Policy R18: Land off Crescent Drive, Shenfield (page 290)

Showing comments and forms 1 to 30 of 527

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26515

Received: 16/10/2019

Respondent: Cllr Chris Hossack

Representation:

The proposals for Cresent Drive would see an over concentration on housing here, the reduction is welcome and could well alleviate the concerns re flooding it also gives the policy more strength to resist over development

Full text:

The proposals for Cresent Drive would see an over concentration on housing here, the reduction is welcome and could well alleviate the concerns re flooding it also gives the policy more strength to resist over development

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26521

Received: 21/10/2019

Respondent: Mr John Darragh

Representation:

provided developer makes contribution to community investment levy to give local residents some benefit

Full text:

provided developer makes contribution to community investment levy to give local residents some benefit

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26533

Received: 01/11/2019

Respondent: Ms Rebecca Edwards

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

This site is BROWNFIELD, not Greenbelt like sites R25 and R26.

Change suggested by respondent:

The number of homes should be increased back to a minimum of 55 and policies R25 and R26 reduced by 20.

Full text:

This site is BROWNFIELD, not Greenbelt like sites R25 and R26.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26560

Received: 30/10/2019

Respondent: Mr Kevin Craske

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The reduction in the number of homes from 55 to 35 (almost 40%) in the Crescent Drive area is purportedly due to i) inconsistency of character, ii) implications on traffic and safety, iii) Development on an urban open space, iv) environment, habitat and flood impact. Shenfield is an affluent area so any extra homes are unwelcome and out of character unless they are large and expensive. The need for homes must outweigh this and the council must find a way to build homes where needed, not where residents object on this basis. This is NIMBYISM of the highest order and should NOT be allowed. Come on Brentwood do the right thing by ALL borough residents not just the rich few! Crescent Drive to be a quiet almost traffic free area when I go to the Community Hospital so where is the traffic coming from? It is within 1 mile of the A12 so where is the issue with highway access? This sounds like a made up excuse to give padding to this reduction of home build in the area. It is nonsense. How can a suburban area have an environment and habitat and flood risk which is of more importance than Green Belt? Our area of green belt is under severe risk as it is with the Thames tunnel plan and Brentwood council are making matters worse by adding to this pressure. In a Green Belt borough emphasis should be on urban/suburban new build not on using green belt as an easy option. Why are Shenfield opinions more important than that of West Horndon opinions? These justifications appear fatuous to me and this proposed change should be rescinded as the council and planning department appear to be making fools of themselves. These are not serious justifications for a re-think, more like a plan to try and shift as much new build as possible as far away from Brentwood Town as possible. When all recent road improvements are on the A12 corridor and the high speed link on rail is coming to Shenfield surely it makes sense to put as many new homes as possible in that area which is also rich in the settlement hierarchy with good transport links, shops and open areas. So again there in an obvious disconnect with no joined up thinking

Full text:

Dear Sir/Madam,
I would like to make the following comments on the Addendum of Focused changes the pre-submission local plan.
The initial statement that it is proposed to build an additional 70 homes at Dunton Hills Garden Village does not match up with the itemised changes. There are 70 homes being relocated from the Shenfield area and a further 20 homes from Blackmore Village area. That is a total of 90 homes. Where are the other 20 homes going to be located?
My specific comments on each proposal are detailed below;
1) Policy ROI
It appears that the Local Plan is to put all the homes it possibly can into Dunton Hills Garden Village at the expense of our local environment and habitat and flood risk rather than impose such a huge number of 70 homes in Shenfield. Obviously the environment and habitat in an urban area is far more important than green belt! Dunton Hills Garden Village is growing like Topsy and will be Dunton Hills Garden Town!
2) Policy R18
The reduction in the number of homes from 55 to 35 (almost 40%) in the Crescent Drive area is purportedly due to i) inconsistency of character, ii) implications on traffic and safety, iii) Development on an urban open space, iv) environment, habitat and flood impact.
1) I understand that Shenfield is an affluent area so any extra homes are unwelcome and out of character unless they are large and expensive. The need for homes must outweigh this and the council must find a way to build homes where needed, not where residents object on this basis. This is NIMBYISM of the highest order and should NOT be allowed. Come on Brentwood do the right thing by ALL borough residents not just the rich few!!
2) I find Crescent Drive to be a quiet almost traffic free area when I go to the Community Hospital so where is the traffic coming from? It is within 1 mile of the A12 so where is the issue with highway access? This sounds like a made up excuse to give padding to this reduction of home build in the area. It is nonsense.
3) How can a suburban area have an environment and habitat and flood risk which is of more importance than Green Belt? Our area of green belt is under severe risk as it is with the Thames tunnel plan and Brentwood council are making matters worse by adding to this pressure. In a Green Belt borough emphasis should be on urban/suburban new build not on using green belt as an easy option. Why are Shenfield opinions more important than that of West Horndon opinions?
All these justifications appear fatuous to me and this proposed change should be rescinded as the council and planning department appear to be making fools of themselves. These are not serious justifications for a re-think, more like a plan to try and shift as much new build as possible as far away from Brentwood Town as possible. When all recent road improvements are on the A12 corridor and the high speed link on rail is coming to Shenfield surely it makes sense to put as many new homes as possible in that area which is also rich in the settlement hierarchy with good transport links, shops and open areas. So again there in an obvious disconnect with no joined up thinking!
3) Policy R19
There is a proposal reduction in scheduled new build homes from 75 to 45 (40%), curiously exactly the same percentage reduction. The same items are stated as the justification for its reduction. My previous comment on POlicy R18 are also very relevant on this proposal too. I find it discriminatory, disgraceful and highly offensive that Shenfield residents have a greater voice than I appear to. They will now have only 80 homes scheduled for build where as our small village will have hundreds more and a new town on our doorstep. The A128 and A127 are already at capacity and entry and exit from our village is already time consuming and risky. Adding more homes and risk. Still Shenfield will be safer I suppose.
4) Policy R25 & R26
Reductions in Blackmore Village from 70 to 50 (30%). The statements for justification are i) inconsistency with character, ii) impact on local services, iii) disagreement with settlement hierarchy, iv) Green Belt development and flood risk.
1) In a large village it is difficult to understand how a total of 70 new homes can make too much difference. There are already a large variety in the types of homes in Blackmore so again how can new build be out of character? What can a reduction of 20 homes do to improve the village character that much? It does not make sense and again appears to be NIMBYISM! Does the council think a token gesture will do in this case? That is how it appears.
2) The impact on local services of 50 homes is not much different to that from 70 homes. Blackmore has good local services with a rail link to Brentwood and this was part of the reasons given for locating hundreds of homes in West Horndon. Road access is good with easy access to the A414, A12,M25 and M11. It has 3 public houses, 2 village halls, sports and social club, football and cricket pitches and a village shop with a farmers market at weekends. Hardly hard done by and surely it could easily take 70 homes without any impact at all. So this part of the justification does not ring true!
3) What is the basis of the settlement hierarchy? Small population areas tend to provide only low order services such as Post Office and Newsagents, not 3 public houses, 2 village halls etc. This is a ridiculous statement as a justification.
West Horndon Village has 1 public house, 1 village hall, no sports and social clubs or cricket pitches etc but is going to have almost 500 extra homes with no improvement in service or facilities. What about our settlement hierarchy? We do not appear to matter to the council and are not as important a village as Blackmore obviously. Again discriminatory, disgusting and very insulting to residents of West Horndon. Where is our value? We pay the same tax to support the council but are obviously second class citizens.
As a separate issue, why has the number of homes on brownfields sites reduced from 1152 to 1132?. There is no mention of where, when or why! Still, I expect they will be relocated to Dunton Hills Garden Town obviously.
All these proposals appear to token gestures pandering to the affluent areas of Brentwood. They show no joined up thinking, there are no explanations of traffic resolution unless you are in the Shenfield area of course.
In my opinion they are poorly thought out and are simply not justifications but excuses for a bad plan which will be pushed through despite protests from residents and tax payers. It is in a mess still!

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26564

Received: 30/10/2019

Respondent: Mr Kevin Craske

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

As a separate issue, why has the number of homes on brownfields sites reduced from 1152 to 1132?. There is no mention of where, when or why! Still, I expect they will be relocated to Dunton Hills Garden Town obviously.

Full text:

