Settlement Hierarchy and Accommodating Growth

Showing comments and forms 1 to 6 of 6

Support

Preferred Site Allocations 2018

Representation ID: 18304

Received: 12/03/2018

Respondent: Hermes Investment Management

Agent: McGough Planning Consultants

Representation:

Hermes Investment Management support the change of West Horndon's categorisation to a Category 2 service centre

Full text:

Hermes Investment Management support the change of West Horndon's categorisation to a Category 2 service centre

Object

Preferred Site Allocations 2018

Representation ID: 18445

Received: 21/02/2018

Respondent: mr james monk

Representation:

Amount of housing outlined in the table starting on page 35 is too high as the existing infrastructure (ie roads) cannot cope with the proposed increase population.

Full text:

Just a few points from the document: Page 31 Map is atrocious. No points of reference; Page 35 900 more homes in Shenfield by 2033. The traffic is already a joke and I haven't managed to get a seat on the train at 6am in 2 years; Page 35 939 more homes in Brentwood. Have you driven through Brentwood lately. Its a car park. The A12 cant handle the traffic and nor can the current roads; Page 35 2500 homes in Dunton hill. Averaging out a 3 people per dwelling is 7500 more people trying to commute and use the existing infrastructure; Page 38 The equation used for EEC formula assumes there are 1 pupil per 4 homes?? My good lord, how old is this formula. 5 houses to my right have 6 children and to my left 9 children. The equation used is out of date and inaccurate; Page 39 Your chart shows Brentwood Town Group 1 is already deficit of 541 school places. Yet you want another 900 more homes in Shenfield alone. Even at the ECC outdate equation that's another 300 pupils on top of pipeline permissions; Page 41 'The Expansion of various primary schools'......Please define?; Page 41 'Potentially 2 new 2FE Primary schools'. Where? What size? 'Flexible criteria'. Again no defined plan!!!; Page 44 You suggest that Brentwood County High School will reduce admission to 1092 by 2021. How is that possible with your stats above???; Page 47 Point 102 No current gaps in front end GP services. Yet I phoned my local GP to apply for the 'Free NHS health check' today and was told 'I don't know why Essex County Council NHS is sending out those documents. We don't have the staff or the time to handle it so it wont be taking place in the foreseeable future'. But I am sure 900 more homes on top of the 90 that were just built on Mountnessing roundabout will surely alleviate the problems; Page 35 Shenfield a total of 900 estimated homes by 2033 yet the Housing sites shown at the bottom of the document show 975 dwellings mostly within 1/5; Page 79 states possible Primary school provision. GOOD. Then plan for it. Don't use the word 'possible'!!!; Page 80 Possible 510 homes. That's a possibility of 510 more vehicles using the Chelmsford Road which is already gridlocked at The Eagle and Child by 8a. I know we need more homes but the infrastructure is so broadly mentioned in this document is allows housing to hit government targets without any consideration for the existing resident and the future residents.

Object

Preferred Site Allocations 2018

Representation ID: 18587

Received: 12/03/2018

Respondent: Lewis Campbell

Representation:

Object. Greenbelt & wildlife should be protected - Brown field used first. Greenbelt should never be built on for monetary gain for developers.

Full text:

To whom it may concern
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 !
Greenbelt & wildlife should be protected -Brown field used first .

Object

Preferred Site Allocations 2018

Representation ID: 18822

Received: 12/03/2018

Respondent: Donaldson Mhairi

Representation:

A 28% increase in the population of Blackmore under such circumstances seems unreasonable. Villages of a similar size in the Brentwood area, including Herongate, Ingrave and Mountessing, have no planned development.

Full text:

The site identified for development sits directly opposite the village's primary school. The significant increase in volume of traffic and type of vehicle necessary for construction to take place will have consequences for air quality, noise, and the quality and safety of our local roads. School drop off and pick up takes place around the village hall and in the road adjacent to Red Rose Lane and an increase in traffic will have consequences for safety of children, and for fluidity of movement through the village, at these times.
Construction work for 5-6 years from 2019 threatens to affect the experience and education of children at the village school (including that of my son, currently in year 1) as a result of increased noise and air pollution. It is also
questionable how the school, already at capacity and at times with a waiting list, could absorb what could feasibly be a 100% increase in numbers of children (the school has approximately 125 places).
The development site is green belt land. My partner and I chose to live in the vicinity of Blackmore because of its rural location. We enjoy outdoor pursuits including cycling and running which are possible because of the rural nature of our community. A significant and sudden increase in the population of the village would lead to a similar increase in the amount of traffic on local roads, making such outdoor pursuits at the very least less safe.
Blackmore has a vibrant community spirit from which all residents benefit and which would be threatened by a significant and sudden increase in the population of the village. I appreciate the need for development in the village to support e.g. younger people to find homes in the area, or older residents of the village to downsize, but believe this should be proportionate, reasonable, and at a rate that allows for absorption by the local community. Disproportionate and rapid increase threatens to be detrimental to the thriving and inclusive community of Blackmore which brings so many benefits to its residents.
Finally, I note that villages of a similar size in the Brentwood area, including Herongate, Ingrave and Mountessing, have no planned development. A 28% increase in the population of Blackmore under such circumstances seems unreasonable.

Object

Preferred Site Allocations 2018

Representation ID: 19606

Received: 12/03/2018

Respondent: Mr Jon Nicholls

Representation:

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. This is not consistent with paragraphs 55 and 80 of the NPPF (current consultation version). 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

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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.

Support

Preferred Site Allocations 2018

Representation ID: 19651

Received: 12/03/2018

Respondent: JTS Partnership LLP

Representation:

The proposed settlement hierarchy and, in particular, the classification of Doddinghurst and Kelvedon Hatch as Large Villages / Village Service Centres is supported. 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.

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