Housing Supply

Showing comments and forms 1 to 30 of 35

Support

Preferred Site Allocations 2018

Representation ID: 18253

Received: 12/03/2018

Respondent: CODE Development Planners Ltd

Agent: CODE Development Planners Ltd

Representation:

In our view, the Council has undertaken a robust and sound assessment of housing land supply and have continued to ensure that the evidence base is as up to date as possible and proportionate to the relevant stage of Local Plan preparation.

Full text:

In our view, the Council has undertaken a robust and sound assessment of housing land supply and have continued to ensure that the evidence base is as up to date as possible and proportionate to the relevant stage of Local Plan preparation.

Comment

Preferred Site Allocations 2018

Representation ID: 18279

Received: 12/03/2018

Respondent: Essex County Council

Representation:

Housing Need and Supply

Full text:

Housing Need and Supply -
ECC acknowledges BBC's work that seeks to meet housing needs in full over the Plan period (7,600/380 dpa) and supports the 20 year Plan period (2013 - 2033). This would deliver the Borough's housing need in full, and support the projected number of jobs/workers forecast in the Plan period. ECC supports the prioritisation of bringing forward brownfield sites and all appropriate land within existing urban areas, and through maximising density where appropriate. This will direct development towards existing settlements, particularly those that already benefit from access to a range of services and access to sustainable transport modes. However, in doing so any strategy will need to demonstrate that the level of growth can be accommodated by the existing and new social and physical infrastructure.

ECC acknowledges that BBC will need to be satisfied that the Local Plan is supported by a proportionate evidence base and that all reasonable alternatives have been considered.

Following its response to the 2016 consultation, ECC continues to seeks further clarification on a number of issues in relation to the proposed spatial strategy including:
* how the A127 Corridor provides more opportunities for growth than the A12 Corridor;
* identification of any cross border implications of the spatial strategy given its role as highway, education, minerals and waste, and lead local flood authority, and public health responsibilities;
* identification of what infrastructure is necessary to deliver the spatial strategy, strategic and individual site allocations; and
* a full assessment of the highway and transportation implications of the proposed spatial strategy, both in terms of the impacts of the individual preferred site allocations, and cumulatively.

ECC therefore withholds support until the appropriate highway modelling has been undertaken, to assess both the site specific and cumulative impacts of such developments on the local, and wider, highway network

Object

Preferred Site Allocations 2018

Representation ID: 18578

Received: 12/03/2018

Respondent: Joshua Campbell

Representation:

Householder need to upgrade by 200,000 pounds at least, this housing is not affordable for our younger generations

Full text:

1. The building of unaffordable houses for people and destroying Greenbelt for monetary gain for the developers is unacceptable & immoral. The LDP shows land miss represented as Brownfield when it is most certainly Greenbelt in the current house market, householder need to upgrade by 200,000 pounds at least, this housing is not affordable for our younger generations

2. Our precious greenbelt provides fresh air alleviating pollution from east the A127, as records show the A127 is exceeding levels of pollution & there is now talk of emission charge ! The woodland & Greenbelt are needed to counteract these pollution levels.

3. These areas have inhabitants of precious Wildlife & will be adversely affected & lost forever -sites of SSI are in place for a reason as is protected Greenbelt -this can not be the allocated

4.All of our facilities are stretched -overburdened roads , GP surgeries ,schools , hospitals -A127 , A128 & Billericay roads are at a standstill certain times of the day -roads are at breaking point . There is no infrastructure for these said unaffordable
Houses. The area is highly congested already causing pollution

5.The figures are completely manipulated why If this is a local plan it is common knowledge that the homes are for executive for those coming from outside if the area .

6.the actual numbers of houses needed is not quantifiable not necessary or needed with the EU brexit we have no idea how many people will be here after these figures you have grabbed we're prior to the referendum last year

Object

Preferred Site Allocations 2018

Representation ID: 18592

Received: 12/03/2018

Respondent: Ms Linda Campbell

Representation:

Object. Greenbelt should never be built on for monetary gain for developers.

Full text:

I object to this consultation as it is flawed figures are incorrect & Greenbelt is misrepresented on your plans I am looking to buy a house in the area I was brought up , this will be unaffordable for me .
The houses are for people coming in fro
Outside of the area NOT for local people like me -I am out priced from living i this area .
Greenbelt should never be built on for monetary gain for developers .
Our roads are overburdened it takes my over half an hour to get to West Horndon station from Billericay Rd !

Object

Preferred Site Allocations 2018

Representation ID: 18746

Received: 12/03/2018

Respondent: Ms Lise Spicer

Representation:

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

Full text:

I object to these proposals because

Infrastructure

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

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

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


Affordable Housing

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


Strain on NHS

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


The council has deliberately misled residents

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

Comment

Preferred Site Allocations 2018

Representation ID: 18808

Received: 27/03/2018

Respondent: Mr Nicholas Ashton

Representation:

If we are so desperate for housing, low density projects as Trueloves
Ingatestone would appear wasteful of much needed land not one of your best decisions.

Full text:

GENERAL

1 When planning permission is granted there should be strict use it or loose it time constraints As with The Crown development Ingatestone WELL DONE

2 If we are so desperate for housing .Low density projects as Trueloves
Ingatestone would appear wasteful of much needed land NOT ONE OF YOUR BEST DECISIONS

3 Provision of electric car charging points should be a consideration

4 There should be proactive action on empty properties and land banking

SPECIFIC PROPOSALS

I find putting forward BRENTWOOD RAILWAY CAR PARK misguided and strongly
object It is a most important facility at present and surely if the town and
its environs are to expand to rail use will also expand

INGATESTONE The surgery is at its limit now . Redrose ? the owners of the GARDEN
CENTRE have undertaken to make ONEOFF contributions to schools and health care
The problem at the doctors is getting staff , both nurses and doctors . They are overwhelmed at present with any more pressure almost certain to result in
departures and not recruitment

Comment

Preferred Site Allocations 2018

Representation ID: 18815

Received: 12/03/2018

Respondent: Mr Gary Duggan

Representation:

The so-called 'affordable housing scheme' unfortunately brings residents otherwise unable to afford to live the areas of development into that area, effectively degrading in some cases the location. Resident's work hard to attain status such as 'a nice area' so it should not be automatic that a mix should be provided. What is wrong with building a development of affordable properties only (I understand the social implications, but it works both ways).

Full text:

The biggest problem that residents object to is the perceived over development, i.e. loss of existing space and feel, and whilst that is a nice to have, that's why many people choose to live in Brentwood. The central Government plan (NPPF) should not be a carte blanche for ruining towns and local areas, hence the local consultation should be listened to with a higher priority.

1. The access roads (including Parking), Schools, and Healthcare facilities are already over burdened, so they should be improved first even if it means we enjoy a better (relative) service for a while whilst building catches up). Most will argue these services have declined in the last decade(s), hence the relative anger over expansion plans.

2. So improve infrastructure ahead of development, and building companies should make less profits whilst providing housing; helping to fund these improvements.

3. The planning LDP is dependent on other agencies to provide infrastructure improvements, so these agencies (Transport (roads trains etc), Healthcare (NHS), Police, ) should have plans firmly linked to the Brentwood LDP.

4. I believe that residents are already stretched in terms of services provided and need solid assurances that they will not further deteriorate.

5. Each preferred site location needs a linked plan of how its growth or new presence will affect residents and then how it will be solved. This will avoid objections at actual planning time.

6. The so-called 'affordable housing scheme' unfortunately brings residents otherwise unable to afford to live the areas of development into that area, effectively degrading in some cases the location. Resident's work hard to attain status such as 'a nice area' so it should not be automatic that a mix should be provided. What is wrong with building a development of affordable properties only (I understand the social implications, but it works both ways).

Object

Preferred Site Allocations 2018

Representation ID: 18864

Received: 28/03/2018

Respondent: Mr & Mrs Dennis & Diane Rensch

Representation:

We are aware of the proposed building sites in the vicinity of Sawyers Hall Lane an area which is already over congested due to traffic and excess building and recent building and planning proposals eg schools, Sawyers Hall Church and the Local Plan which includes Wates Way.

Full text:

Having reviewed the documents we have found it necessary to respond once again as residents living around Sawyers Hall Lane, Bremtwood.
We are aware of the proposed building sites in the vicinity of Sawyers Hall Lane an area which is already over congested due to traffic and excess building and recent building and planning proposals eg schools, Sawyers Hall Church and the Local Plan which includes Wates Way.
Our concerns are two fold:
1. Wates Way. Unless sensible traffic control measures are put in place this will mean Sawyers Hall Lane and Burland Road being used as a 'Rat Run' to access the new housing site and eventually the new estate. As the residents of Brenwood North we have not been listened to in the past especially by the Highways Department, the situation in an already congested Sawyers Hall Lane and we might add a dangerous road will become worse.
2. Hopefield Animal Sanctuary, Sawyers Hall Lane. At the moment Tesco's the owner of the this land are applying pressure to sell the land for housing. Although we note this land is not currently a site proposed for development within the Local Plan we have a fear that as the Council are under pressure from Central Government to find building sites this will be all too easy to be considered as a viable option. The consequences are a road being cut thorough at the end of Sawyers Lane to access any potential site, taken account it would also be a convenient route in gaining access and joining up with the proposed development either side of Doddinghurst Road.
We therefore ask you give serious consideration to our concerns.

Object

Preferred Site Allocations 2018

Representation ID: 18866

Received: 28/03/2018

Respondent: Mr & Mrs Dennis & Diane Rensch

Representation:

Hopefield Animal Sanctuary, Sawyers Hall Lane. At the moment Tesco's the owner of the this land are applying pressure to sell the land for housing. Although itis not currently a site proposed for development within the Local Plan we have a fear that as the Council are under pressure from Central Government to find building sites this will be considered as a viable option. The consequences are a road being cut thorough at the end of Sawyers Lane to access any potential site, taken account it would also be a convenient route in gaining access and joining up with the proposed development either side of Doddinghurst Road.

Full text:

Having reviewed the documents we have found it necessary to respond once again as residents living around Sawyers Hall Lane, Bremtwood.
We are aware of the proposed building sites in the vicinity of Sawyers Hall Lane an area which is already over congested due to traffic and excess building and recent building and planning proposals eg schools, Sawyers Hall Church and the Local Plan which includes Wates Way.
Our concerns are two fold:
1. Wates Way. Unless sensible traffic control measures are put in place this will mean Sawyers Hall Lane and Burland Road being used as a 'Rat Run' to access the new housing site and eventually the new estate. As the residents of Brenwood North we have not been listened to in the past especially by the Highways Department, the situation in an already congested Sawyers Hall Lane and we might add a dangerous road will become worse.
2. Hopefield Animal Sanctuary, Sawyers Hall Lane. At the moment Tesco's the owner of the this land are applying pressure to sell the land for housing. Although we note this land is not currently a site proposed for development within the Local Plan we have a fear that as the Council are under pressure from Central Government to find building sites this will be all too easy to be considered as a viable option. The consequences are a road being cut thorough at the end of Sawyers Lane to access any potential site, taken account it would also be a convenient route in gaining access and joining up with the proposed development either side of Doddinghurst Road.
We therefore ask you give serious consideration to our concerns.

Object

Preferred Site Allocations 2018

Representation ID: 18867

Received: 28/03/2018

Respondent: Ms Denise Brien

Representation:

The Council Office and the former Police Station sites are not mentioned - are these already decided? The land in Ingrave Road which was formerly Warwick Wright has been standing empty for years.

Full text:

I am writing regarding this and am unable to copy your form to this email - perhaps I am too late for commenting.
My comments are one of alarm at the number of sites you have noted in the plan. Hopefully not all will come to pass. It seems to me that a lot of these proposed sites take no account of the extra traffic and therefore congestion which would be caused. The developments at Warley, Fords, Mascalls Lane would cause severe pressure on Mascalls Lane itself - it already suffers from greatly increased traffic from the Warley Hospital developments. Most of the town centre proposals would also cause congestion and if car parks are developed where is parking to be provided for those residents and visitors.
While I appreciate that there is a need for housing in this country due to increases in the population I feel it is necessary that it is done so as not to destroy the country and the quality of life most of us are lucky to have. London and the south east always seem to bear to brunt of mass building you only have to look at London on leaving Liverpool Street for that!!
Some the proposed sites seem to be taking greenfield or woods into the development area which is unnecessary. We have many brownfield sites which should be used first. I understand the Campaign to Protect Rural England has listed sites throughout the country which could provide about 1 million homes. Will there be more roads to accommodate extra traffic, more schools, healthcare services, buses and trains and, perhaps, more importantly - jobs? I note some of the sites take industrial areas into being developed for homes. I know a great deal is done on the internet but there will surely be a need for other types of work.
While not agreeing with a lot in the plan it is good that a plan is being prepared as I saw a programme which showed what happens if local councils do not have one or update one. We are lucky to live in Brentwood which still has country parks and green areas - at the moment - but I think most people would be unhappy to see it turned into a Romford and Ilford which I think looks like a mini-Manhattan!
I note that the Council Office and the former Police Station sites are not mentioned - are these already decided? The land in Ingrave Road which was formerly Warwick Wright has been standing empty for years.
I do not think this huge planned development of 300,000 homes a year is realistic bearing in mind the infrastructure that has to go with it. Also will it really end bearing in mind the figures suggesting 200,000+ (net) people are migrating to the UK every year!

Object

Preferred Site Allocations 2018

Representation ID: 19241

Received: 05/04/2018

Respondent: Ms Julie Landragin

Representation:

Most of the housing will be unaffordable for young people when flats are being sold currently for at least £350,000!

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.

Object

Preferred Site Allocations 2018

Representation ID: 19319

Received: 06/03/2018

Respondent: Mr Geoff Sanders

Representation:

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?

Full text:

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

Comment

Preferred Site Allocations 2018

Representation ID: 19374

Received: 12/03/2018

Respondent: Mr Julian How

Representation:

In my view, what is required is affordable rental homes and that would be best achieved in the form of Council House developments. I would urge the Council to consider doing this particularly in the larger areas, scubas east of Shenfield and in the sites around the A127. We need to try and bring a younger population into the area and this can only be done if the properties are both affordable and rental ones.

Full text:

I respond to the Local Development Plan Consultation. I have looked at the proposed development areas that are set out in the Plan. The plan envisages significant additional housing in the area. No mention seems to be made as to the type of housing proposed. I have to say that, in my view, what is required is affordable rental homes and that would be best achieved in the form of Council House developments. I would urge the Council to consider doing this particularly in the larger areas, scubas east of Shenfield and in the sites around the A127. But coming to the plan itself, where I feel that it falls short is that it does not contain any infrastructure planning to support the increase in population that the developments will bring. Most of the developments are 'out of town' which will bring significantly increased traffic and there is nothing that I can see to improve the roads and to remove bottlenecks. The roads are already overloaded. Furthermore, there is nothing that I can see planned to create additional parking both for commuters and shoppers. As it is, existing car parks are already full. What is worse is that your plan actually proposes to use existing car parks for housing, particularly in Brentwood where these car parks are, in my experience, fully utilised. Until such time as replacement and increased parking has been dealt with I would urge the Council not to develop the area further. Of course, increasing housing will not only change the character of the area but will bring consequential air and noise pollution. Crossrail will inevitably bring such of that and I would urge the Council to quantify the impact of Crossrail first before embarking on such an ambitious housing project. And finally, I would urge the Council to ensure that most of the housing development that does go ahead is for truly affordable housing which, in my opinion, has to be Council rental property. We need to try and bring a younger population into the area and this can only be done if the properties are both affordable and rental ones.

Object

Preferred Site Allocations 2018

Representation ID: 19395

Received: 10/03/2018

Respondent: Suzanne Kissin

Representation:

Environmentally speaking, building all these extra houses will have a detrimental impact, bringing more traffic into the area (and therefore more pollution) and the actual process of the building work itself will also create pollution. Roads do not have the capacity to take all these extra vehicles which will be inevitable with so many extra households. Our public transport is also not efficient enough to cope. Greentbelt should be protected and not developed.

