How will you improve transport and movement?

These are fine, so long as the development is really sustainable and environmentally friendly.

S022 objective - to improve cycling and walking facilities. This is misleading although I am support the intent. A similar statement was included in the present Plan (adopted August 2005) however there has been minimal investment. Cycling and walking has become more problematic as traffic volumes have increased and roads have deteriorated. No plans have been presented to satisfy this objective.

These seems like a reasonable set of Strategic Objectives. I particularly support the addition of SO17.

The Strategic Objectives on Environmental Protection and Enhancement should include a commitment to the protection and enhancement of biodiversity.

Strategic Objective SO17:
New housing developments and houses themselves should be designed to integrate space for both wildlife and people, as well as to reduce carbon emissions and minimise water usage.

A good nature-friendly development protects and keeps existing wildlife habitats and joins them up with wildlife-rich gardens, verges, amenity green space, cycle paths and walkways. The aim is to create a network of natural green and blue corridors through the development, into the surrounding urban or rural landscape and contributing to the wider ecological network.

This approach improves air quality, reduces surface water flooding and makes developments greener and more attractive places to live. Residents have easy access to safe, beautiful, natural space for exercise, play and social interaction. Wildlife becomes part of everyday life.

New housing developments should provide:

* Real, measurable gains for wildlife and make a demonstrable, positive contribution to nature's recovery.

* Effective water management, pollution and climate control provided by green spaces and water courses, sustainable urban drainage, green roofs, trees, woodlands, wetlands and other natural features.

* Connectivity between wild places - enabling both wildlife and people to move through the landscape, and for natural processes to operate effectively.

* Improved health, wellbeing and quality of life for people living and working nearby.

* Easy access to high quality, wildlife-rich, natural green space for everyone, providing daily opportunities to experience wildlife.

Benefits of this approach:

Housing developments designed with environmental sensitivity and green infrastructure at their heart can deliver multiple social, environmental and economic benefits. Nature-rich housing can provide benefits for everyone - from developers to home-owners.

Benefits for wildlife:

* No loss of key wildlife sites - better protection of the already diminished wildlife resource and sites. Protection and beneficial management for Local Wildlife Sites and sites of national and international importance for wildlife.

* Much more space for wildlife - a substantial increase in the creation and restoration of habitats, through additional funding and resources, for example Section 106 agreements and conservation covenants - contributing to an overall increase in the abundance and diversity of wildlife and an improvement of soil and catchment health.

* Improved connectivity of wildlife habitats - both within developments and linking to the wider landscape and ecological networks beyond.

* Buildings that are more wildlife-friendly - with bird and bat boxes, pollinator and insect-friendly structures and connected spaces for hedgehogs.

* Reduced emissions - reducing carbon emissions, pollutants and water use to help minimise threats to wildlife.

Benefits for people:

* Daily enjoyment of nature - people can experience and benefit from contact with wildlife and wild places in their daily lives, because there is wildlife around them near to home.

* Improved health - accessible natural green spaces for fresh air, exercise and quiet contemplation improve health and wellbeing, for example by helping to lower levels of heart disease, obesity, stress and depression.

* Protection against extremes of climate - natural green spaces and trees within urban areas help stabilise temperature and reduce pollution.

* Safer transport routes - networks of natural green spaces can provide safe and attractive pedestrian and cycle routes.

* Sense of community - natural green space in and around housing areas can provide a shared space for the local community to come together and socialise - reducing isolation.

Benefits for the economy and wider society:

* Cost-effective environmental protection - providing green space in and around housing is a cost-effective and sustainable way of increasing environmental resilience, for example by reducing surface water flooding and improving air quality.

* Employment - when communities get involved in the planning and management of the natural green space where they live this provides jobs and volunteering opportunities.

* Space for local food - networks of natural green space in and around housing areas provide opportunities for local food production, bee keeping, etc.

* Attracting investment - high quality developments rich in natural green space can attract further investment from business and visitors.

* Reduced health-care costs - people living in developments with more green space are likely to place fewer demands on the NHS, as they enjoy better health and higher quality of life.

Benefits for developers:

* Satisfied customers - houses and developments set in natural green space are more desirable to buyers.

* Market value - houses in greener developments can have a higher market value.

* Enhanced brand value - developers that take a lead on nature build their brand and change the sector as a whole.

* Improved high-calibre skills recruitment - such developers are also more likely to attract up-and-coming graduates by demonstrating a genuine commitment to the environment.

* Improved environmental performance - helping drive higher ranking in sustainability and nature indices, making the direct links to the benefits of a natural capital approach.

* Happier communities - new houses designed to retain existing natural features with high quality greenspace are more acceptable to existing residents.

Principles guiding this approach

All housing developments must result in:

* A measurable improvement for wild species and habitats, avoiding any loss of or damage to wildlife sites - new housing must not damage or destroy important national and local wildlife sites. Our natural environment is finite. These sites are remnants of a rich past and essential to our future.

* More than compensating for any habitat that is lost - where damage to existing habitats is unavoidable, mitigation must bring about an overall gain in habitats. This should be assessed objectively using an improved version of the Defra biodiversity metric.

* Creating new habitat - habitat creation should be a standard feature of all new housing development, wherever it is.

* Designing in existing habitats - new housing must work with as much existing habitat as possible. For example, retaining existing woods, copses, hedges and streams as integral parts of new developments.

All residents having lasting access to nearby nature, which means:

* Providing wildlife on the doorstep - space for wildlife must be designed into new development, much of this should be easily accessible to people.

* Ensuring our natural spaces are well managed for posterity - maintaining local green spaces is as essential as maintaining roads, power and other important infrastructure. Financial planning should account for this at the outset, through a service charge or capital endowment.

* Empowering communities - for major housing developments provision should be made to empower local residents to come together to maintain shared spaces, grow food and understand the area they live in.

* Engaging civil society - local charities and social enterprises have skills and experience that will be vital to ongoing community engagement.

This can be ensured by:

* Using ecological network maps - such maps should be built from local, up to date data with the active involvement of civil society and must be the basis for deciding where new housing is (and isn't) located, and how close it is to existing natural areas and wildlife habitats.

* Developing within environmental limits - decisions about the planning, design and construction of new housing must be based on a thorough understanding of the natural environment's capacity to meet the demands placed on it.

* Employing ecological expertise - when making decisions on land use and new development planning authorities should consult experienced ecologists and ensure they have access to high quality wildlife and environmental data.

As they relate to the redevelopment of the sites at West Horndon Industrial Estate, and the new employment allocation on land south of East Horndon Hall, Hermes Investment Management support the following strategic objectives: SO1, 2, 3, 5, 6, 8, 10, 11, 12, 14, 15, 16, 17, 18, 19, 21, 22, 23

See attached.

I am re-emailing my previous comments as I feel that they are still relevant.


1. It would appear that the Council has allocated a number of its Car parks, as land suitable for building dwellings. This includes the car parks in Westbury Road, Chatham Way and William Hunter Way. This creates two problems:

a) In fill like this does not provide an attractive environment - either for the new residents or existing residents.
b) There does not seem to be clear provision of new/alternative car parking to replace the lost spaces. Where are visitors/shoppers supposed to park? Where do Brentwood workers park, long-stay? Its difficult enough at present.

I was told a few years ago that there was a waiting list for long-term parking annual permits: a friend asked to park on my drive because he couldn't park in Brentwood while he worked. Also, I know one retailer who received £3,000 worth of parking fines for parking his work van at the back of his shop, because he could no longer get a parking permit for a local car park. He has since closed the shop in Brentwood High Street.

* The Council removed the small free parking bay at the end of the High Street, which allowed for 30 minutes of shopping - very appropriate for the types of shops directly next to this bay. Unsurprisingly, a number of these have now shut - the shoe repairers, the florist, the fruit and veg shop etc which were independent shops. The Council claims to encourage these in section 8.37.
S. 8.37 refers to Brentwood Town Centre attracting many visitors for a variety of reasons including a high quality shopping environment. The current empty units are unattractive, and the choices of retailers who have recently taken some of the larger spaces are not conducive to an interesting and up-market shopping experience. And if, as per s. 8.56 the Council "seeks to retain existing large retail units as they can be a major driver of footfall" why did it allow The Dairyman and Wildwood to take the larger retail sites when they became vacant?

* Brentwood is too expensive and not an attractive enough shopping area with its difficult-to-find and very expensive when-you-do-find-it parking. If I needed to drive to shops, I would drive to Upminster which has lovely shops, a choice of supermarkets and cheap, available parking. There is always Lakeside. Or, I would drive further afield for a much wider choice of niche shops, for example to Tunbridge Wells, or Cambridge.

2. Section 8 discusses that the town apparently requires more retail units and section 5.74 states that the existing vacant units are not sufficient to provide for the requirement.
There are currently at least 20 empty units in the High Street, Bay Tree Centre, Kings Road and Chapel Ruins area. Why can these not be filled first? Can these be adapted (if smaller or larger units are desired) for use by retailers, with their advance agreement, so that shopping in Brentwood is an attractive proposition.

3. The consultation for the semi-pedestrianisation of the High Street was largely ignored by the Council, who appeared determined to press ahead regardless of public opinion. The subsequent decision to re-surface the High Street has been an expensive disaster. The road needs extensive, expensive repairs and although its appearance is pleasing, it was not necessary. Please do not make
the same mistake of ignoring public opinion.

4. Regarding a cinema - something that has been promised for the last 15+ years. We still don't have a cinema in the town, which is a great shame. I still don't understand why this cannot be at the Brentwood Sports and Leisure Centre where there is the space for a new building, and the parking that would be needed. I have been told that one concern is "already congested roads" but I don't agree that the roads are congested towards the Brentwood Centre. In fact, if the cinema were built in William Hunter Way, the increased traffic in William Hunter Way, Western Avenue and Weald Road, including the crossroads junctions with the High Street would be worse.

5. What is happening with the space that has been boarded up since the demolition of the Grade 11 listed building that was the Sir Charles Napier pub? It is very ugly at the moment, and a waste of development space that is sorely needed. This requires development so that it is both attractive and useful.

6. Brentwood needs some open spaces and to retain its Victorian market town feel. The little "green area" in Kings Road makes such a difference and more like this would be very welcome.

7. Re. resurfacing the High street : Not only did this close the High Street for nearly a year causing major sales problems for many retailers, but it also means that you cannot cycle in the High Street, and nor can there be the annual Cycle Race that used to occur.

kind regards
Susan Marigold

Figure 9 - we note that this figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF. Interim Sustainability Appraisal (SA) - The Interim SA advises that it welcomes comments from stakeholders. Redrow Homes owns one of
the proposed allocation sites (site 128). It intends to bring this site forward for development as soon as planning permission is granted. Site 128 is included in the Interim SA and the appraisal so far raises a few concerns that Redrow Homes wishes to comment on. These relate to the topics used for assessment and how these have been applied to this site. Special Landscape Area - Site 128 is given an amber rating for this in Table C and the notes in Table B say that this is to reflect potential the effects on landscape. It is unclear how this can be assessed at this stage as there is no reference as to what is special about the landscape that could be affected and no account is take of the existing redundant nature of the site. It is further noted that the SLA designation is not proposed to be carried forward into the new development plan. It is also noted at Table A that "Limited data is available to inform the appraisal. Work is ongoing to ensure that all site options are categorised in terms of potential for landscape impacts and also the potential to result in loss of functioning Green Belt (i.e. Green Belt that meets the established purposes). This work will be drawn upon in the future." It is apparent, therefore, that this rating will need to be updated when further information is available and we would ask that it also include an assessment that takes into account the existing nature of the site, the potential for landscape enhancement and the removal of the SLA designation. Distances to facilities (criteria 7-9) - It is noted that Department of Transport walking distance guidelines have been used to rate the distance from these facilities. Consideration should be given to departing from these in light of the health benefits of walking and the NHS guidance that specifically encourages walking to maintain a healthy lifestyle. For these reasons it is considered that the walking distances should be extended. Site allocation 128 - we note that this site is described as being a self-contained urban extension with the neighbouring site (site 106). Redrow Homes owns site 128 and is bringing this forward for development. It has no control over site 106 and would not wish the wording of the allocation to be misconstrued as meaning that both sites must come forward together. The proximity of the site to the settlement boundary means that is clearly an urban extension and therefore it is suggested that the reference to site 106 is unnecessary. As such, it is requested that this be deleted from the allocation summary. SO1 - we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3 - we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations. Figure 15 - the RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.