Dear Sir/Madam,
I would like to make the following comments on the Addendum of Focused changes the pre-submission local plan.
The initial statement that it is proposed to build an additional 70 homes at Dunton Hills Garden Village does not match up with the itemised changes. There are 70 homes being relocated from the Shenfield area and a further 20 homes from Blackmore Village area. That is a total of 90 homes. Where are the other 20 homes going to be located?
My specific comments on each proposal are detailed below;
1) Policy ROI
It appears that the Local Plan is to put all the homes it possibly can into Dunton Hills Garden Village at the expense of our local environment and habitat and flood risk rather than impose such a huge number of 70 homes in Shenfield. Obviously the environment and habitat in an urban area is far more important than green belt! Dunton Hills Garden Village is growing like Topsy and will be Dunton Hills Garden Town!
2) Policy R18
The reduction in the number of homes from 55 to 35 (almost 40%) in the Crescent Drive area is purportedly due to i) inconsistency of character, ii) implications on traffic and safety, iii) Development on an urban open space, iv) environment, habitat and flood impact.
1) I understand that Shenfield is an affluent area so any extra homes are unwelcome and out of character unless they are large and expensive. The need for homes must outweigh this and the council must find a way to build homes where needed, not where residents object on this basis. This is NIMBYISM of the highest order and should NOT be allowed. Come on Brentwood do the right thing by ALL borough residents not just the rich few!!
2) I find Crescent Drive to be a quiet almost traffic free area when I go to the Community Hospital so where is the traffic coming from? It is within 1 mile of the A12 so where is the issue with highway access? This sounds like a made up excuse to give padding to this reduction of home build in the area. It is nonsense.
3) How can a suburban area have an environment and habitat and flood risk which is of more importance than Green Belt? Our area of green belt is under severe risk as it is with the Thames tunnel plan and Brentwood council are making matters worse by adding to this pressure. In a Green Belt borough emphasis should be on urban/suburban new build not on using green belt as an easy option. Why are Shenfield opinions more important than that of West Horndon opinions?
All these justifications appear fatuous to me and this proposed change should be rescinded as the council and planning department appear to be making fools of themselves. These are not serious justifications for a re-think, more like a plan to try and shift as much new build as possible as far away from Brentwood Town as possible. When all recent road improvements are on the A12 corridor and the high speed link on rail is coming to Shenfield surely it makes sense to put as many new homes as possible in that area which is also rich in the settlement hierarchy with good transport links, shops and open areas. So again there in an obvious disconnect with no joined up thinking!
3) Policy R19
There is a proposal reduction in scheduled new build homes from 75 to 45 (40%), curiously exactly the same percentage reduction. The same items are stated as the justification for its reduction. My previous comment on POlicy R18 are also very relevant on this proposal too. I find it discriminatory, disgraceful and highly offensive that Shenfield residents have a greater voice than I appear to. They will now have only 80 homes scheduled for build where as our small village will have hundreds more and a new town on our doorstep. The A128 and A127 are already at capacity and entry and exit from our village is already time consuming and risky. Adding more homes and risk. Still Shenfield will be safer I suppose.
4) Policy R25 & R26
Reductions in Blackmore Village from 70 to 50 (30%). The statements for justification are i) inconsistency with character, ii) impact on local services, iii) disagreement with settlement hierarchy, iv) Green Belt development and flood risk.
1) In a large village it is difficult to understand how a total of 70 new homes can make too much difference. There are already a large variety in the types of homes in Blackmore so again how can new build be out of character? What can a reduction of 20 homes do to improve the village character that much? It does not make sense and again appears to be NIMBYISM! Does the council think a token gesture will do in this case? That is how it appears.
2) The impact on local services of 50 homes is not much different to that from 70 homes. Blackmore has good local services with a rail link to Brentwood and this was part of the reasons given for locating hundreds of homes in West Horndon. Road access is good with easy access to the A414, A12,M25 and M11. It has 3 public houses, 2 village halls, sports and social club, football and cricket pitches and a village shop with a farmers market at weekends. Hardly hard done by and surely it could easily take 70 homes without any impact at all. So this part of the justification does not ring true!
3) What is the basis of the settlement hierarchy? Small population areas tend to provide only low order services such as Post Office and Newsagents, not 3 public houses, 2 village halls etc. This is a ridiculous statement as a justification.
West Horndon Village has 1 public house, 1 village hall, no sports and social clubs or cricket pitches etc but is going to have almost 500 extra homes with no improvement in service or facilities. What about our settlement hierarchy? We do not appear to matter to the council and are not as important a village as Blackmore obviously. Again discriminatory, disgusting and very insulting to residents of West Horndon. Where is our value? We pay the same tax to support the council but are obviously second class citizens.
As a separate issue, why has the number of homes on brownfields sites reduced from 1152 to 1132?. There is no mention of where, when or why! Still, I expect they will be relocated to Dunton Hills Garden Town obviously.
All these proposals appear to token gestures pandering to the affluent areas of Brentwood. They show no joined up thinking, there are no explanations of traffic resolution unless you are in the Shenfield area of course.
In my opinion they are poorly thought out and are simply not justifications but excuses for a bad plan which will be pushed through despite protests from residents and tax payers. It is in a mess still!

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26576

Received: 10/11/2019

Respondent: Mr Anthony Cross

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

The number of proposed dwellings should not be reduced. This site, being brownfield land, is much more appropriate for development compared to greenfield sites included in the LDP. For example, the additional 20 dwellings that could be built here, would go part of the way towards enabling the removal of sites R25 and R26 from the plan.

Change suggested by respondent:

The number of dwellings to be developed on this site should remain at 55.

Full text:

The number of proposed dwellings should not be reduced. This site, being brownfield land, is much more appropriate for development compared to greenfield sites included in the LDP. For example, the additional 20 dwellings that could be built here, would go part of the way towards enabling the removal of sites R25 and R26 from the plan.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26594

Received: 13/11/2019

Respondent: Mr. James Harris

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

This is a Brownfield site numbers should not be reduced

Change suggested by respondent:

20 houses should be re-instated to this site

Full text:

This is a Brownfield site numbers should not be reduced

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26607

Received: 13/11/2019

Respondent: Susan Harris

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

The 20 home reduction should be re-instated

Change suggested by respondent:

Brownfield site in town 20 additional homes will have less impact than on a small village with no infrastructure such as Blackmore

Full text:

The 20 home reduction should be re-instated

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26626

Received: 14/11/2019

Respondent: Punch Partnerships (PGRP) Ltd

Agent: Cordage Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

The proposed reduction in housing numbers in Shenfield and Blackmore reduces housing numbers in sustainable settlements where growth is needed, and puts them in a less sustainable location. In relocating the units to the proposed strategic allocation at Denton Hills, the provision of these units will inevitably occur later in the plan period, when the focus should be on early provision to address the current housing land supply shortfall. The site at Spital Lane is an ideal candidate, having minimal impact on the openness of the Green Belt, being capable of accommodating six houses without any risk of flooding.

Change suggested by respondent:

A much better solution would be to reprovide the units lost from the Shenfield and Blackmore allocations on sustainable sites in and around Brentwood. The site at Spital Lane is an ideal candidate, being located on the edge of the town close to services and facilities, having minimal impact on the openness of the Green Belt, and as per the Environment Agency comments on the most recent planning application, being capable of accommodating six houses without any risk of flooding. We therefore advocate that Spital Lane be allocated for housing in the emerging plan, along with other suitable smaller sites identified in the SHLAA, to make up the housing numbers lost in Shenfield and Blackmore.

Full text:

The proposed reduction in housing numbers in Shenfield and Blackmore is problematical for two reasons.
First, because it reduces housing numbers in sustainable settlements where growth is needed, and puts them in a less sustainable location.
Second, because in relocating the units to the proposed strategic allocation at Denton Hills, the provision of these units will inevitably occur later in the plan period, when the focus should be on early provision to address the current housing land supply shortfall.
A much better solution would be to reprovide the units lost from the Shenfield and Blackmore allocations on sustainable sites in and around Brentwood.
The site at Spital Lane is an ideal candidate, being located on the edge of the town close to services and facilities, having minimal impact on the openness of the Green Belt, and as per the Environment Agency comments on the most recent planning application, being capable of accommodating six houses without any risk of flooding.
We therefore advocate that Spital Lane be allocated for housing in the emerging plan, along with other suitable smaller sites identified in the SHLAA, to make up the housing numbers lost in Shenfield and Blackmore.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26633

Received: 15/11/2019

Respondent: Mrs Patricia Dillon

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

Brownfield site in ton centre no reduction should be allowed.

Change suggested by respondent:

Confirm objection to reduction.

Full text:

Brownfield site in ton centre no reduction should be allowed.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26640

Received: 18/11/2019

Respondent: Mr Adam Harris

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

Brownfield site with good transport & infrastructure

Change suggested by respondent:

This reduction should be reversed

Full text:

Brownfield site with good transport & infrastructure

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26653

Received: 19/11/2019

Respondent: Anglian Water

Representation:

We note that it is proposed to decrease the amount of housing on this allocation site to address comments made as part of the previous consultation. As an infrastructure provider we closely monitor housing growth in our region to align our planned investment with additional demand for water recycling infrastructure. Therefore we have no comments to make relating to the focused change to Policy R18.

Full text:

We note that it is proposed to decrease the amount of housing on this allocation site to address comments made as part of the previous consultation. As an infrastructure provider we closely monitor housing growth in our region to align our planned investment with additional demand for water recycling infrastructure. Therefore we have no comments to make relating to the focused change to Policy R18.

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26694

Received: 25/11/2019

Respondent: Mr Mr J Nicholls and Mr A Biglin (Land owners)

Agent: Sworders

Representation:

We support the following changes to the Pre-Submission Local Plan:
* Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes".
* Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes".
* Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes".
* Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
We support the reduction in housing numbers at the allocation sites in Shenfield and Blackmore, as this is justified by the evidence base.

Full text:

These representations are submitted in response to the publication of:
Brentwood Borough Council Local Plan Consultation on Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)
We object to the following change to the Pre-Submission Local Plan:
* Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,770 homes in the plan period".
We support the following changes to the Pre-Submission Local Plan:
* Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes".
* Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes".
* Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes".
* Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
We support the reduction in housing numbers at the allocation sites in Shenfield and Blackmore, as this is justified by the evidence base.
However, we object to the re-distribution of the 70 dwellings to the Dunton Hills Garden Village (DHGV) allocation, because it would mean that fewer homes would be delivered in the early years of the plan. The reliance on DHGV to deliver such a large proportion of the Borough's housing need within the early years of the plan is too great, particularly when smaller sites are available, some of which are brownfield.
Larger sites often take longer to deliver housing, because they typically have complex ownership structures and require significant investment in infrastructure. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that for sites of over 2,000 dwellings, the average timeframe between the validation date of the planning application and the delivery of the first dwelling was just under seven years. This compares with just under three years for smaller sites of up to 99 dwellings and therefore, whilst it is justified to reduce the housing allocation at the sites in Shenfield and Blackmore, the 70 dwellings should be re-distributed to suitable smaller developments rather than being added to DHGV.
Smaller sites are often able to come forward more quickly than larger sites because they are typically in single ownership and require less investment in infrastructure. They also attract smaller, more local housebuilding companies that would not be present on larger sites, enable more early deliveries and constitute a more sustainable approach towards meeting the housing need.
Brownfield sites should also be prioritised in line with the requirements of the NPPF, which states in paragraph 137 that:
'before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development'.
As a result, brownfield land should be utilised, with greenfield land being released only when all sustainably located, available and deliverable sites have been identified as allocations.
In contrast, Brentwood Borough Council propose relying entirely on the delivery of a single, large, greenfield site to be able to demonstrate and maintain a five-year supply in the early plan period - a method that has been criticised by several inspectors at Local Plan Examinations in Braintree District, Tendring District and Colchester Borough Council in relation to North Essex Garden Communities.
Due to the location of the Dunton Hills Garden Village allocation, a significant proportion of Brentwood's housing would be located on the Borough boundary with Basildon. The settlement would adjoin Basildon's Green Belt and although it was once intended for both Councils to locate settlements in this area, Basildon no longer propose this. It could therefore also be considered that the authorities have not complied with their duty to co-operate.
In conclusion, we object to the re-distribution of 70 dwellings into the Dunton Hills Garden Village allocation, considering instead that the dwellings should be re-allocated to more suitable smaller sites and brownfield land. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged, particularly when suitable alternative sites are available.

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26702

Received: 23/11/2019

Respondent: Mr John Lester

Representation:

This is a large brownfield site that is currently derelict and ripe for development. It is close to shops an main line rail station and on a bus route.

Full text:

This is a large brownfield site that is currently derelict and ripe for development. It is close to shops an main line rail station and on a bus route.

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26705

Received: 24/11/2019

Respondent: Mr. David Cartwright

Representation:

Denton village is being correctly planned and thought through in respect of the infrastructure to support housing developments ie schools doctors and road/rail links

Full text:

Denton village is being correctly planned and thought through in respect of the infrastructure to support housing developments ie schools doctors and road/rail links

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26706

Received: 24/11/2019

Respondent: Mr. David Cartwright

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

The number of planned houses should not be reduced as there is already the local infrastructure to support the proposed level of development

Change suggested by respondent:

Leave the number of houses as originally planned

Full text:

The number of planned houses should not be reduced as there is already the local infrastructure to support the proposed level of development

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26714

Received: 25/11/2019

Respondent: Mrs. Margaret Cartwright

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

The number of houses on this development should remain. This site has numerous facilities including railway, shops schools and medical support locally. Government policy is that brownfield sites must be developed in preference to green field sites and therefore the development of there's houses should be confirmed to protect any risk to greenfield sites

Change suggested by respondent:

The original number of houses must remain and not be reduced

Full text:

The number of houses on this development should remain. This site has numerous facilities including railway, shops schools and medical support locally. Government policy is that brownfield sites must be developed in preference to green field sites and therefore the development of there's houses should be confirmed to protect any risk to greenfield sites

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26722

Received: 25/11/2019

Respondent: Mr Barry Tydeman

Representation:

'I represent the Crescent Drive Residents Association. Broadly, we support we support Policy R18 for the Crescent Drive site: Reduction from 'around 55' to 'around 35 homes'. We have previously submitted that the Fairview application for this site be refused permission as contrary to Policies SP01, HP03 and HP14. Our petition had 500+ signatories against that proposal. We submit that it also fails the judge's decision criteria in Canterbury Council v Gladman Developments this year: a Planning Inspector must not decide in favour of an application meeting only one approved Development plan policy.

Barry Tydeman
For CDRA'

Full text:

Dear Sir

Brentwood Borough Council Local Plan Consultation on
Addendum of focused changes to the pre-submission Plan

I am writing on behalf of the Crescent Drive Residents Association ('CDRA') with our formal representation in response to the above. CDRA represents the residents of all 28 houses in Crescent Drive.

In principle we support the proposed changes to the pre-submission plan. Our interest in the Plan relates mainly to its relevance to the current planning application for 86 flats on the site of the former NHS Blood Centre in Crescent Drive and any future application for the development of flats in volume there.

We have previously submitted that the application (by Fairview) should be refused permission on the grounds that it is contrary to the Council's Planning Policies SP01, HP03 and HP14 and we have had 500+ signatories in support of our petition against the Fairview proposal. Thus we support Policy R18 for the Crescent Drive site in the pre submission plan: Reduction from 'around 55' to 'around 35 homes'.

We also submit that the Fairview application fails the criteria for approval in the judge's decision this year in Canterbury Council v Gladman Developments: that a Planning Inspector must take into account all the policies in the approved Development Plan and not decide in favour of an application which accords with only one of them; in that particular case, 'sustainable development'.

Yours sincerely

Barry Tydeman
For CDRA

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26724

Received: 25/11/2019

Respondent: Fairview New Homes Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation:

Please see attached letter
* The Council's failure to demonstrate that the strategic requirement of National
Planning Policy Framework have need met. Therefore, the Local Plan is not
legally compliant or sound;
* That no evidence or justification has been provided by the Council to justify the
reduction in the number of units allocated of the site;
* The lack of evidence and justification behind the Council's decision to reallocate
additional housing onto a large strategic Green Belt allocation where the delivery
has already been highlighted as risk within the Sustainability Appraisal 2019; and
* The continued failure of the Council to support the full capacity of a strategic site,
despite discussion with Development Management and Statutory Consultees
which demonstrate that the site could accommodate in excess of 55 units.

Change suggested by respondent:

Please see attached letter

Full text:

Please see attached letter:
Summary
* The Council's failure to demonstrate that the strategic requirement of National
Planning Policy Framework have need met. Therefore, the Local Plan is not
legally compliant or sound;
* That no evidence or justification has been provided by the Council to justify the
reduction in the number of units allocated of the site;
* The lack of evidence and justification behind the Council's decision to reallocate
additional housing onto a large strategic Green Belt allocation where the delivery
has already been highlighted as risk within the Sustainability Appraisal 2019; and
* The continued failure of the Council to support the full capacity of a strategic site,
despite discussion with Development Management and Statutory Consultees
which demonstrate that the site could accommodate in excess of 55 units.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26728

Received: 26/11/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

NPPF para 31 requires planning policies to be underpinned by relevant and up to date evidence.

BBC need to be satisfied reduction in dwelling numbers is supported by appropriate evidence base, including:
- demonstrating site makes effective and efficient use of land (paragraphs 117, 118, 122 and 123 of the NPPF)
- is economically viable (paragraph 67)
- updated transport evidence base fully assesses
transport implications.

Proposed policy change does not address ECC's Pre-Submission Reg.19 consultation representations to this policy (March 2019).