Full text:

I object to these proposals because our green belt is precious and valuable. Environmentally speaking, building all these extra houses will have a detrimental impact, bringing more traffic into the area (and therefore more pollution) and the actual process of the building work itself will also create pollution. Then we will have to take into account the carbon footprint left by all the people living in those new houses, every time they use electricity or turn their heating on and every time they have their black sack rubbish collected and taken to landfill. I also object because our roads do not have the capacity to take all these extra vehicles which will be inevitable with so many extra households. Our public transport is also not efficient enough to cope.

Object

Preferred Site Allocations 2018

Representation ID: 19594

Received: 10/03/2018

Respondent: Mr George Tuck

Representation:

Brentwood has understandably grown to become a commuter town and positively affected the community in many ways. However many homes that are being built across Brentwood are profit based houses that will cause a great deal of alienation with a vast majority of the towns working and middle class polulation. Over the last 30-40 years none of the Council homes sold off under the Right to buy were ever replaced. With less and less Council homes being replaced by unaffordable homes, many people are being pushed out. The town is unaffordable for the working and middle class.

Full text:

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

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

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

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

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

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

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

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

I look forward to hearing from you.

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 19596

Received: 10/03/2018

Respondent: Mr George Tuck

Representation:

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

Full text:

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

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

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

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

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

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

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

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

I look forward to hearing from you.

Attachments:

Comment

Preferred Site Allocations 2018

Representation ID: 19649

Received: 12/03/2018

Respondent: JTS Partnership LLP

Representation:

The Council received a number of representations, in relation to the 2016 Draft Local Plan, to the effect that there was a lack of information about the site assessment methodology and overall SHLAA / HELAA. This situation has not changed, such that it is not possible, on the basis of the information published on the Council's website, to make a meaningful assessment of the merits of the proposed site allocations or the sites which have been rejected by the Council.

Full text:

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

Support

Preferred Site Allocations 2018

Representation ID: 19661

Received: 12/03/2018

Respondent: Chilmark Consulting Limited

Representation:

Barwood Land and Estates (BLEL) support paragraph 54 (page 22) of the Local Plan that is concerned with the supply of housing sites. BLEL agree that it is appropriate to review, test and evaluate (and discount where necessary) a wide range of housing sites through the HELAA process. The process undertaken has been thorough in identifying potential sites and in evidencing those selected for allocation in the Plan.

Full text:

This representation is made on behalf of our client, Barwood Land and Estates Ltd.
Barwood Land and Estates (BLEL) support the proposed allocation of Land at Honeypot Lane, Brentwood (reference 022) as a Brentwood Urban Area, A12 Corridor Urban Extension as set out at page 77 of the Local Plan. The proposed allocation follows the settlement hierarchy and proposed spatial distribution of housing set out in other plan policies and objectives. BLEL support the proposed housing allocation of Land at Honeypot Lane but raise a number of more specific comments as follows: BLEL consider that Land at Honeypot Lane has an indicative development capacity for >200 dwellings based on masterplanning and detailed site analysis/testing undertaken to date by BLEL and shared with the Borough Council. The proposed allocation information should therefore be updated accordingly for up to 250 dwellings total. The next iteration of the Local Plan Sustainability Appraisal should also take this quantum into account. BLEL note that the Honeypot Lane site is also identified as a potential location for a C2 Use Class care home and query where this indicative land use proposal originates as it has not been proposed to the Borough Council or discussed with BLEL as the development promoter to date. The reference to C2 Care Home appears to refer to paragraph 9.2.5 of the Interim Sustainability Appraisal Report that notes that there is a potential for some 40 bed space C2 Use Class provision for the site and itself purports to draw this from the latest version of the Borough's Strategic Housing Market Assessment. Land at Honeypot Lane is described as a 'self-contained urban extension' but clearly the development would be integrated with Brentwood and particularly with surrounding areas including St Faiths Country Park. Indeed, the site's location supports the potential for a high degree of integration rather than self-containment. BLEL suggest that the wording of the Local Plan text be modified accordingly in this respect. With respect to housing delivery, BLEL consider that Land at Honeypot Lane is capable of delivery within the five year period rather than in the longer 5-10 year period. The site is suitable, available and achievable and has a willing landowner, developer and investor. The potential for early delivery in the plan period has been discussed with the Borough Council and BLEL suggest that the Local Plan text be updated to reflect the ability to bring this site forward early in the plan period. Barwood Land and Estates support the Spatial Strategy shown in Figure 5 (page 17). The Spatial Strategy shows a realistic overall distribution of growth. It focuses on sustainable urban locations and the best opportunities for Green Belt release in/adjacent to existing higher order settlements in order to meet identified housing and economic growth objectives of the Local Plan. Barwood Land and Estates (BLEL) support the proposed Housing-led Allocation set out in Figure 9 (pages 26 - 27). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. Land at Honeypot Lane is a sustainable location and a deliverable housing site within the urban area of Brentwood. The site can come forward early in the Plan period without the need for extensive new infrastructure. Release of the site from the Green Belt will ensure development can be achieved in a timely manner and that this site can contribute to supplying much needed new housing in Brentwood. BLEL has undertaken an extensive and detailed technical and design analysis of the Honeypot Lane site and has concluded that the site is capable of delivering more than 200 dwellings without causing adverse effects on highways, landscape, amenity or other matters. BLEL has previously shared this analysis with the Borough Council. On this basis BLEL consider that the site is capable of sustainably accommodating up to 250 dwellings and the Local Plan should be updated accordingly at Figure 9 (and elsewhere where the Plan identifies a proposed allocation quantum for the site) to reflect this. Barwood Land and Estates (BLEL) support the proposed Settlement Hierarchy set out in Figure 14 (page 35). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. The proposed settlement hierarchy represents the current pattern of activity and forms a realistic approach to guiding future sustainable development patterns of activity and land use in the Borough. The hierarchy clearly and appropriately identifies Brentwood, Shenfield, Hutton, Warley, Brook Street and Pilgrims Hatch as 'Category 1 - Main Towns'. Barwood Land and Estates (BLEL) has reviewed the Interim Sustainability Appraisal Report (SA)
that supports the Local Plan Site Allocations and has the following comments with respect to paragraphs 10.5.4 (page 44); 10.10.2 (page 52); and the Site Appraisal of BLEL's site and Honeypot Lane, Brentwood (022) on page 81. Paragraph 10.5.4 (page 44) BLEL note that the Honeypot Lane site is proposed for a reduced level of housing (200 dwellings compared to 250 dwellings) when comparing the current Site Allocations Plan with the previous 2016 draft Local Plan. BLEL are not aware of any site specific reason why there should be a reduction and have considers (based on extensive technical assessments and site masterplanning that the site should be allocated for up to 250 dwellings. The SA should therefore be updated and revised accordingly in this respect. BLEL agree with the SA at 10.5.4 that the Land at Honeypot Lane site is associated with an opportunity to support enhanced pedestrian links through St Faiths Country Park. The SA notes at 10.5.4 that the potential for noise and potentially air pollution on the Honeypot Lane site arising from the A12 road. BLEL considers that the site's design and specific technical measures respond to the context of the site, including proximity to the A12 road and that the emerging scheme design includes appropriate buffers and mitigations for noise and air pollution amenity accordingly. The SA text should therefore be updated accordingly in this respect. A small watercourse running through the Honeypot Lane site is noted in the SA at 10.5.4 and the text highlights this as an example of the factors that will need to be taken into account in developing the site. BLEL has undertaken extensive technical analysis including physical surveys and assessments of the site and can confirm that site and surrounding area physical characteristics have been taken fully into account in concluding that the site can deliver up to 250 dwellings. Paragraph 10.10.2 (page 52) Paragraph 10.10.2 of the SA Interim Report identifies a lower level of housing delivery at Land at Honeypot Lane (and other Green Belt sites in Brentwood) as potentially having a lower landscape effect than earlier proposals and also potential for more green space on the site. BLEL's conclusion, following extensive technical analysis including landscape and visual impact assessment work is that Land at Honeypot Lane can deliver more than the 200 dwellings set out in the Site Allocations Plan and it can do so without adverse landscape effects. The site can achieve this while supporting levels of new amenity and green infrastructure to high degree. Honeypot Lane can therefore deliver more housing than the current version of the Plan identifies and can do so without adverse landscape effects given sensitive site design and the effective use of the site's natural topography and natural boundary vegetation as appropriate. Honeypot Lane Site Appraisal (page 81) BLEL note that the SA Interim Report has provided a high level sustainability appraisal of the Honeypot Lane site (page 81). BLEL concur with the analysis and note that the Site performs well in relation the analytical criterion. BLEL notes that the SA site assessment criteria covering issues such as access to primary and secondary schools and GP's surgeries is based on existing local provision and does not consider the potential future provision arising from new development as the Local Plan is implemented. I.e. the SA site assessment does not consider the potential for an enhanced level of site sustainability where development has supported the provision of new or expanded facilities. It is also important, in BLEL's view that that the SA site assessments consider factors such as the quality or capacity of facilities and services as well as a site's distance from such facilities. Quality and capacity are equally important sustainability factors. The Red Amber Green (RAG) scoring system used for the SA's site sustainability appraisals has no green scores in relation to a number of criteria. For example, Air Quality Management Areas and proximity to SSSI designations. This means that all sites are either scored red or amber for such criteria. Similarly, the distance from a Local Nature Reserve criteria is scored as either Red or Green (there is no amber). The RAG scoring system is, in BLEL's view, helpful but rather confusing overall as it mixes two and three RAG scoring codes depending on the criterion in question. BLEL is of the view that the assessment criteria and RAG scoring should be used consistently in respect of each criteria in the next version of the Sustainability Appraisal of the Local Plan. Barwood Land and Estates (BLEL) support the Local Plan at paragraph 43 (page 19) concerning objectively assessed housing need. BLEL support the higher OAN figure (380 dpa) calculated in the latest version of the Strategic Housing Market Assessment, but consider it is realistic and appropriate to now plan on basis of the Government's standardised methodology as set out in the new consultation draft NPPF and in revisions to the NPPG. It is clear that Government intends to adopt the standardised methodology in future and the Local Plan should reflect this now. Therefore, the Plan should set out opportunities and sites to deliver the 454 dpa (+74 dpa over the OAN). This supports and emphasises the need for a choice and mix of sites to ensure delivery and focuses the Plan into ensuring release of sufficient brownfield land and Green Belt sites at sustainable locations in order to deliver. Barwood Land and Estates (BLEL) support paragraph 54 (page 22) of the Local Plan that is concerned with the supply of housing sites. BLEL agree that it is appropriate to review, test and evaluate (and discount where necessary) a wide range of housing sites through the HELAA process. The process undertaken has been thorough in identifying potential sites and in evidencing those selected for allocation in the Plan. The Vision (page 11) supports sustainable growth and makes best use of brownfield and greenfield
land. This represents a realistic approach to the need to release Green Belt land to fully support housing and economic delivery objectives of the Local Plan.

Comment

Preferred Site Allocations 2018

Representation ID: 19670

Received: 08/03/2018

Respondent: Grafik Limited

Agent: Strutt & Parker LLP

Representation:

The settlement boundary of Stondon Massey should be amended to include the small ribbon development that extends northwards from the existing settlement boundary along Nine Ashes Road. The Council is currently considering a planning application (reference 18/00154/FUL) for the erection of two dwellings within this ribbon development. The ribbon development comprises an existing line of dwellings and therefore it is suggested that these properties would be more appropriately excluded from the Green Belt, given the existing residential character of the area and their association with the core of Stondon Massey. Pleas refer to Landscape, Visual and Green Belt Impact Assessment

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19692

Received: 12/03/2018

Respondent: Marden Homes Ltd.

Agent: Strutt & Parker LLP

Representation:

We are supportive of this uplift but do still have outstanding concerns that the increased need does not fully represent the full extent of housing need. The reduction of the stated need of 348 dpa to 280 dpa based on tests of underlying trends. Given the subjective nature of these tests, and the unknown shortterm trends will indeed become the new normal for the longer term we urge a precautionary approach to ensure housing needs are met. A 348dpa baseline and 36% uplift would more accurately reflect these projections emerging from the government proposed standard housing needs methodology.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19739

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation:

The Council said it is "unlikely to be able to demonstrate a 5year housing land supply on plan adoption due to a significant rolling deficit" and: "one of the critical factors in this calculation will be the number and type of allocations that are deliverable in the first 5years of the plan. A mixed portfolio of sites, including smaller greenfield/Green Belt sites may form part of this approach, rather than over reliance on large scale strategic sites with longer delivery lead in periods and complex brownfield sites". Placing 46% of housing need on one site is contrary to above statements.

Full text:

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

see attached representations and appendices

Object

Preferred Site Allocations 2018

Representation ID: 19819

Received: 12/03/2018

Respondent: Plainview Planning

Representation:

We strongly object to the exclusion of our client's land at Spital Lane, Brentwood as an allocation within the category 'Green Belt Land - Edge of Brentwood Urban Area'. The exclusion of this site has not been justified by the Council, yet very comparable sites have been included in this list. This land is available, achievable and suitable for development and could contribute to the 5-year housing supply.

Full text:

See attached.

Attachments:

Comment

Preferred Site Allocations 2018

Representation ID: 19825

Received: 12/03/2018

Respondent: Diocese of Chelmsford

Agent: Strutt & Parker LLP

Representation:

To ensure the plan is fully robust we suggest it is important to plan for higher level of growth. Additionally in order to ensure delivery throughout the plan period it is important the supply includes sufficient sites that are deliverable in the early part of the plan period in addition to any strategic or new settlement allocations.

Full text:

See attached.

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 19877

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

The Draft Plan included the industrial estates at West Horndon as proposed brownfield housing land allocations. However, the Ford Offices at Eagle Way, Warley was scheduled as an employment land allocation, where redevelopment or changes of use for non Class B uses would be permitted only in certain defined circumstances. Both sites are now preferred housing allocations.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19879

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

Our principal concern is the uncertainty surrounding a number of these brownfield sites and the consequences for an early boost to the current serious undersupply of available housing land.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19884

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

Historic completion rates is not an excuse for failing to produce a local plan. The lack of new building in Brentwood is unlikely to be the consequence of lack of demand as the LPA's own comments but more likely the result of a lack of suitable sites or that sites that have been given permission have proved difficult to develop. Although the LPA makes much of an increasing gap between planning permissions given and the level of completions, the latest assessment of the supply of land available for housing development is 2.67 years, well below the NPPF's 5 year requirement.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19885

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

The LPA's full response to the Secretary of State relies heavily on the proposed Dunton Hills Garden Village proposal to speed up housing delivery within the District. It is hoped that this proposal will provide a minimum of 30% of Brentwood's housing needs during the plan period. We regard this as an optimistic assumption, to say the least. This is a joint project with another LPA; it will be reliant on the effective co-ordination of many different partners; and it will not have the type of powers and mechanisms that were available to the new towns to ensure delivery.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19886

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

Given the problems that remain with the delivery of brownfield sites in the District, reflected in recent housing completion rates, and the high level of reliance that the LPA is placing on Dunton Hills Garden Village, it is imperative to re-consider a modest release of Green Belt land. Otherwise it will be impossible in either the short or medium term to lift the current supply of available land from the current 2.67 years to the 5 years required by the NPPF.

Full text:

See attached.

Object

Preferred Site Allocations 2018

Representation ID: 19894

Received: 10/03/2018

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation:

Whilst the LPA's sequential approach to finding land is commendable, not enough suitable brownfield land has become available to boost completion rates and meet demand. This must surely cast doubt on the Preferred Site Allocations Document's list of brownfield sites. Some of them have been included in consultation programmes for more than 10 years, and they have still not come forward. The only way to quickly increase completion rates would be through making available more, easily developed, greenfield sites.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19961

Received: 12/03/2018

Respondent: Basildon Borough Council

Representation:

The housing allocations proposed within the Preferred Site Allocations 2018 amount to 6,151 dwellings, or just over 74% of the total housing growth. BBC has not stated within the Preferred Site Allocations 2018 consultation document that it does not intend to meet its OAHN within the Brentwood Borough boundary. It is therefore not clear where all of the proposed housing needs would be located, and further evidence of this should be provided to demonstrate an appropriate level of housing supply. The SHLAA is not up to date and will need to be before Reg 19.

Full text:

See attached.

Attachments: