2.29

Showing comments and forms 1 to 29 of 29

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 78

Received: 02/10/2013

Respondent: Chelmsford City Council

Representation Summary:

- CCC objects to BBC not meeting objectively assessed need.

- In the context of a national housing shortage, CCC does not consider that the protection of the Green Belt overrides meeting the full housing needs of Brentwood Borough.

- CCC objects to the distinct lack of published evidence base to support BBC's Spatial Strategy, in particular a Green Belt review.

- CCC strongly objects BBC's Preferred Strategy which includes the possibility of looking to Chelmsford to meet a proportion of Brentwood Borough's unmet housing need.

Full text:

Chelmsford City Council objects to Brentwood's Spatial Strategy which places the protection of the Green Belt and the quality and character of the landscape above meeting objectively assessed need. BBC has rejected Alternative Option 1 which makes provisions for 4,960-5,600 dwellings (331 to 373 homes a year) which is BBC's identified objectively assessed need. Instead BBC has chosen to make provisions for 3,500 new dwellings which equates to only 60% of its objectively assessed need. This means 40% of the housing needs for the Borough will not be met.

BBC's argument for not meeting objectively assessed need is the protection of the Green Belt which they consider to be the top priority for its Local Plan along with protecting the quality and character of the Borough. By their own omission, the protection of the Green Belt and ensuring there is adequate infrastructure to serve residents precludes the accommodation of the totality of market demand. In the context of a national housing shortage, the City Council does not consider that the protection of the Green Belt overrides meeting the full housing needs of Brentwood Borough. Furthermore, where is the evidence to justify this approach? The Plan indicates that the Landscape and Green Belt Assessment is forthcoming. This is unacceptable. This is a crucial piece of evidence base work that should be made available as part of the current consultation. As raised by the City Council and many other authorities in attendance at the Duty to Co-operate meeting on 29th July 2013, by not undertaking a Green Belt review BBC is leaving itself extremely vulnerable at Examination.

At the same Duty to Co-operate meeting Basildon Borough Council asked how BBC can allocate sites for development without the need for a Green Belt review. BBC responded saying that their approach was one of capacity - environmentally sensitive landscapes, capacity of transport infrastructure, provision of services and facilities, etc. However, again there is no published evidence to support this approach. Paragraph 2.29 of the Plan indicates that the Landscape and Green Belt Assessment, Transport modelling, Utilities Study and SHMA update are all forthcoming. The City Council would question how BBC has established their approach to the growth and development of the Borough over the Plan period without the relevant evidence? Paragraph 158 of the NPPF clearly states that 'each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.'

For the reasons set out above, the City Council strongly objects to BBC's Preferred Strategy which includes the possibility of looking to Chelmsford to meet a proportion of Brentwood Borough's unmet housing need. Brentwood Borough is not unique in their circumstances of being constrained by the Green Belt and other landscape characteristics. Chelmsford also has large areas of Green Belt and other environmental and infrastructure constraints which influence the delivery of its own housing requirements. Therefore, it is unreasonable and unacceptable for BBC to expect Chelmsford to make provisions for a proportion of their growth when Chelmsford itself has similar constraints. The City Council already is, and will be expecting to continue, to meet the needs of the City over the Plan period and beyond, without importing or exporting any other growth to/from neighbouring authorities.

The National Planning Policy Framework gives local authorities the ability to review Green Belt boundaries where it would meet objectives of the Framework and this includes meeting objectively assessed need. The City Council considers a Green Belt review is imperative and to meet the needs of the Borough some revisions to Brentwood Green Belt boundaries may be necessary.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 226

Received: 02/10/2013

Respondent: Thurrock Borough Council

Representation Summary:

1.The Brentwood Preferred Option Policy S1 seeks to protect the Green Belt and local character and focus new developmenton land accessible within existing settlements. Other than a strategic Green Belt development site identified at West Horndon there are no other significant Green Belt boundary changes. The draft local plan strategy is based on strong local support for protection of the Green Belt and technical evidence that suggests there are significant capacity constraints with higher levels of growth having significant impacts on Green Belt, landscape, settlement character and identity, together with congestion and infrastructure capacity issues. Thurrock Council strongly objects to draft plan policies S1 and in particular provision in Policy S2 to accommodate only some of the identified objectively assessed need for housing within Brentwood.
2.Thurrock Council also objects to the Brentwood Local Plan looking to neighbouring authorities to accommodate the remainder of its need. It is considered that Brentwood Council approach is flawed and the Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood or within the Strategic Housing Market Area as part of the Duty to Co-operate process. Thurrock Council is not within the Brentwood SHMA area and at this stage does not consider that other options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
3.It is considered that Brentwood Council should undertake a formal Green Belt review as part of the spatial options testing which is subject to further public consultation before the Council progresses the local plan to submission stage.
4.Furthermore considerable elements of the evidence base including the character assessment, infrastructure and transport studies have not been made available during the consultation process and have therefore not been able to be included in any comments at this stage. It is considered this is a major error in the consultation and Duty to cooperate process and that the plan and evidence when available should be subject to further consultation.

Full text:

See Attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 342

Received: 03/10/2013

Respondent: South Essex Partnership University NHS Trust

Agent: Bidwells

Representation Summary:

The Council's preferred housing target of 3,500 new homes over the Plan period cannot be deemed sound on the basis that it will not meet the Council's objectively assessed housing need despite there being suitable sites which have not been allocated for housing. My client's site is a highly sustainable location for development and meets the Council's own assessment criteria for allocation. On the basis that my client's site has been discounted when it is entirely suitable for housing development, we must assert that in our view the Council's justification for this preferred strategy is unsound.

Full text:

See attached

Attachments:

Comment

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 374

Received: 02/10/2013

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

Representation Summary:

It is noted that the Borough Council has decided to place greater emphasis on the need to protect the Green Belt, than the need to provide for full OAN. As a result, the policy makes provision for 3,500 new dwellings against an interim OAN of 4,962 to 5,600 dwellings (331 to 373 homes a year). The fact that the Council has decided to plan for a figure well below this figure makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no, or only a limited, green belt function and which should be identified for residential development following a limited review of green belt boundaries). It is the Company‟s view that the Council will need to identify sites falling within all of the above four categories if it is to produce a "sound‟ Local Plan

Full text:

See Atteched

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 376

Received: 02/10/2013

Respondent: JTS Partnership LLP

Representation Summary:

We note that the overriding priority given to protecting the Green Belt means that the Council has chosen not to plan for 'objectively assessed housing needs'. As such, we consider that Brentwood Council may find it difficult to convince an
Inspector that the Plan is 'sound. It is our view that the Plan would be more robust if the Council could find additional housing sites, consistent with the Spatial Strategy set out in the policy, and if it also undertook a limited review of the Green Belt, in order to remove that land which clearly serves no Green Belt function.

Full text:

see attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 377

Received: 02/10/2013

Respondent: JTS Partnership LLP

Representation Summary:

The Council in deciding to plan for a figure well below 'objectively assessed housing needs' makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no or a limited Green Belt function).
It is the Partnership's view that the Council will need to identify sites if it is to produce a 'sound' Local Plan.

Full text:

see attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 426

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

Representation Summary:

Given that the Council has decided to plan for a figure well below 'objectively assessed housing needs' makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil or provide only a limited, Green Belt function. On this basis Joy Fook Restaurant (falls within catogory c above) and should be identified for residential development.

Full text:

See Attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 506

Received: 02/10/2013

Respondent: JTS Partnership LLP

Agent: JTS Partnership LLP

Representation Summary:

It is noted that the Borough Council has decided to place greater emphasis on the need to protect the Green Belt, than the need to provide for full OAN. As a result, the policy makes provision for 3,500 new dwellings against an interim OAN of 4,962 to 5,600 dwellings (331 to 373 homes a year). The fact that the Council has decided to plan for a figure well below this figure makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no, or only a limited, green belt function and which should be identified for residential development following a limited review of green belt boundaries). It is the Company‟s view that the Council will need to identify sites falling within all of the above four categories if it is to produce a "sound‟ Local Plan.

Full text:

See Attached

Attachments:

Support

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 550

Received: 02/10/2013

Respondent: Hansteen Holdings Plc

Agent: McGough Planning Consultants

Representation Summary:

See the concerns set out for para 2.20 above. In the event that the LPA can show "significant and demonstrable harm" in meeting all Brentwood's objectively assessed need, Hansteen would support the LPA's position and welcomes a Strategic Allocation at West Horndon as a way of meeting a significant part of the housing land requirement.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 688

Received: 02/10/2013

Respondent: The Croll Group

Agent: Strutt & Parker LLP

Representation Summary:

Then Plan is proposing to build 3,500 new dwellings over the plan period 2015-2030, with an allocation of 1,500 new dwellings at West Horndon. PBA's OAN Report, which has been undertaken but not published by the Council, suggesting a figure of 362 dwellings each year or 5,430 new dwellings over the plan period. This ilustrates a shortage in housing numbers of 1,930 or 128 dwellings each year.

It should also be noted that the councils SHMA has not yet been finalised or published, which makes it difficult to provide comment on the Plan when all of the facts are not made available to evaluate. this does not accord with Para. 159 of the NPPF.

Full text:

See Attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 702

Received: 02/10/2013

Respondent: Mr R Faruggia

Agent: JTS Partnership LLP

Representation Summary:

It is noted that the Borough Council has decided to place greater emphasis on the need to protect the Green Belt, than the need to provide for full OAN. As a result, the policy makes provision for 3,500 new dwellings against an interim OAN of 4,962 to 5,600 dwellings (331 to 373 homes a year). The fact that the Council has decided to plan for a figure well below this figure makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no, or only a limited, green belt function and which should be identified for residential development following a limited review of green belt boundaries). It is the Company‟s view that the Council will need to identify sites falling within all of the above four categories if it is to produce a "sound‟ Local Plan

Full text:

See Attached

Attachments:

Support

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 707

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

It is noted that the Borough Council has decided to place greater emphasis on the need to protect the Green Belt, than the need to provide for full OAN. As a result, the policy makes provision for 3,500 new dwellings against an interim OAN of 4,962 to 5,600 dwellings (331 to 373 homes a year). The fact that the Council has decided to plan for a figure well below this figure makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no, or only a limited, green belt function and which should be identified for residential development following a limited review of green belt boundaries). It is the Company‟s view that the Council will need to identify sites falling within all of the above four categories if it is to produce a "sound‟ Local Plan

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 778

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

Representation Summary:

It is difficult to fully understand the objectively assessed housing need (OAN) for Brentwood Borough because at the time of writing the Council had not published the Report prepared by Peter Brett Associates. Paragraph 2.30 of the Local Plan document does identify the OAN figure recommended by the report, however it must nonetheless be considered that this lack of openness seriously undermines the transparency of the plan preparation process and the robustness of the consultation.

Full text:

See attached Report.

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 809

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Para 2.20 of the Local Plan states that the Council has carried out a technical exercise to objectively assess development needs, and the preferred spatial strategy seeks to accommodate a 'significant proportion of this need'. Para 2.20 goes on to state that "due to significant capacity constraints, however, it is not possible to accommodate fully the scale of growth implied within the context of a coherent spatial strategy in accordance with sustainable development principles set out in the NPPF". By implication, BBC must be looking to neighbouring authorities to meet its unmet need through a 'Duty to Cooperate'. As matters stand it is unclear what the Council is actually doing in terms of "exploring options" with adjoining districts as there is no evidence available to demonstrate that BBC has effectively cooperated to plan for issues with cross-boundary impacts (NPPF Para 181). Given that neighbouring authorities are relying on housing to be delivered beyond their boundaries, it is unlikely that BBC's unmet housing needs will be able to be accommodated sustainably elsewhere. No definitive solution to the identified shortfall in future housing provision has been put forward.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 955

Received: 02/10/2013

Respondent: Barwood Land and Estates Ltd

Agent: Chilmark Consulting Limited

Representation Summary:

The draft Local Plan fails to provide an adequate justification as to why it cannot deliver Brentwood's full objectively assessed housing needs. There is no evidence presented in the Plan to demonstrate why a capacity constraint-led approach is the most appropriate strategy given the level of housing needs identified, there is also an over-reliance on assumed delivery from the West Horndon major allocation, with inadequate provision made in the draft Local Plan for flexibility and contingency in housing delivery from other sites.

Full text:

See Attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1001

Received: 02/10/2013

Respondent: Mrs Gemma Houghton

Representation Summary:

I have grave concerns over the extensive proposals for our village.
There is no evidence or SHMA to support the 5,000 dwelling requirement.

Full text:

See attached response.

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1188

Received: 02/10/2013

Respondent: Gladman Developments

Representation Summary:

Policy S2 of the Council's Preferred Options sets out an overall housing requirement of 3,500 new homes over the Local Plan period 2015-2030, with the rate of development phased to deliver 200 dpa between and 2015 and 2020 and 250 dpa between 2020 and 2030. Reviewing the Council's policy justification Gladman submit that this requirement is too low and is not justified by an adequate evidence base.

Full text:

See Attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1202

Received: 02/10/2013

Respondent: Mr. Giles Murray

Agent: Mr. Steve Hayhurst

Representation Summary:

The Council's proposed housing provision would fail to meet its objectively assessed housing needs for the Borough, as required by paragraph 47 of the NPPF. In order to meet it the Council should consider releasing sites on the edge of the larger villages excluded from the Green Belt, including at Herongate. Inspectors' decisions on other local plans strongly suggest that the Council's argument, that it should not have to meet its objectively assessed housing needs because the District is tightly constrained by Green Belt, will not succeed. Nor will it be able to foist its requirement onto neighbouring authorities.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1217

Received: 02/10/2013

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation Summary:

The Council's own "objective assessment" of housing need, carried out by PBA, estimated that around 350 new dwellings would be required each year, a total of 5,250 over the 15 year Plan period. The Plan makes provision for 3,500 new dwellings, some 2,250 short of this OAN. This shortfall in provision is justified by a lack of capacity, as identified in a number of studies, including the Housing Growth Scenarios Study carried out by Brentwood with its neighbouring Essex authorities. If we assume that the OAN for Brentwood report is correct, a considerable amount of the need it identified should be catered for by the Preferred Options Document. This must result in one or more of the following consequences:
*the need not catered for by the Plan is diverted to, and met by, provision in neighbouring areas
*the identified needs may be diminished by as yet unforeseen changes in local social and demographic characteristics
*the need remains as predicted, increasing pressure on the Borough's housing stock, generating additional increases in prices and rents in the private sector, and
*a continuing lengthening of the waiting list for socially provided housing.

Either the need identified by Peter Brett Associates is real and properly constituted or it is not. Assuming that it is, then the Preferred Options Document is choosing to export or defer to a later period a substantial part of this need. It will be left to the next Plan to decide how much irrevocable damage to other interests will be needed to accommodate what by then will be even greater pressures on housing provision. The Plan's proposals apparently do not meet the area's OAN. This is a very risky strategy, given the increasing evidence and concern about the
crisis in housing provision, and simply delays tough decisions, that need making now, to a time when it will be even more difficult to provide the housing needed without the "irrevocable harm" that the Plan fears will happen.

Full text:

See Attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1281

Received: 01/10/2013

Respondent: JB Planning Associates Ltd.

Representation Summary:

We are extremely concerned with the direction of the Local Plan. We believe the Council is failing to recognise the scale of housing needs in Brentwood. The plan fails to meet the requirements of the National Planning Policy Framework (NPPF) with respect to meeting the full range of 'objectively assessed' housing needs and as a result, the Local Plan is unsound. The Plan is planning for a significant shortfall in homes over the 15 year period of the plan. With little information provided on how the needs of those residents will be met, we can only assume a future scenario of increased unaffordability, overcrowding, homelessness and pressure on neighbouring authorities to meet Brentwood's unmet housing needs. This approach is therefore inconsistent with the objective of the NPPF to promote sustainable development.Evidence produced by the Council demonstrates a need for 4,960-5,600 additional homes from 2015-2031. This would represent meeting the full range of housing needs. However, Policy S2 of the consultation draft proposes to deliver 3,500 additional homes during the same period. This represents an under-provision of approximately 1,500 homes. The reasons given for the preferred housing target are to resist pressure on existing services and infrastructure; to not worsen congestion in Brentwood Town Centre; and to protect the rural character of the Borough. According to the Council, Green Belt sites would need to be released to meet the shortfall which would risk 'irrevocably changing the rural character of the borough'. It is our opinion that the reasons given for setting a lower housing target than would meet the Borough's housing needs are insufficient and unsatisfactory.

Full text:

See attached

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1466

Received: 01/10/2013

Respondent: H. Watson

Representation Summary:

1. We are being asked to comment on a major and very significant proposal, but only being presented with an unfinished outline of what is proposed. The benefits for the village are unstated and unknown. There is no proposal of how the scheme might seek to mitigate against any harmful impacts.
2. The national guidelines state that 'Local Plans should develop robust and comprehensive policies'. The plan presented to residents is still in its infancy and has lots of gaps (flooding, transport infrastructure, health and educational services, amenities, public transport are still to be considered). Until this is carried out the proposal is neither robust nor comprehensive. The borough council need to carry out a study of West Horndon and the other sites mentioned above in order to accurately ascertain whether its plans are affordable.

Full text:

I wish to respond to the Draft Plan on the proposed development at West Horndon as follows:

1. Size of development

The Draft Option shows the preferred option for Borough Council of a major new development of 1500 dwellings added to a small village community which is currently made up of 750 dwellings. The proposed development would triple the size of the village and change its character. The village would be asked to accept 43% of the development of the borough.

West Horndon village is mentioned in the 1086 Doomsday Book. The scale of the development proposed would swamp the existing village and would result in creating a new settlement that threatens to make the the current commercial and community centre of the village redundant or even polarise the village by creating a competing commercial area to the existing areas. The plans do not enhance the village but are a bolt-on to the village.

The plan contains few details to support the allocation of a major development to a small village. For example a variety of alternative, modern methods of sustainable sewage treatment are suitable and environmentally beneficial which could be used in the less populated north of the borough, but these appear not to have been investigated. For example, near West Horndon, in St Mary's Lane is a brand new settlement of 10-12 houses with an independent waste water treatment which is commercially viable as all properties have been sold. This should be thoroughly investigated and replicated where possible in the areas discounted as alternative options 3 (semi dispersed growth) and 4 (dispersed growth) in section S1 Spatial Strategy.

National guidance states that Local Planning Authorities should assess the quality and capacity of infrastructure, water supply, waste water and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education and flood risk, and its ability to meet forecast demands. This has not been done. For example the preferred options document makes reference to an evidence based and infrastructure, but is says that an "Infrastructure Delivery Plan is forthcoming". It is essential that the borough council provide a plan that address the following issues: West Horndon is several degrees cooler than the surrounding town areas and heating is very important in the long winter months, the broadband is very slow, the primary school and doctors surgery are already at full capacity and there is a legal obligation for authorities to provide school places and healthcare to everyone who needs it. The area is marked as a flood risk. The lack of evidence is not acceptable and full studies would need to be carried out and consulted upon before any agreement to develop takes place.

We are being asked to comment on a major and very significant proposal, but only being presented with an unfinished outline of what is proposed. The benefits for the village are unstated and unknown. There is no proposal of how the scheme might seek to mitigate against any harmful impacts.

The Borough Council are attempting to run a full consultation exercise on a very draft proposal which needs further research and proper evidence. It would probably be open to judicial review if passed in its present form.

2. Consultation process
The government has said that, "too often power was exercised by people who were not directly affected by the decisions they were taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them".

I feel that this plan and the consultation process have been done with a top down process and not bottom up, it feels like the borough council are not listening to the community. I do agree that any dwellings should be developed on the green belt land identified on the plan as 037. There is no natural stopping boundary in this proposal and I believe in time would be extended to cover all the land up to the A127.

The national guidelines state that 'Local Plans should develop robust and comprehensive policies'. The plan presented to residents is still in its infancy and has lots of gaps (flooding, transport infrastructure, health and educational services, amenities, public transport are still to be considered). Until this is carried out the proposal is neither robust nor comprehensive. The borough council need to carry out a study of West Horndon and the other sites mentioned above in order to accurately ascertain whether its plans are affordable. It is easy to build houses, it is another thing to enhance a community. The developers will build the houses and walk away leaving remaining problems and challenges on the doorstep of the Borough Council and West Horndon residents to solve and pay for.


3. Metropolitan Green Belt
The National Planning Policy Framework states that the government attaches great importance to Green Belts and to build on them is in appropriate and harmful. The large plot of 037 is green belt and has no boundary and creep will eventually result in it being built on to the A127 boundary.

If building has to take place in West Horndon then is should be done on the brown belt areas. Suitable brown belt areas are the West Horndon Industrial Estate. There are also brown belt areas at Hutton Industrial, Waits Way industrial Estate and the site formerly housing Elliott's night club. Timmerman's nursery on the 127 was formerly green belt land and if it were to be purchased would be a site suitable for dwellings. Ingatestone have a garden centre which could be developed into residential dwellings. As stated above, there is a site of 10-12 newly built houses which have sold successfully, that have an independent sewage system. This could be replicated across the north of the borough. I would prefer not to see one dwelling built on green belt. However IF green belt land in West Horndon has be built upon then perhaps extending the town along Station Road, and extending the park behind the dwellings and opening an entrance onto Station Road to provide a boundary might be an option. This would extend the lighting along Station Road and along with newly developed suitably lit pathways in the park would provide safe areas for jogging and walking for all age groups, which at the moment is missing from the village. This could provide an exceptional benefit to all members of the community.

4. Cohesion with local amenities
The last census shows that West Horndon contains 750 dwellings, with some 1900 people. The proposal is for an additional 1500 dwellings of yet undetermined density. This is a major proposal which will have a significant impact on the current residents and the proposed new residents. For example the village a limited range of shops (two corner shops, two fireplace shops, several hairdressers and beauty treatment shops, one or two small cafes. The corner shops shut at 8pm and the other shops are all closed by 5pm. The ATM charges to withdraw money. The majority of events running in the village hall run during the day. The village does not have a secondary school and has limited and unreliable bus runs to the schools. The bus service is limited and also unreliable (with perhaps two busses a day to Brentwood and return.) The morning commute to Fenchurch Street is already at full capacity and Network Rail have no plans to upgrade the station, the ancient cement foot bridge, the very dangerous pedestrian entrance (it has no footpath, frequently floods, and near constant low hanging greenery on the way in which includes rosebushes). Availability of doctors is over stretched, there is a three day wait and the surgery does not open before 9am or after 5pm and never on a Saturday, and it closes for 2 hours at lunch! The primary school is at full capacity and there is little for kids to do after school. Unlike the rail link between Shenfield and Ingatestone, the rail at West Horndon only leads out of the borough, thus a more reliable and affordable bus link to Brentwood is essential if the borough wishes to attempt to contain money within the borough. In particular if jobs are to be created within West Horndon it would be good if the council could support residents with in the borough to get to West Horndon and have access to these jobs. If the industrial estate located at West Horndon is to be moved to the M25 site then a reliable and affordable link between the West Horndon train station and the new industrial estate is essential. Shenfield will soon receive Cross rail and despite being advertised as 'end of the crossrail line' is in fact one stop to Liverpool Street and therefore makes access to Heathrow extremely quick indeed! Travel between West Horndon, Billericay and Shenfield is through busy, winding country lanes.

Creating additional dwelling would need a local shop that opens later than 8pm; a free to use ATM; additional money and resources to allow the village hall to run classes and events after work hours; a completely upgraded bus service with frequent and reliable journeys to Brentwood; the doctors surgery too would need more resources to allow it to open for longer hours and Saturdays.

It would be good if a much more thought could be given to the proposed retail development on the brownfield site so that it enhances rather than competes or takes away from the village centre and heart.

5. Impact on the countryside and character of the village
The village is a small low density settlement and is surrounded all by open countryside. Plot 037 has been farmed for years for wheat, oil seed rape, and peas. Construction of 1,000 dwellings that green belt farmed land will reduce food available to the UK, less land for wildlife and loss of ancient hedgerows and borders. It will also destroy the open setting and rural character of the village.

6. Impact on the residents
If any dwellings are to be built on West Horndon Brown Field Sites the residents should really have a say in the mix, proportion and density of the dwellings proposed. The draft plan and road shows did not indicate what is proposed. We would like low density development please. The proposed location of new shops and 'new village hall' is close to existing dwellings and noise of large lorries backing up will travel. Timings of deliveries will need to be limited and agreed. I disagree with a new village hall as proposed by the developers, we really don't need two and it will give the village two centres, thus polarising it - so much for integrating old and new!

The volume of traffic will increase through the village including additional trucks supply the shops and take away the waste. Back gardens currently not over looked will be intruded and the village will lose its rural character, so any development against existing really should be low level. Any development needs to be agreed by the residents and again, I say not one house should be built on green belt land.

7. Impact on the road and junctions in the borough
The major roads of 127 and 128 are already unable to cope with the morning and evening flows of traffic. To create an additional lane and make the dual carriage ways three lanes (effectively making them motorways) would be extremely costly and involve removing several homes. The Station Road 128 Junction would require redevelopment. The bridge over the railway station is an s bend and narrow. it would need to be widened and become a modern 'carbuncle' on the side of the village.

The junction at the station, the current industrial estate is a dangerous blind spot. Traffic coming over the bridge cannot see traffic exiting the station nor from the estate. Traffic from the station exit is unable to see traffic coming over the bridge. Pedestrian do not have a crossing across station road and need to run the width of two lanes and two bus stops - a very wide stretch of road between the proposed site and the station. If dwelling are built on the industrial estate the crossing to the railway station and bus station (for children returning from secondary school) will be extremely dangerous. The proposed small roundabout proposed by the developers would not work. It appears to be a lazy and cheap solution and needs proper investigation. The pedestrian entrance to the station is shared with the vehicles. There is no footpath.

Existing junctions from 127 to the village are inadequate and vehicles need to slow down to 20mph and lower to safely go onto these roads, at the annoyance and indeed horror of other road users which, when able, can travel at 60mph.

There are no footpaths to the west of the west of the village along St Mary's Lane which lead to winding narrow roads.

8. Flood risk
The proposed plot of 037 is the flood plain for Thorndon Park. It does indeed flood and has done badly 1958, 1981 and 2012. An assessment of the drainage in the area would need to be carried out before any building is planned in West Horndon. The Environment Agency web site shows West Horndon and Bulphan as being at risk of flooding. It is the low lying area with the hills of Brentwood to its north. Flood alleviation in the area will have a knock on affect to land south of West Horndon.

9. loss of current employment
The brownfield site proposed to be used is almost 17 hectares of employment land. It will be essential that existing businesses can be relocated to near by sites efficiently, cheaply and with benefit to the businesses so that they are not lost to other boroughs in the area. We need to ensure that we local employment is encouraged.


I really do care for the village I have chosen to live in and welcome good well-integrated, robustly investigated and sustainable development. In the years ahead I will not wish to explain to my family why developers were able to walk away with huge profits yet able to leave the village with long-term, expensive challenges that the community and borough council have to solve and pay for.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1636

Received: 02/10/2013

Respondent: Mr Paul Morris

Representation Summary:

Objects because of lack of evidence base and research on particular areas around the borough.

Full text:

Having now had time to assess the proposed plan for Brentwood's development, as a West Horndon resident I write to express my thoughts and concerns for the plans for the village I live in, but firstly I would like to express my extreme disappointment to learn of such a large scale project proposal via the front page of the local newspaper, and without any prior notice or consultation with myself and fellow residents of what is in my opinion a truly great village, and one that should be treated with the equal respect that is shown by those people who have made it their home. I appreciate that work has been done in the last few weeks, and I am truly grateful to all those people involved within the local council and our own parish council, but to see front page news a few weeks back for a plan to treble the size of the population in the area that you live in is truly shocking. In a nutshell, on a personal note, trying to give you some perspective of how one receives such news, this projected plan leaves me, and I certainly feel many of my fellow residents, with a feeling of a lack of respect paid to us by this proposal, ft's unpleasant, it feels like an attack on your way of life, this is the reality, and I am concerned that such a likely reaction has not been considered well in this proposal, and if it actually has, I put it to you that there clearly exists a lack of respect for the people of this village. The sheer size of this project naturally delivers a threat to the way of life we enjoy here currently, and it doesn't take a genius to identify there are inherent risks, and that significant changes in infrastructure will be required. I am truly astounded that some of the key discussions that are critical to this project such as the impact on the local school, our roads, the increase on the rail-passengers, flood risk, do not seem to have been researched at all well at this stage, if at all. To hear this lack of research after learning of the project and its scale in your local paper is very disappointing. The people of West Horndon are a great community, and are worthy of better treatment, and a less dramatic and better researched proposal for change in their neighbourhood. Despite the positive intentions of this project, and one can of course understand these intentions and the opportunities that West Horndon may provide for new settlement, we should not ignore what makes this village great and the community it has become today. There exists within the plan a great risk of destroying this community as we know it with the scale of this project and the lack of research currently undertaken. I will now highlight my key concerns:

Scale
43% of the target new housing for Brentwood being allocated to West Horndon is far too excessive a figure despite the opportunities the village is deemed to bring. How on earth can the village be expected to bear this huge majority share of the borough's target new housing?. It is truly mindblowing, and again how do you expect residents to react? - and i f you were expecting such a response, I stress again you are knowingly showing a lack of respect to the people of West Horndon. A % figure this high should surely highlight to you that an unfair proportion is being allocated to West Horndon. People invested in their homes in this area due to the village's way of life. As my local council, I expected you to recognise and help me maintain this way of life. The changes you propose completely alter what was an easy decision to make West Horndon our home. Surely you can understand why such a huge project worries me? Especially one with such poor early research.

Top Down nature of this proposal.
As already mentioned, I am disappointed at the level of engagement with the residents in the early stages of such a huge proposed change to our way of life. I refer to the Localism Act here, which highlights the natural reaction and resentment that such actions bring.

Metropolitan Green Belt
I believe all Green Belt should remain so, show me a genuine person that doesn't. I would like to see the targeted Industrial Estates become housing, this part of the project I agree to be positive for both the existing village and the new settlements, but a more reasonable number of houses should be considered and debated with residents.

Sustainable Location
Due to the evident inadequacies that West Horndon has for such growth, there needs to be far better researched feedback to residents to enable people to make their own informed decisions on whether the area can remain providing services and a lifestyle that residents are currently used to. I have no confidence whatsoever currently that the village can be considered a sustainable location following such a dramatic change. This is critical, and from what I see currently, there is a huge amount of work to do to convince residents that sustainability is achievable.

The "Village" and its setting
Why do people choose to live in West Horndon? Why do people move to West Homdon? The answer is because it provides a countryside village enviromnent in a great borough that provides beautiful views, wildlife in abundance, a certain type of home for a certain type of individual/family, ft's not for everybody, but it has qualities that appeal to certain people. The small population and open space are some of these qualfties, and provide for the "village" status.

People
invest their life's savings here when they make this place their home, and they invest based on a typically quieter environment than the average town. Your proposed plan carries a huge risk to this investment, and i f one was to consider this in pure purchasing terms as some kind of "contract', would it be fair to say that what one has purchased has changed so much as to be something that the purchaser did not intend to purchase at the outset of the contract? Would West Horndon remain a village?

Roads
Traffic increase is a concern. The A127 is appalling at rush hour. The abolishment of the Industrial Estate provides for less HGV's, but the growth in smaller family cars will be huge. The roads are currently inadequate for this projected growth, and there is no sight of a convincing plan or strategy for the accommodation of this increased traffic.

Flood Risk
This risk is one close to my heart and a sensitive subject. Our home, and four of our neighbours were flooded throughout on Christmas Day 2012. The past year has been the most difficult of my
life, restoring our home, and endeavoring to maintain everyday life in the process. We lost our
next-door neighbour, a dear old lady, moved into temporary accommodation, shortly after the event. This change in lifestyle, albeit temporary, clearly had too great an impact, but I hope demonstrates the impact a dramatic change in lifestyle can have for some people. Sorry to paint this sad picture, but its fact, and I do so you can understand the significance of this flood event. A not so merry Christmas, a holy flood maybe? Our home was flooded in every room, the entire house is currently still being restored, room by room. I remind you that I am a resident in Brentwood. I have heard nothing whatsoever from Brentwood Council, which is fine, we've coped and I'm not sure to what extent you would get involved in such an event, so can only assume there seems no interest in this catastrophe, yet at the same time I am faced with the prospect of a repeat event. I put it to you that unless I consider some significant changes to my landscape, I will remain exposed to the peril of flood despite the ditch at the back of my property, which clearly is inadequate to withstand flooding.

That's obvious, its happened once, and the landscape remains unchanged. I ask you do you really
understand the risk imposed by flood in this village, and if so, why did my property flood?

Additionally, can you please explain why the new housing will not be exposed to flood, and
additionally whether similar precautionary work can be carried out on my own property.

Summary
I hope that I have managed to get across the concerns my family have with this project, and hope
that my criticisms will be viewed constructively, and that we accept that some housing would be positive, certainly in place of the current industrial area. I have been as honest as possible with my response, and hope that our reaction to this proposal can be understood to be a natural one, and one based on very real risks and concerns.

My family and I totally respect the need for the provision of housing for a growing population, but West Horndon is completely misunderstood in this proposal, with a short-sighted emphasis really based in my view on a station which happens to have lots of open land around it. There is extremely poor research and non-existent planning currently into the needs of the area to respond to such a significant change, and this added to the ignorance of people's reasons for choice of investment here, making the village their home, leaves me currently very disappointed for the first time since my arrival in Brentwood from London 10 years ago. Brentwood is a truly great borough, and we should all be proud of it. West Horndon is a great village, and we are proud to call it our home, and we truly hope it can remain so for the future.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1654

Received: 02/10/2013

Respondent: Mrs Vivienne Thompson

Representation Summary:

Objects because lack of evidence base. Without these details I can not assess the full impact so have to object.

Full text:

I have read the Local Plan 2015 - 2030: Preferred Options for Consultation with interest and while I can understand the overall rationale I must object to the proposed development at West Horndon. There are many reasons why the village of West Horndon objects. I will focus on the following:

Policy CP4: West Horndon Opportunity Area
Policy CP13: Sustainable Transport
Policy DM1: General Development Criteria
Policy DM5: Employment Development Criteria

Policy CP4: West Horndon Opportunity Area
Justification 3.7 states that West Horndon has "good road and rail access". Whilst true it does have a train station the train line, operated by c2c, runs from Fenchurch Street to Shoeburyness. It does not stop, nor pass through, any other stations in Brentwood Borough and peak trains run once every 20 minutes c2c has no plans to increase the frequency of the trains.

In order to gain rail access to the other Brentwood Borough stations travellers would have to either: travel to Upminster, change to the Greater Anglia line to Romford and change trains again to catch a train towards Brentwood; or, travel to Southend and change train lines to come back towards London.

Whilst West Horndon does provide good access to the City, the "good rail access" will not improve access to the Borough, nor help to keep jobs within the borough as those travelling by train are much less likely to live within the borough unless they live within West Horndon itself.

Policy CP13: Sustainable Transport
I commend you for seeking to reduce travel, congestion and pollution, but I fail to see how you will achieve this. The reduction in travel is linked to providing jobs in West Horndon, but these are likely to be in retail, with some small offices. Given that your own research to date shows that a higher than average percentage of Brentwood borough residents commute to central London, I would like to understand how retail and small offices will keep jobs local. What plans are in place to encourage those who would occupy the 1500 new homes in prime commuter belt to work locally? Without these details I can not assess the full impact so have to object.

Justification 3.57 seeks to reduce car travel, partly by introducing a Green Travel Route (3.59) to link Brentwood with West Horndon and the Enterprise park. The journey from Brentwood to West Horndon on the proposed Green Travel Route is 5.5 miles and currently would take c. 20 minutes at peak times, not including the additional time a bus requires to pick up and set down passengers. The journey from West Horndon to Brentwood would be 6.5 miles and take 27 minutes, again without accounting for the additional time required. I have to question again why those moving to the new home in the borough would make this journey to get to work when they could:

a. Commute to any of the other major employment centres on their train line (c2c/Greater Anglia). West Horndon to Basildon takes 8 minutes; Brentwood to Shenfield takes 6 minutes. Passengers can even get to Fenchurch Street and Liverpool Street in 30 and 38 minutes respectively.
b. Drive, taking short-cuts and not stopping at each bus stop, reducing their journey time and providing greater flexibility throughout the day.

At present, because I assume the transport assessment is still forthcoming, the frequency and practicality of such a service has not been determined. Nor has the cost of a ticket per journey/season tickets. Similarly, improved walking and cycling routes have not yet been defined. I would point out that to the average commuter, walking or cycling 5.5 - 6.5 miles to get to work would be considered too far and be too time consuming.

The bus journey on the proposed Green Travel Route has to utilise the A127. The road is already at capacity and arguably over capacity during peak times with a build up of traffic back past the Junction with the A128. Without understanding how the additional traffic, firstly from demolishing the industrial estate and building the new development, then from the occupants and business of the new development in West Horndon, would be accommodated on the A127 I can not asses if it is practical so can not support the plan.

Policy DM1: General Development Criteria
The policy states that the development should "have no adverse affect on the visual amenity, the character or appearance of the surrounding area". While you do acknowledge in Justification 4.3 that new dwellings should not look out of place, the addition of 1500 homes plus the other (mixed) development will treble the size of the village changing dramatically the character or 'feel' of the village. I, and many other residents of West Horndon, chose the village because we wished to live in a small, close-knit, community. Trebling the size of the village will remove this, it will no longer be the type of place in which I chose to live. In addition, there is a risk, given the location of the development, that a 'them and us' culture could develop. Without understanding how this will be sensitively managed I can not support the development.

Policy DM5: Employment Development Criteria
I can not agree that trebling the size of the village will mean that the development complies with point a. "be of a scale and nature appropriate to the locality". Point d requires vehicular access to avoid residential streets and county lanes. I have to question how this will be achieved. Current access to the site is via the main road in West Horndon which is a residential street. The development is planned over 15 years, this would be many, many years of disruption for the residents.

I am aware that there are many more objections to the proposed West Horndon development, including the flood risk as the village has flooded twice in the past three years. There is also concern that a secondary school has not been proposed, this would require further transport to be provided to enable children aged between 11 - 16 to attend a school, potentially in a neighbouring borough.

While I do support the development of brown-field sites I can not support the development of green-field sites. Moving the current West Horndon industrial park to a new location with vastly improved road access makes good sense, as does developing the current Industrial site to accommodate new housing and a small mix of other amenities. The current infrastructure is also significantly more likely to be able to cope with a smaller scale development.

I would like to understand how the neighbouring boroughs have been consulted about the plans. As West Horndon is on the very edge of Brentwood borough, any increases to population will impact both Havering and Thurrock. What impact is this expected to have on them and are they able to cope with the proposals?

In conclusion, I can not support the development plans as they stand for West Horndon as I do not believe the village or the infrastructure can support them. I also question the time and cost required to make improvements to the infrastructure if the plans were to go ahead as shown. How would the drastic improvements be funded?

I would be happy to discuss my comments and look forward to the Community Master Planning exercise.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1659

Received: 02/10/2013

Respondent: Mr Gary Thompson

Representation Summary:

Objects because lack of evidence base. Without these details I can not assess the full impact.

Full text:

I have read the Local Plan 2015 - 2030: Preferred Options for Consultation with interest and while I can understand the overall rationale I must object to the proposed development at West Horndon. There are many reasons why the village of West Horndon objects. I will focus on the following:

Policy CP4: West Horndon Opportunity Area
Policy CP13: Sustainable Transport
Policy DM1: General Development Criteria
Policy DM5: Employment Development Criteria

Policy CP4: West Horndon Opportunity Area
Justification 3.7 states that West Horndon has "good road and rail access". Whilst true it does have a train station the train line, operated by c2c, runs from Fenchurch Street to Shoeburyness. It does not stop, nor pass through, any other stations in Brentwood Borough and peak trains run once every 20 minutes c2c has no plans to increase the frequency of the trains.

In order to gain rail access to the other Brentwood Borough stations travellers would have to either: travel to Upminster, change to the Greater Anglia line to Romford and change trains again to catch a train towards Brentwood; or, travel to Southend and change train lines to come back towards London.

Whilst West Horndon does provide good access to the City, the "good rail access" will not improve access to the Borough, nor help to keep jobs within the borough as those travelling by train are much less likely to live within the borough unless they live within West Horndon itself.

Policy CP13: Sustainable Transport
I commend you for seeking to reduce travel, congestion and pollution, but I fail to see how you will achieve this. The reduction in travel is linked to providing jobs in West Horndon, but these are likely to be in retail, with some small offices. Given that your own research to date shows that a higher than average percentage of Brentwood borough residents commute to central London, I would like to understand how retail and small offices will keep jobs local. What plans are in place to encourage those who would occupy the 1500 new homes in prime commuter belt to work locally? Without these details I can not assess the full impact so have to object.

Justification 3.57 seeks to reduce car travel, partly by introducing a Green Travel Route (3.59) to link Brentwood with West Horndon and the Enterprise park. The journey from Brentwood to West Horndon on the proposed Green Travel Route is 5.5 miles and currently would take c. 20 minutes at peak times, not including the additional time a bus requires to pick up and set down passengers. The journey from West Horndon to Brentwood would be 6.5 miles and take 27 minutes, again without accounting for the additional time required. I have to question again why those moving to the new home in the borough would make this journey to get to work when they could:

a. Commute to any of the other major employment centres on their train line (c2c/Greater Anglia). West Horndon to Basildon takes 8 minutes; Brentwood to Shenfield takes 6 minutes. Passengers can even get to Fenchurch Street and Liverpool Street in 30 and 38 minutes respectively.
b. Drive, taking short-cuts and not stopping at each bus stop, reducing their journey time and providing greater flexibility throughout the day.

At present, because I assume the transport assessment is still forthcoming, the frequency and practicality of such a service has not been determined. Nor has the cost of a ticket per journey/season tickets. Similarly, improved walking and cycling routes have not yet been defined. I would point out that to the average commuter, walking or cycling 5.5 - 6.5 miles to get to work would be considered too far and be too time consuming.

The bus journey on the proposed Green Travel Route has to utilise the A127. The road is already at capacity and arguably over capacity during peak times with a build up of traffic back past the Junction with the A128. Without understanding how the additional traffic, firstly from demolishing the industrial estate and building the new development, then from the occupants and business of the new development in West Horndon, would be accommodated on the A127 I can not asses if it is practical so can not support the plan.

Policy DM1: General Development Criteria
The policy states that the development should "have no adverse affect on the visual amenity, the character or appearance of the surrounding area". While you do acknowledge in Justification 4.3 that new dwellings should not look out of place, the addition of 1500 homes plus the other (mixed) development will treble the size of the village changing dramatically the character or 'feel' of the village. I, and many other residents of West Horndon, chose the village because we wished to live in a small, close-knit, community. Trebling the size of the village will remove this, it will no longer be the type of place in which I chose to live. In addition, there is a risk, given the location of the development, that a 'them and us' culture could develop. Without understanding how this will be sensitively managed I can not support the development.

Policy DM5: Employment Development Criteria
I can not agree that trebling the size of the village will mean that the development complies with point a. "be of a scale and nature appropriate to the locality". Point d requires vehicular access to avoid residential streets and county lanes. I have to question how this will be achieved. Current access to the site is via the main road in West Horndon which is a residential street. The development is planned over 15 years, this would be many, many years of disruption for the residents.

I am aware that there are many more objections to the proposed West Horndon development, including the flood risk as the village has flooded twice in the past three years. There is also concern that a secondary school has not been proposed, this would require further transport to be provided to enable children aged between 11 - 16 to attend a school, potentially in a neighbouring borough.

While I do support the development of brown-field sites I can not support the development of green-field sites. Moving the current West Horndon industrial park to a new location with vastly improved road access makes good sense, as does developing the current Industrial site to accommodate new housing and a small mix of other amenities. The current infrastructure is also significantly more likely to be able to cope with a smaller scale development.

I would like to understand how the neighbouring boroughs have been consulted about the plans. As West Horndon is on the very edge of Brentwood borough, any increases to population will impact both Havering and Thurrock. What impact is this expected to have on them and are they able to cope with the proposals?

In conclusion, I can not support the development plans as they stand for West Horndon as I do not believe the village or the infrastructure can support them. I also question the time and cost required to make improvements to the infrastructure if the plans were to go ahead as shown. How would the drastic improvements be funded?

I would be happy to discuss my comments and look forward to the Community Master Planning exercise.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1891

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Representation Summary:

Paragraph's 2.29 and 2.32 of the consultation document identify that BBC has commissioned a number of technical studies to inform their view of how OAN can be met and how many homes can be accommodated. This flawed approach is for example highlighted in paragraph 2.32 which states that "Evidence suggests that a higher level of growth would significantly worsen existing traffic congestion problems (Traffic Modelling Study - forthcoming)". It is considered that without the forthcoming Traffic Modelling Study, the Council do not possess the necessary up to date evidence base.

Full text:

See Attached

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1986

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

Representation Summary:

It is noted that the Borough Council has decided to place greater emphasis on the need to protect the Green Belt, than the need to provide for full OAN. As a result, the policy makes provision for 3,500 new dwellings against an interim OAN of 4,962 to 5,600 dwellings (331 to 373 homes a year). The fact that the Council has decided to plan for a figure well below this figure makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no, or only a limited, green belt function and which should be identified for residential development following a limited review of green belt boundaries). It is the Company‟s view that the Council will need to identify sites falling within all of the above four categories if it is to produce a "sound‟ Local Plan

Full text:

See Attached

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 2003

Received: 24/09/2013

Respondent: Maldon District Council

Representation Summary:

For reasons set out in the attached letter, relating to duty to co-operate and local capacity issues in Maldon District, Maldon District Council concludes that it is not possible to consider taking additional growth from neighbouring authorities or authorities within the three housing market areas that Maldon participates in.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 3381

Received: 02/10/2013

Respondent: JTS Partnership LLP

Representation Summary:

As a preliminary point, we highlight a concern that the Council has not yett published the Objectively Assessed Needs for Brentwood housing report. As an objective assessment of housing needs should form the basis of the growth strategy, which underpins the Plan, the absence of such information considerably compromises the ability of stakeholders to prepare full representations.

Full text:

see attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 3387

Received: 01/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

Representation Summary:

Paragraph's 2.29 and 2.32 of the consultation document identify that BBC has commissioned a number of technical studies to inform their view of how OAN can be met and how many homes can be accommodated.Paragraph 2.29 acknowledges that the majority of this work has not yet been published, and on this basis it is considered that the selection of a Preferred Option (which consequently rules out other approaches) is unsound. The absence of relevant technical work in order to support this decision is contrary to all four tests of soundness identified within paragraph 182 of the NPPF: positively prepared, justified, effective and consistent with national policy.

Full text:

See attached