ECC's position has not changed on this matter.

Change suggested by respondent:

As a result of the reduction in dwelling numbers for this site allocation BBC should include, within the Plan evidence and supporting text for this Policy, details to demonstrate that the site allocation makes effective and efficient use of land, and is economically viable.

BBC should also update its transport evidence base for the Local Plan to fully assess the transport implications of the change in dwellings numbers on this site allocation.

The policy needs to be further changed to address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.

Full text:

2. Justified
3. Effective
4. Consistent with National Policy

Paragraph 31 of the NPPF requires planning policies to be underpinned by relevant and up to date evidence.

BBC will need to be satisfied that the reduction in dwelling numbers on this site is supported by the appropriate evidence base, including demonstrating that the site allocation makes effective and efficient use of land (paragraphs 117, 118, 122 and 123 of the NPPF), and is economically viable (paragraph 67).

BBC will need to be satisfied that the transport implications of the change in dwelling numbers on this site allocation are fully assessed through an updated transport evidence base for the Local Plan.

The proposed change to this policy does not address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.
See
ECC 82 / BBC 22450

ECC's position has not changed on this matter.

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26739

Received: 26/11/2019

Respondent: Mr Richard Owers

Representation:

In principle we support the proposed changes to the policy R18 for the Crescent Drive site - Reduction from 'around 55' to 'around 35 homes' providing the planning application is for a development in keeping with the surrounding area, meets all the required planning criteria and is designed to reduce the future environmental footprint and impact by incorporating the latest sustainability construction methods, transport planning and provision for personal wellbeing.
In particular we require the plan to allow for houses facing Crescent Drive (not flats and apartments) as this is in keeping with Crescent Drive and all surrounding roads, and that all new properties have sufficient off road dedicated parking to meet all the requirements of the residents of the new properties and their visitors.
The height of any new development should be no higher than the current structure at any point so that the current visibility of all trees and vegetation is maintained.

Full text:

Dear Sir

Brentwood Borough Council Local Plan Consultation on
Addendum of focused changes to the pre-submission Plan

Focussed Change 2, Policy R18: Land off Crescent Drive, Shenfield (page 290)

We are writing with a formal representation in response to the above.
In principle we support the proposed changes to the policy R18 for the Crescent Drive site - Reduction from 'around 55' to 'around 35 homes' providing the planning application is for a development in keeping with the surrounding area, meets all the required planning criteria and is designed to reduce the future environmental footprint and impact by incorporating the latest sustainability construction methods, transport planning and provision for personal wellbeing

In particular we require the plan to allow for houses facing Crescent Drive (not flats and apartments) as this is in keeping with Crescent Drive and all surrounding roads, and that all new properties have sufficient off road dedicated parking to meet all the requirements of the residents of the new properties and their visitors.

The height of any new development should be no higher than the current structure at any point so that the current visibility of all trees and vegetation is maintained.

Yours faithfully,

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26745

Received: 26/11/2019

Respondent: Basildon Borough Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising
car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.

Full text:


RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26775

Received: 27/11/2019

Respondent: Philip Cunliffe-Jones

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Focussed change reducing dwellings to "around 35 homes". This will keep an area of on site public open space. I consider that this change has not been positively prepared and not consistent with policies in the NPPF requiring an integrated approach to housing and community facilities. The woodland open space should be a priority and an opportunity to enhance a community asset in an area of open space deprivation is foregone.
(i) Paragraph 3 of the Focussed Changes Consultation states that a significant number of representations were received, and a summary of key concerns raised "include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitats impacts; and flooding."
(ii) No site appraisal justifying the proposed change appears to have been prepared. The character of the area was established by the Glanthams Park Estate Development scheme and layout with some statutory and charitable modifications before the redevelopment of the main hospital site in 2011 with the transfer of land for a public woodland opens space, and a footpath between the hospital and the Regional Blood Transfusion site (R18). In addition to the footpath the R18 site benefits from an easement for a right of way connecting to Worrin Road.
(iii) The proposed focussed change to R18 does not relate to the objectives of the Hospital redevelopment scheme and transfer of public woodland open space.
(iv) These objections are supported by a serious caveat in the Addendum to the SA Report prepared by AECOM Infrastructure, and a conclusion which is couched in evasive language.
(v) The Addendum is qualified by being in accordance with the established budget, and also states that information provided by third parties has not been checked. At paragraph 2.5.3 of the Addendum there is a caveat that costly "costly access and transport infrastructure upgrades will be required in order to ensure a good flow of traffic and support safe access by walking and cycling...... There is a need to question whether scheme viability could be adversely affected as a result in the reduction in the number of homes". In other words, the work has not been carried out to justify the soundness of the change
(vi) The conclusion to the Addendum at paragraph 2.5.6 is equivocal. It makes the highly dubious assertion that a response to (some but not all) concerns has positive implications for community objectives while highlighting an unquantified degree of uncertainty concerning infrastructure, including community infrastructure at DHGV.
(vii). It is open to the Council to make an order under the Highways Act creating a byway for all traffic over its easement. This would open up the public open space transferred in 2011, which has been the subject since then of encroachments and trespass. There are other options. However, the focussed change proposed seeks to take a line of minimum development with some onsite open space to avoid grasping the nettle of integrated planned development. This is unsound, unjustified and inimical to national planning policy objectives and not in the public interest.
Philip Cunliffe-Jones

Full text:

I make the following representations in respect of the Focussed Change to R18 and the Addendum to the SA Report. My personal details are the same as the representations in March 2019 regarding the original iteration of Policy R18.
1. Focussed change reducing dwellings to "around 35 homes". This will keep an area of on site public open space. I consider that this change has not been positively prepared and not consistent with policies in the NPPF requiring an integrated approach to housing and community facilities. The woodland open space should be a priority and an opportunity to enhance a community asset in an area of open space deprivation is foregone.
2. The addendum of focussed change to Policy R18 is not effective and not justified.

Reasons:
(i) Paragraph 3 of the Focussed Changes Consultation states that a significant number of representations were received, and a summary of key concerns raised "include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitats impacts; and flooding."
(ii) No site appraisal justifying the proposed change appears to have been prepared. The character of the area was established by the Glanthams Park Estate Development scheme and layout with some statutory and charitable modifications before the redevelopment of the main hospital site in 2011 with the transfer of land for a public woodland opens space, and a footpath between the hospital and the Regional Blood Transfusion site (R18). In addition to the footpath the R18 site benefits from an easement for a right of way connecting to Worrin Road.
(iii) The proposed focussed change to R18 does not relate to the objectives of the Hospital redevelopment scheme and transfer of public woodland open space.
(iv) These objections are supported by a serious caveat in the Addendum to the SA Report prepared by AECOM Infrastructure, and a conclusion which is couched in evasive language.
(v) The Addendum is qualified by being in accordance with the established budget, and also states that information provided by third parties has not been checked. At paragraph 2.5.3 of the Addendum there is a caveat that costly "costly access and transport infrastructure upgrades will be required in order to ensure a good flow of traffic and support safe access by walking and cycling...... There is a need to question whether scheme viability could be adversely affected as a result in the reduction in the number of homes". In other words, the work has not been carried out to justify the soundness of the change
(vi) The conclusion to the Addendum at paragraph 2.5.6 is equivocal. It makes the highly dubious assertion that a response to (some but not all) concerns has positive implications for community objectives while highlighting an unquantified degree of uncertainty concerning infrastructure, including community infrastructure at DHGV.
(vii). It is open to the Council to make an order under the Highways Act creating a byway for all traffic over its easement. This would open up the public open space transferred in 2011, which has been the subject since then of encroachments and trespass. There are other options. However, the focussed change proposed seeks to take a line of minimum development with some onsite open space to avoid grasping the nettle of integrated planned development. This is unsound, unjustified and inimical to national planning policy objectives and not in the public interest.
Philip Cunliffe-Jones

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26776

Received: 27/11/2019

Respondent: Philip Cunliffe-Jones

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The addendum of focussed change to Policy R18 is not effective and not justified.
(i) Paragraph 3 of the Focussed Changes Consultation states that a significant number of representations were received, and a summary of key concerns raised "include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitats impacts; and flooding."
(ii) No site appraisal justifying the proposed change appears to have been prepared. The character of the area was established by the Glanthams Park Estate Development scheme and layout with some statutory and charitable modifications before the redevelopment of the main hospital site in 2011 with the transfer of land for a public woodland opens space, and a footpath between the hospital and the Regional Blood Transfusion site (R18). In addition to the footpath the R18 site benefits from an easement for a right of way connecting to Worrin Road.
(iii) The proposed focussed change to R18 does not relate to the objectives of the Hospital redevelopment scheme and transfer of public woodland open space.
(iv) These objections are supported by a serious caveat in the Addendum to the SA Report prepared by AECOM Infrastructure, and a conclusion which is couched in evasive language.
(v) The Addendum is qualified by being in accordance with the established budget, and also states that information provided by third parties has not been checked. At paragraph 2.5.3 of the Addendum there is a caveat that costly "costly access and transport infrastructure upgrades will be required in order to ensure a good flow of traffic and support safe access by walking and cycling...... There is a need to question whether scheme viability could be adversely affected as a result in the reduction in the number of homes". In other words, the work has not been carried out to justify the soundness of the change
(vi) The conclusion to the Addendum at paragraph 2.5.6 is equivocal. It makes the highly dubious assertion that a response to (some but not all) concerns has positive implications for community objectives while highlighting an unquantified degree of uncertainty concerning infrastructure, including community infrastructure at DHGV.
(vii). It is open to the Council to make an order under the Highways Act creating a byway for all traffic over its easement. This would open up the public open space transferred in 2011, which has been the subject since then of encroachments and trespass. There are other options. However, the focussed change proposed seeks to take a line of minimum development with some onsite open space to avoid grasping the nettle of integrated planned development. This is unsound, unjustified and inimical to national planning policy objectives and not in the public interest.
Philip Cunliffe-Jones

Full text:

I make the following representations in respect of the Focussed Change to R18 and the Addendum to the SA Report. My personal details are the same as the representations in March 2019 regarding the original iteration of Policy R18.
1. Focussed change reducing dwellings to "around 35 homes". This will keep an area of on site public open space. I consider that this change has not been positively prepared and not consistent with policies in the NPPF requiring an integrated approach to housing and community facilities. The woodland open space should be a priority and an opportunity to enhance a community asset in an area of open space deprivation is foregone.
2. The addendum of focussed change to Policy R18 is not effective and not justified.

Reasons:
(i) Paragraph 3 of the Focussed Changes Consultation states that a significant number of representations were received, and a summary of key concerns raised "include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitats impacts; and flooding."
(ii) No site appraisal justifying the proposed change appears to have been prepared. The character of the area was established by the Glanthams Park Estate Development scheme and layout with some statutory and charitable modifications before the redevelopment of the main hospital site in 2011 with the transfer of land for a public woodland opens space, and a footpath between the hospital and the Regional Blood Transfusion site (R18). In addition to the footpath the R18 site benefits from an easement for a right of way connecting to Worrin Road.
(iii) The proposed focussed change to R18 does not relate to the objectives of the Hospital redevelopment scheme and transfer of public woodland open space.
(iv) These objections are supported by a serious caveat in the Addendum to the SA Report prepared by AECOM Infrastructure, and a conclusion which is couched in evasive language.
(v) The Addendum is qualified by being in accordance with the established budget, and also states that information provided by third parties has not been checked. At paragraph 2.5.3 of the Addendum there is a caveat that costly "costly access and transport infrastructure upgrades will be required in order to ensure a good flow of traffic and support safe access by walking and cycling...... There is a need to question whether scheme viability could be adversely affected as a result in the reduction in the number of homes". In other words, the work has not been carried out to justify the soundness of the change
(vi) The conclusion to the Addendum at paragraph 2.5.6 is equivocal. It makes the highly dubious assertion that a response to (some but not all) concerns has positive implications for community objectives while highlighting an unquantified degree of uncertainty concerning infrastructure, including community infrastructure at DHGV.
(vii). It is open to the Council to make an order under the Highways Act creating a byway for all traffic over its easement. This would open up the public open space transferred in 2011, which has been the subject since then of encroachments and trespass. There are other options. However, the focussed change proposed seeks to take a line of minimum development with some onsite open space to avoid grasping the nettle of integrated planned development. This is unsound, unjustified and inimical to national planning policy objectives and not in the public interest.
Philip Cunliffe-Jones

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26788

Received: 25/11/2019

Respondent: Historic England

Representation:

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Full text:

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26861

Received: 26/11/2019

Respondent: Mrs Christina Atkins

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Site received less than 1% of total Reg 19 responses. Brownfield sites should be prioritised over greenfield sites and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 and R26 should be removed entirely. Would make much more sense as Buses and Trains are close for people to go to work.

Change suggested by respondent:

The number of homes should be increased back to a minimum of 55 and R25 and R26 should be removed entirely.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic AllocationThe allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree. Would make much more sense as Buses and Trains are close for
people to go to work.

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure. We should prioritise building on sites that are close or near to existing
infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP. I feel the site should be completely removed from the LDP. A reduction of ten houses would not change the fundamental problems in connection with the infrastructure and services of of Blackmore Village not to mention that a Development like this would complete spoil the uniqueness of this Village which has much history.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). It is important to build on Brownfield Sites before we carry out any destruction to Green Belt Land.

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree.

Q - Additional comments
A - We do not need anymore houses in Blackmore as we are a sustainable Village as we are, anymore Housing would be horrendous for this village. Would have to mention more Traffic, Flood Risk, Doctor Services, School etc.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26892

Received: 29/11/2019

Respondent: L Apostolides

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Change suggested by respondent:

Remove R25 and R26 from the plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The GP surgery can not cope with the number of patients now and the schools are not large enough for more children
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26897

Received: 29/11/2019

Respondent: Mr Alex Atkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree. I agree that brownfield sites should be released first before any building
can be completed on greenfield

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree,
I agree that brownfield sites should be released first before any building
can be completed on greenfield
Comment: :
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated


Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26905

Received: 29/11/2019

Respondent: Mr Christopher Atkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree,
Before distruction of Greenbelt land all Brownfield Sites should be
used.
Comment: :
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure, No point building houses in a rural area where there is no infrastructure as it makes living more difficult to reach services.

Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
,
The houses needed can go elsewhere on the LDP so as not to spoil a
very quaint unique village.
COMMENT: :
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
,
No building on Greenbelt land in
Blackmore.
COMMENT: :
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
This village is sustainable as it is, anymore houses would be horrendous and completely spoil the village.
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26910

Received: 26/11/2019

Respondent: Mr Joseph W E Atkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree. Green belt land should not be used at all, Brownfield Sites should be
used.

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree,
Green belt land should not be used at all, Brownfield Sites should be
used.
Comment: :
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure, Infrastructure should be considered at all costs when residential development takes place as it's pointless placing people in a rural area
with little infrastructure i.e Health Centre, Transport and many other services that people have to drive to.

Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
,
The Development proposed for Blackmore should've removed from the
Plan as Blackmore cannot sustain any further houses.
COMMENT: :
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
,
Red rose Farm is a Brownfield site and a proposed development of 12
houses will deliver part of our own village plan so it should therefore
replace R26 kits entirity. Green belt land should not be built on,
Brownfield should always be considered first.
COMMENT: :
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated

Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
Blackmore is Greenbelt Land and Brownfield Sites should be used before the destruction of Green Belt Land.
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree