POLICY R21: LAND SOUTH OF INGATESTONE

Showing comments and forms 1 to 5 of 5

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22479

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Policy R21 B. d. covers 2 separate matters (landscape buffers and heritage) and should be split into two criteria.

Change suggested by respondent:

Amend Policy R21 B. d. as follows to separate into two criteria -

d. provide for appropriate landscaping and buffers along sensitive boundary adjoining the A12 and railway line; and

e. provide a heritage assessment taking account of archaeological potential for the proximity to Roman Road

Full text:

3. Effective.

Policy R21 B. d. covers 2 separate matters (landscape buffers and heritage) and should be split into two criteria.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22573

Received: 19/03/2019

Respondent: Essex Wildlife Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy wording lacks a commitment to deliver biodiversity net gain.

Change suggested by respondent:

Policy wording should be amended as follows:

b. provision for "multifunctional" public open space "to deliver a measurable net gain in biodiversity";

Full text:

Policy wording lacks a commitment to deliver biodiversity net gain.

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 23268

Received: 21/03/2019

Respondent: Mid and South Essex STP

Representation Summary:

Anticipated mitigation as a result of development on this site should include contribution towards increasing capacity by means of extension, reconfiguration or refurbishment or/and recruitment costs.

Full text:

1.0 Introduction
1.0.1 Thank you for consulting the Basildon & Brentwood Clinical Commissioning Group (CCG) and the Mid and South Essex Sustainability and Transformation Partnership (STP) on the above emerging Local Development Plan (LP) Document.
1.1 In reviewing the context, content and recommendations of the LP Document and its current phase of progression, the following comments are with regard to the Healthcare provision on behalf of the STP
2.0 Existing Healthcare Position in the Emerging Plan Area
2.1 The LP Document covers the administrative area of Brentwood.
2.2 Currently, within the administrative area, healthcare provision incorporates a total of 9 GP Practices, 13 pharmacists, 9 dental surgeries, 10 Opticians, 2 community clinics and 2 community hospitals.
2.3 These are the healthcare services available that this Local Plan must take into account in formulating future strategies.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 26110

Received: 19/03/2019

Respondent: Mrs. Dorothy Auduc

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Ingatestone Garden Centre: The plan showing the garden centre is not correct.
a) There are two pieces of land between Burnt House Lane and the garden centre tat should not be included IE: the plot of Green Belt behind the gardens of 2 and 2A BHL and a further large plot of land which is owned by somebody else and has nothing to do with the garden centre.
b) Between the GC and the A12 works site is the recycling centre. Have you overlooked this?
C) The proposed development started with 60 homes which was far too many bearing in mind its position. Now this has been increased to 161 homes plus a further 57 homes a 1/4 of a mile down Roman Road. This will mean 218 homes with approx. 400 or more extra cars all using Roman Road? The slip road to the A12 which is needed for emergency services.
D) This site is just too big? In the wrong place.

Change suggested by respondent:

Remove site R21 from the plan

Full text:

Ingatestone Garden Centre: The plan showing the garden centre is not correct.
a) There are two pieces of land between Burnt House Lane and the garden centre tat should not be included IE: the plot of Green Belt behind the gardens of 2 and 2A BHL and a further large plot of land which is owned by somebody else and has nothing to do with the garden centre.
b) Between the GC and the A12 works site is the recycling centre. Have you overlooked this?
C) The proposed development started with 60 homes which was far too many bearing in mind its position. Now this has been increased to 161 homes plus a further 57 homes a 1/4 of a mile down Roman Road. This will mean 218 homes with approx. 400 or more extra cars all using Roman Road? The slip road to the A12 which is needed for emergency services.
D) This site is just too big? In the wrong place.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 26512

Received: 19/03/2019

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

R21 is a relatively narrow triangular site lying between the mainline railway and the A12. Previously described as land adjacent to the garden centre, we now note that the proposed allocation includes the garden centre. The site is at a level with the A12 and the railway, with consequent air and noise pollution issues. The allocation's extension northwards to the rear of homes in Burnthouse Lane means that it will form a long, southern extension to Ingatestone. It will consolidate coalescence with Mountnessing, which lies to the west of the site on the other side of the A12. Our comments made in 2018 regarding social isolation and pollution remain correct. R03, R16, R17, R21, R22 allocations are all bounded by the A12 to a greater or lesser extent. As noted in our representations on Policy NE05, the Pre-Submission Document's paragraph 8.50 states that transport generated emissions are the prime source of air pollution in the Borough. We have consistently questioned the wisdom of locating new housing next to the A12 on the grounds of public health. All these proposed allocations, in whole or part, have significant issues resulting from their proximity to principal sources of air and noise pollution. There is conflict with the Pre-Submission Document's own policies on these issues, including Policy NE05. Consequently we are suggesting a number of modifications to the relevant policies.

Change suggested by respondent:

We propose the following modifications for the reasons outlined in our response to the Local Plan consultation. Strengthen the wording of all policies to ensure that appropriate air and noise pollution measures form an integral part of any development proposals. Wherever there is reference to either the A12, or the mainline railway, the related criterion should read as follows:
"appropriate measures, including barriers, embankments and landscaping, to reduce air and noise must be provided along the site's boundary(ies) with the A12 and/or the mainline railway."
Removal of R17 from Policy R16 and R17.
Removal from proposed allocation R03 of the elliptical shaped piece of land between the A1023 Chelmsford Road and the A12 Marylands Interchange, and the area to the north of the site bounded by the Marylands Interchange to the north, the railway line to the south-east, a part of Arnold's Wood to the south-west and Chelmsford Road to the north-west.
Removal of Allocation R21 on grounds of poor physical environment, isolation from the main settlement of Ingatestone and coalescence with the village of Mountnessing.
Removal of Allocation R22 on grounds of poor physical environment

Full text:

We have grouped these polices together since our comments relate to their common characteristics. The most important is that these allocations are all bounded by the A12 to a greater or lesser extent. As noted in our representations on Policy NE05, the Pre-Submission Document's paragraph 8.50 states that transport generated emissions are the prime source of air pollution in the Borough. We have consistently questioned the wisdom of locating new housing next to the A12 on the grounds of public health.
Policy R16 and R17 refers to two parcels of land on either side of the A12, currently designated as Green Belt. The Policy says that new development on this land should consider, amongst other things, providing for:
"... appropriate landscaping and buffers along sensitive boundary adjoining the A12."
R17 is a relatively narrow strip of land on the southern side of the A12. It is currently a relatively wooded area at around the same level as the A12. Any landscaping here would be confined by the narrowness of the site and ineffective as a barrier against air and noise pollution. This should be removed from the allocation and designated instead as open space.
R16 is a larger and better configured space and we agree that a degree of development here could be achieved in an acceptable environment, provided there are strong and effective measures to reduce air and noise pollution from the A12. Again, the land is on much the same level as the A12. Clearly, the further any development is located away from the A12 then the less the risk of pollution measures to mitigate.
Policy R16 and R17 is weakly worded on the need for appropriate mitigating measures. It should state that any new development will provide effective measures along boundaries with the A12 and elsewhere. We note that the Policy also includes requirements for public open space and provision of pedestrian and cycling connections. Again, the Policy should insist on these provision and not simply ask potential developers to "consider" them.
Effective noise and pollution barriers do not look aesthetically pleasing. Adequate space will be needed for landscaping to mitigate their visual impact.
R03 is one of the Pre-Submission Document's strategic allocations. Much of this allocation seems sensible and logical. It is bounded to the north-west by the A12 and south-east by the main railway line. As with Policy R16 and R17, R03 says new development should consider providing for:
"... appropriate landscaping and buffers along sensitive boundary adjoining the A12."
As with Policy R16 and R17, Policy R03 should be more strongly worded to insist on appropriate mitigation measures. There are two parts of the allocation which should be removed and left in the Green Belt. The first is the elliptical shaped piece of land between the A1023 Chelmsford Road and the A12 Marylands Interchange, unless it is specifically reserved for the employment uses mentioned in Policy R03 at A.e.:
"... provision of 2ha of land for employment purposes."
The Marylands Interchange is elevated at this point and would result in a poor residential environment.
The second is an area to the north of the site bounded by the Marylands Interchange to the north, the railway line to the south-east, a part of Arnold's Wood to the south-west and Chelmsford Road to the north-west. This site would also provide a poor and unhealthy environment for new homes as a consequence of its proximity to both the interchange and the mainline railway. Regardless of any mitigation measures, residential development this close to Arnold's Wood, already bisected by the railway line, can only be detrimental to its wildlife value.
R21 and R22 are both proposed allocations for Ingatestone. R21 is a relatively narrow triangular site lying between the mainline railway and the A12. Previously described as land adjacent to the garden centre, we now note that the proposed allocation includes the garden centre. The site is at a level with the A12 and the railway, with consequent air and noise pollution issues. The allocation's extension northwards to the rear of homes in Burnthouse Lane means that it will form a long, southern extension to Ingatestone. It will consolidate coalescence with Mountnessing, which lies to the west of the site on the other side of the A12. In our representations on 2018' s Preferred Sites Consultation, we said:
"This narrowing site, wedged between the A12 and the main railway line is completely unrelated to any existing residential area. The area would suffer from social isolation as well as air and noise pollution. Although the Ingatestone Nursery site would help to form a bridge with the rest of the village, it is our opinion that this site would retain significant disadvantages, and is not a sustainable location in either social or environmental terms."
We think this assessment remains true, even though the nursery now forms part of the allocation.
R22 - we still think it extraordinary to propose this allocation as a satisfactory environment for new homes. There are houses immediately to the south-west along Roman Road, but their presence should not be seen as a justification. The site is at a level with the A12, with the B1002 on the site's northern boundary elevated to cross the A12. We said in our response to 2018's Preferred Sites Consultation that no further consideration should be given to this site and nothing in the Pre-Submission Document has changed our views on this.
Our main point here is that all these proposed allocations, in whole or part, have significant issues resulting from their proximity to principal sources of air and noise pollution. There is conflict with the Pre-Submission Document's own policies on these issues, including Policy NE05. Consequently we are suggesting a number of modifications to the relevant policies.

Attachments: