The emissions are already illegal- I do not want to raise a young family with such high pollution levels. In addition, local services are few and far between- how will they cope with the additional influx of residents? Our primary schools are fully subscribed, with catchment areas diminishing year on year. Once again, additional housing will only make this situation more untenable. As a local primary school teacher, I can confidently say that our schools cannot cope. Furthermore, the destruction of greenbelt land is unnecessary.

Object

Preferred Site Allocations 2018

Representation ID: 19513

Received: 11/03/2018

Respondent: Paula Masters

Representation Summary:

I vehemently protest about any plans to build on Green Belt Land as it should be protect. There are no apparent plans to provide further health services with the new housing developments and insufficient thought has been given to the need for school places with the amount of housing proposed. Every new development should provide health and education facilities in addition to those already available. Brentwood is already at capacity and that new building developments should be minimised to maintain the culture and character of the borough that it currently enjoys.

Full text:

I vehemently protest about any plans to build on Green Belt Land. It has been allocated as Green Belt to protect it and if should, therefore, not be developed under any circumstances. I am pleased there are no plans to develop Doddinghurst any further as the village is already larger than most. The data about school numbers is incorrect as Essex County Council has agreed that Holly Trees Primary School cannot be developed to enable growth as the site is unsuitable. Warley Primary School on the other hand, is set to become 2FE and this is it represented in the plan. I am concerned that there are no apparent plans to provide further health services with the new housing developments and insufficient thought has been given to the need for school places with the amount of housing proposed. Every new development should provide health and education facilities in addition to those already available. However, overall I am concerned that Brentwood is already at capacity and that new building developments should be minimised to maintain the culture and character of the borough that it currently enjoys.

Object

Preferred Site Allocations 2018

Representation ID: 19528

Received: 12/03/2018

Respondent: Mrs. B Thomas

Representation Summary:

I object to these proposals, we need to preserve our greenbelt not ruin it. There are already too many cars on the road and no extra infrastructure, just more pollution. What extra resource are you giving to the local Hospital with all the new homes being built?

Full text:

I object to these proposals, we need to preserve our greenbelt not ruin it. There are already too many cars on the road and no extra infrastructure, just more pollution. What extra resource are you giving to the local Hospital with all the new homes being built?

Object

Preferred Site Allocations 2018

Representation ID: 19538

Received: 12/03/2018

Respondent: Ms Nichola Webber

Representation Summary:

Green Belt land is in place for the safety and environment of local residents. By building this number of homes pollution levels are only set to rise. Causing more problems for NHS. Much of this land is flooded. The cost of flood management will be too high for local councils to resolve. Existing traffic infrastructure will not cope. Encouragement to use public transport and bicycles by local councils whilst beneficial if the infrastructure is there for cycle and bus lanes. There are brown fields sites which should be used first.

Full text:

I object to these proposals because- 1. This involves using Green Belt land which is in place for the safety and environment of local residents. By building this number of homes polllution levels are only set to rise. Causing more problems for NHS wirh increased cases of asthma and other breathing difficulties. 2. Much of this land is flooded with runoff and by concreating over it local rivers and streams will not cope. Culverts in built up areas become silted and cause localised flooding. The cost of flood management will be too high for local councils to resolve. 3. existing traffic infrastructure will not cope with increase in number of cars. We are a nation of car users. Encouragement to use public transport and bicycles by local councils whilst beneficial if the infrastructure is there for cycle and bus lanes. will not change a car owning culture. Plus cyclists will be put off by the increased pollution for using cars to commute. 4. There are brown fields sites which should be used first. In Brentwood there are many empty offices which can be converted in affordable housing. Building 3-4 bedroom dedatched housing will not be afforded to first time buyers. Our green belt is precious and this blatant disregard for its purpose and the quality of that land. It is short sighted in long term and appears to be for the greed of others.

Object

Preferred Site Allocations 2018

Representation ID: 19562

Received: 12/03/2018

Respondent: Mr. Stuart Willsher

Representation Summary:

RS2 Properties Ltd has put forth 41 Shenfield Road as a potential site which could accommodate 21-46 dwellings in the first five years of the Plan period. This site should have been included in the plan as it supports the current NPPF consultation document in encouraging development of small sites as well as the councils spatial strategy. This site would help the council with achieving its 5-year housing supply. We welcome the opportunity to discuss the development of this site further.

Full text:

See Attached

Object

Preferred Site Allocations 2018

Representation ID: 19591

Received: 12/03/2018

Respondent: Turn2us

Agent: Strutt & Parker LLP

Representation Summary:

The site identified as 219 Land at Rayleigh Road, Hutton - should have been included in the Preferred Options Document. See attached document for a list of evidence prepared to support this site. The current proposed spatial strategy fails to ensure the sustainable growth of Hutton. The proposal to direct none of the Borough's housing need to Hutton is unjustified, and inconsistent with national policy. This site has potential to accommodate extra care accommodation.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19605

Received: 12/03/2018

Respondent: GL Hearn

Agent: GL Hearn

Representation Summary:

The Hopefield site is able to deliver up to 450 new homes which would contribute significantly towards helping the Council meet its local development needs. The proposals provide a new point of access between Doddinghurst Road and Sawyers Hall Lane to significantly improve accessibility and connectivity from Brentwood urban areas to the north and west, including Pilgrims Hatch, to the six schools along Sawyers Hall Lane. We recommend that the Hopefield site is allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not.

Full text:

Summary of comments These Representations are submitted to Brentwood Borough Council, on behalf of Tesco Stores Limited (who are the freeholder of land currently occupied by Hopefield Animal Sanctuary, Doddinghurst Road, Brentwood), in response to the Draft Local Plan Preferred Site Allocations Regulation 18 Consultation published in January 2018. This document provides our comments to the Draft Local Plan and makes the case for housing-led development at the Hopefield site. Our objective is to achieve a Housing-Led Allocation in the Local Plan (Reg 19 Consultation). Following the Council's sequential approach to identify sites, the Hopefield site represents a sustainable location for housing. It is situated at the heart of the A12 Corridor, adjoins the Brentwood urban area, and is close to the town centre, railway stations, bus stops and local schools and healthcare. The Council even considers the A12 Corridor as one of three potential locations for strategic growth, which demonstrates its sustainability credentials are not in question. Given that urban areas and brownfield site capacity has been exhausted, it is extremely likely that Brentwood will have to release additional land from the Green Belt for housing to meet their local development needs, in accordance with adopted and emerging national policy. In this respect, the Hopefield site is well defined by defendable boundaries and proposals for reinforced landscape planting will strengthen the eastern edge. Importantly, the proposals also maintain the existing role and function of the Green Belt and safeguard the green wedge / critical countryside gap between Brentwood and Shenfield urban areas. The Hopefield site is able to deliver up to 450 new homes which would contribute significantly towards helping the Council meet its local development needs. Beyond housing proposals, the indicative masterplan is also able to deliver a range of unparalleled community benefits: The proposals secure the long-term future of Hopefield Animal Sanctuary which is recognised as a valuable community asset. Hopefield Animal Sanctuary support the Tesco proposals for housing-led development including relocation of the sanctuary on-site and re-provision of grazing land off-site. The proposals provide a new point of access between Doddinghurst Road and Sawyers Hall Lane to significantly improve accessibility and connectivity from Brentwood urban areas to the north and west, including Pilgrims Hatch, to the six schools along Sawyers Hall Lane. This is achieved through the provision of a walk through which connects Doddinghurst Road to the northern end of Sawyers Hall Lane plus a pick-up and drop-off point with car park for 50 spaces. This element of the proposal would in turn lead to a range of related benefits: Improved accessibility to schools along Sawyers Hall Lane for pupils, parents, staff and visitors; Promoting walking and cycling to help address health and wellbeing issues; Less reliance on private car (in particular for local school trips and other local trips); Reduced congestion along Sawyers Hall Lane and Doddinghurst Road; Improved conditions in terms of safety, especially along Sawyers Hall Lane; Alleviation of some traffic congestion to allow for existing schools to expand to help meet future local needs, and achieve their own development and education ambitions. As part of discussions with local stakeholders, St Thomas School have told us of ambitions to expand by further 1/2 form at all levels and that our proposals would help support this aspiration to expand. These proposals are based on our detailed analysis of the local area and meetings with key stakeholders including schools located along Sawyers Hall Lane. Feedback to date has been positive and discussions are on-going. Our comments demonstrate that the Draft Local Plan is unsound, when tested against the National Planning Policy Framework (2012) as it is not positively prepared, not justified, not effective and not consistent with national policy. Most recent Government advice contained in the Draft NPPF (2018) issued on 05 March 2018 requires local planning authorities to adopt the Standard Methodology for calculating housing need. For Brentwood, this would increase the housing target from 380 dpa to 454 dpa, representing an extra 1,480 dwellings over the plan period from 2013-2033. As the Draft Local Plan only identifies supply for 8,263 dwellings this means the Council must identify land for an additional 817 dwellings. It therefore is our view that to address the shortcomings in plan preparation i.e. the evidence base is incomplete and not up to date (e.g. highways evidence is dated 2016) and the current assessment does not consider all the potential sites in a consistent or comprehensive manner. Notably the Council's site assessment does not consider each site on an individual basis and it only considers a limited set of sustainability criteria, with no regard to site specific proposals or benefits, so to identify extra housing sites the Council must restart the sites assessment process. We recommend that the Hopefield site is allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. Overall, the proposals at Hopefield would help address a range critical planning issues which Brentwood Borough Council is currently facing. We would be happy to further discuss proposals with the Council and stakeholders to towards achieving a Housing-Led Allocation. General Comment In summary, at this stage of the plan-making process, we consider that the 2018 DLP is unsound. The 2018 DLP, including supporting evidence base, is not positively prepared, justified, effective or consistent with national policy especially in respect of Paras.11, 36, 61, 74, 117, 134, 137 and 209. This is a serious matter and we recommend that Brentwood Borough Council thoroughly reviews the approach to plan-making in order to prepare a sound Local Plan. Housing Need - DLP ref: Housing Need - Paras. 38-45, and Para.67 The NPPF (2012) Para.14 and Draft NPPF (2018) Para.11 clearly state that LPAs should plan to meet local development needs and the Draft NPPF (2018) Para.61 states that such needs should be calculated using the Government's standard methodology. We therefore recommend that the Council plans to fully meet its local development needs, based on the Government' standard methodology, with sufficient flexibility to respond to rapid change. We recommend that the 2018 DLP increases its planned housing target from 380 dpa to 454 dpa. Over the 20 year plan period from 2013-2033 this increases the overall target from 7,600 dwellings to 9,080 dwellings. Therefore the target must increase by 1,480 dwellings. We recommend that the Council recognises that the standard methodology approach offers a range of local and national benefits. It ensures a consistent and fair approach is applied by all LPAs across the country, and it will help work towards achieving the national objective to provide 300,000 net housing additions each year in England. The application of the standard methodology approach, alongside duty-to-cooperate, should be considered by the Council as paramount importance to provide the basis of a sound Local Plan. By adopting this approach the Council would also save a disproportionate amount of time discussing objectively assessed need at the Local Plan examination. Overall we do not consider that Brentwood Borough Council has any excuse not to adopt the standard methodology approach for the purposes of plan-making. We recommend that the new Local Plan must plan for 9,080 dwellings rather than the 7,600 (currently set out in the 2018 DLP). This approach must be adopted for the new Local Plan to be sound. We recommend that the Council considers unmet needs of surrounding LPAs within the Local Plan. Site Assessment and Sustainability Appraisal - DLP ref: An Evolving Evidence Base - Para. 14-17 - DLP ref: Site Allocations - Evidence Base ref: Sustainability Appraisal - Evidence Base: Sustainability Appraisal - Reasonable Alternatives Briefing Note - Evidence Base: Preferred Site Allocations Site Selection Methodology and Summary of Outcomes -Working Draft We recommend that the site assessment process is revisited and undertaken in a consistent and comprehensive manner, and based on a complete evidence base. The Sustainability Appraisal scoring system completely fails to recognise the site specific benefits of the proposals at Hopefield. We recommend that a new site assessment is undertaken in light of the unique site specific factors relating to securing the future of Hopefield Animal Sanctuary and improved accessibility (including range of impacts relating to safety, school access and expansion). We consider that a new assessment would elevate the site to a position where site allocation would be fully justified. Finally, as previously reported to the Council, the Sustainability Appraisal, refers to the site at Hopefield as two sites: "024A" and "024B". This approach does not reflect the actual site opportunity, which we are promoting and which is under a single ownership. We recommend that Brentwood Borough Council recognise the site at Hopefield as a single site, not two sites. This point was raised in our 2015 and 2016 Representations but the Council still fails to recognise this matter. Overall we recommend that the whole site assessment (to inform the 2018 DLP) is undertaken again because the approach adopted by the Council is not sound. We recommend that the revised assessment is undertaken in a comprehensive and consistent manner so that all factors relevant to each site are acknowledged and all sites are considered individually. As a result of the new site assessment, we recommend that the site at Hopefield is identified as a Housing-Led Allocation. Spatial Strategy and Sequential Approach - DLP ref: Spatial Strategy - Paras. 29-37 - DLP ref: Settlement Hierarchy and Accommodating Growth - Para. 75 As discussed under Housing Need above, in accordance with national policy, we recommend that that Council plans for 454 dpa, not 380 dpa. We recommend as a result that additional sites for housing must be identified by the Council so that it can fully meet its local development needs. This approach must be adopted for the new Local Plan to be sound. Assuming that no more or a limited amount of land within the urban area can be identified and there is no or limited scope to accelerate delivery or increase densities, we recommend that Green Belt land represents the only solution to deliver more houses. We recommend that the Council recognises that the Hopefield site is part previously developed land as it contains a large single dwelling house. Further to this, the principle of activity is long established on site (through the animal sanctuary use and works and visitors on-site). In addition, the site is well-served by public transport. It is 2.2 km from Brentwood station and within 400m of four bus stops. We support transport corridor-led growth, which is promoted in the 2018 DLP, especially long the A12 Corridor. The sustainability credentials of this general location for growth are not in question. Furthermore, the settlement hierarchy set out in the 2018 DLP identifies Brentwood as the Main Town (in Category 1). Therefore we recommend that an additional sources of housing supply be identified at or adjoining Brentwood urban area. We recommend that the transport corridor led approach to new growth is preferred over further pursuing village growth in rural areas. Overall we recommend that an additional site within the A12 Corridor is bought forward for housing-led development. Given its location, adjoining Brentwood and in the heart of the A12 Corridor, combined with its PDL characteristics plus the unique benefits of the proposals relating to securing the long-term future of Hopefield and improving local accessibility and connectivity, the site at Hopefield must be identified as a Housing-Led Allocation in the new Local Plan. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. Housing Supply / Housing Led Allocations - DLP ref: Housing Supply - Paras. 51-56 - DLP ref: Housing Led Allocation - Paras. 57-68 Based on the fact that the 2018 DLP has identified a supply of 8,263 dwellings, to achieve the Government's standard methodology target of 454 dpa, we recommend that the Local Plan identifies land for an additional 817 dwellings. In terms of Green Belt sites for housing, and in respect of 2018 DLP Para. 67, we consider that the Hopefield site can provide "defendable" edges. Overall we recommend that the Hopefield site is added to Figure 9 of the 2018 DLP under "Green Belt Land - Edge of Brentwood Urban Area." The site has the capacity to deliver up to 450 new homes. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. The 2018 DLP does not include any comment on the five year housing supply position. The latest publication of a five year housing land supply assessment is from 2016. At present we consider that Brentwood cannot demonstrate a five year housing land supply and therefore is not fully aware of its pipeline or trajectory of future housing sites. Without this we consider the 2018 DLP is not flexible or cannot respond to any changes in housing delivery. Therefore the 2018 DLP is not sound because it is not positively prepared or consistent with national policy. We recommend an up to date five year housing land supply is prepared by the Council. Transport and Infrastructure Plan - DLP ref: Transport - no references - DLP ref: Infrastructure Planning - Para. 18 - DLP ref: Infrastructure Planning - Para. 76 - DLP ref: Primary Schools - Para 77-87 We consider that the 2018 DLP does not propose enough to improve the primary school provision situation. Therefore we recommended that the Hopefield site is proposed as a Housing-Led Allocation in the new Local Plan because it's allocation would contribute towards helping local schools expand. Vision - DLP ref: Vision - Para. 26 We recommend that the vision is not changed but the Local Plan is amended so that the Council plans to meet its local development needs of 454 dpa, not 380 dpa. This required the Local Plan to increase the housing target to 9,080 dwellings over the plan period, and based on an existing identified housing supply of 8,263 dwellings identify land for an additional 817 dwellings. Plan-Making and Evidence Base - DLP ref: Plan-Making - Para. 1 - DLP ref: An Evolving Evidence Base - Para. 7 Overall, the plan-making approach for the Brentwood Local Plan is not sound and is not justified or consistent with national policy. We recommend that the plan-making process is revisited by Brentwood Borough Council and that the new Local Plan is based on an up to date evidence base, justified site assessment and that the whole preparation process is consistent with national policy. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. We recommend that the Green Belt Review is undertaken to inform the new Local Plan, especially in relation to preferred site options for growth which are proposed to be released from the Green Belt. Therefore the site assessment process can only commence once an independent and objective Green Belt Review has been completed. Meeting Strategic Objectives - DLP ref: Para. 28 We note that the 2018 DLP sets out a total of 23 strategic objectives, of which 12 are new since the previous 2016 DLP. The site we are promoting at Hopefield contributes significantly towards the objectives (as detailed below in Table 1). Therefore we recommend that the Hopefield site is proposed as a Housing-Led Allocation the Local Plan Regulation 19 document. In conclusion, we recommend that the Hopefield site is identified as a Housing-Led Allocation because the proposals for the site make a major contribution toward the Council's strategic objectives. The allocation of the site would make a significant contribution towards helping meet local development needs which is required to make the Local Plan sound. We recommend that the Hopefield site should be allocated for development on its own merits, because of its unique range of community benefits, regardless of whether the overall housing target for Brentwood increases or not. (See attached for further evidence).

Object

Preferred Site Allocations 2018

Representation ID: 19607

Received: 12/03/2018

Respondent: Mr Jon Nicholls

Representation Summary:

We object to the planned housing need on the basis that it is insufficient to meet needs. Para 47 requires LPAs to boost significantly the supply of housing. Changes to the NPPF may require the Councils housing targets to increase. A cursory 'overprovision' of only 663 dwellings does not do enough to account for the significant upward housing. The current timetable is extremely ambitious - the deadline to take advantage of the transitional provisions could well be missed.

Full text:

In regards to Spatial Strategy: We object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations. Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver. We support the spatial strategy, as set out at paragraph 31, to focus upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with the NPPF (paragraphs 17 and 111). It is also in accordance with the draft policies in the new NPPF consultation proposals March 2018; Chapter 11 reinforces and strengthens this aim. However, we do not consider that the capacity of brownfield sites has been fully explored. The Site Assessment Methodology and Summary of Outcomes (January 2018) states that the approach was to prioritise using brownfield land first and then consider growth in settlements in terms of their relative sustainability linked to services and facilities. However, the process actually discounts sites where they are considered to be in an unsustainable location, which included sites in the Green Belt with no connecting boundary to an existing urban area, before considering the potential to exploit brownfield land. This has resulted in sites such as site 183 being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable. Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail. Paragraph 32 of the NPPF requires that: "...the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure". On this basis, it is considered that the site is sufficiently sustainable to support a small to mid-sized residential development. In regards to Dunton Hills Garden Village: We object to this policy to propose a new settlement to deliver 2,500 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged. We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF. It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example nearby Uttlesford District Council. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings. Adopting the lag of seven years and a Plan adoption date before the end of 2019 would mean there would be no deliveries on site until 2026. There are no circumstances that suggest that Dunton Hills Garden Village can deliver more quickly than the seven years recommended by the above research. As such, we object to the reliance on this site for such a large proportion of the Borough need and consider that a greater number of smaller sites should be allocated to allow for flexibility and earlier delivery. In regards to Housing Need: We object to the planned housing need on the basis that it is insufficient to meet the Borough's needs. Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The consultation document assumes a housing need of circa 380 dwellings per annum or 7,600 dwellings across the plan period (2013-33). However, the Department for Communities and Local Government consultation on the methodology for a standardised approach to calculating local housing need in England demonstrates a housing need of 454 dwellings per annum in Brentwood Borough, an increase of 74 dwellings per year over the planned figure. Whilst it is appreciated that under the current timetable the Borough are expecting to take advantage of the transitional provisions in the draft NPPF currently open for consultation, the Plan should nevertheless take account of Governments direction of travel. A cursory 'overprovision' of only 663 dwellings does not do enough to account for the significant upward housing pressure in the Borough. Whilst the transitional provisions currently open for consultation in the draft NPPF suggest that any plans submitted this year will be examined under the old (current) NPPF, the Brentwood Local Plan is still at a relatively early stage of production. We also consider the current timetable, which allows only six months to consider representations to the current consultation and publicise and submit the Regulation 19 Plan, to be extremely ambitious. As such, the deadline to take advantage of the transitional provisions could well be missed. In this instance, the Council will have to go back to Regulation 18 stage to consider the new housing need. However, planning for the higher housing need at this stage will enable for the Plan to continue to examination, even if this deadline is missed. The "fallback position", should the Council need to accommodate this significant increase in housing need, is consideration of whether the delivery of Dunton Hills Garden Village could be accelerated to increase its dwelling yield within the plan period. However, this has not been fully explored and, as set out in our comments in relation to the Dunton Hills allocation, the current anticipated delivery is ambitious, making accelerated delivery wholly unrealistic. Failing to meet the objectively assed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound. Notwithstanding the above objection to the quantum of the housing need, we also object to the proposed strategy to deliver this need. Figures 8 and 9 demonstrates how the housing need will be met. These show an intention to deliver 663 dwellings in excess of the identified need of 7,600 dwellings. However, this includes both a windfall allowance and "Forecast Forward - additional completions and permissions between 1st April 2017 and 31st March 2018". Both of these figures are uncertain and taken together total 757 which exceeds the 'overprovision' of 663 dwellings. The plan does not appear to include any non-implementation allowance, therefore, in order to meet the objectively assessed need every single extant consent, allocation, permitted development, plus the "forecast forward" and windfall allowance must come forward during the plan period in order to meet the minimum need requirement. As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF. In regards to Settlement Heirachy: Whilst we support the classification of Ingave as a "Category 3 - Large Village", we object to the inconsistent treatment
of this settlement in comparison to other settlements occupying the same level in the hierarchy. For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave. The moratorium of growth in these villages is contrary to the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities (paragraph 55). The new draft NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 80). Allocation of additional land for housing at Ingrave would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.

Object

Preferred Site Allocations 2018

Representation ID: 19610

Received: 12/03/2018

Respondent: Gladman Developments

Representation Summary:

The LDP should therefore increase its housing need included in the Plan to better reflect the Government's emerging agenda of solving the housing crisis. Several of the allocations which are proposed in the LDP are of a strategic scale and will take a considerable length of time to deliver. There is a need for the Council to establish realistic delivery timeframes and lead-in times whilst also having robust evidence to justify delivery rates on the sites.

Full text:

See Attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19617

Received: 12/03/2018

Respondent: Mr. Paul Webster

Representation Summary:

The land to the rear of Crossbby Close in Mountnessing was included in past drafts of the LDP, however has been removed from this version due to highway constraints. Evidence has been submitted as part of this response to support that sufficient access to the site can be achieved and therefore we are requesting that the Council reconsidered this site as an appropriate allocation for development.

Full text:

See attached