Sustainability Appraisal
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 245
Received: 01/10/2013
Respondent: Essex County Council
Paragraph 1.14 indicates that a Sustainability Appraisal was undertaken to support the Issues and Options stage of the Local Plan, and to support previous work concerning Gypsy and Traveller sites. Brentwood Borough Council published a Sustainability Scoping Report for consultation in May/July 2013. Consequently, it is unclear how this Appraisal could have appropriately informed the spatial strategy in the Preferred Option Local Plan. As such, as far as can be evidenced, no independent recommendations regarding sustainability could have influenced the production of these two elements of the plan, contrary to paragraph 1.14.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 301
Received: 13/09/2013
Respondent: Castle Point Borough Council
1. Failure to properly consider matters of Sustainability is also an issue affecting the robustness of the Brentwood draft Local Plan. A Sustainability Appraisal of the draft LP did not accompany the Committee Report, and has only recently been published in August 2013. This raises questions about the procedural soundness of the draft Local Plan, and potentially means that the draft Local Plan does not represent the most sustainable strategy for Brentwood.
2. Potential impacts on European Sites have not been assessed.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 344
Received: 03/10/2013
Respondent: South Essex Partnership University NHS Trust
Agent: Bidwells
Pastoral Way, Warley
The SA reaffirms the site's suitability demonstrating its high sustainability credentials. The only potential matters flagged are:
BIODIVERSITY: The site is 1km from the nearest SSSI (Thorndon Park);
LANDSCAPE: The site is in the Green Belt; and
LANDSCAPE: The site adjoins a Special Landscape Area.
None of these matters would result in 'significant harm', nor do they pose insurmountable barriers to development. They are also significantly outweighed by the considerable sustainability credentials of the site (acknowledged by the SA), particularly the contribution the site would make to delivering much needed new homes.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 587
Received: 23/09/2013
Respondent: Ingatestone and Fryerning Parish Council
Concern that the Draft Local Plan was produced before the consultation on the SA had been carried out and the information in our response o this consultation may not have been taken into consideration. We have therefore enclosed a copy of this earlier SA response and you to ensure that the issues raised by us are considered in conjunction with this response.
See attachments
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 626
Received: 02/10/2013
Respondent: Anderson Group
Agent: Bidwells
The Councils LDP is subject to a SA but it only assesses the implications of developing those sites which accord with its preferred spatial strategy. Furthermore, it does not provide measurable criteria by which the relative sustainability credentials of the selected sites may be assessed. Indeed there is no comparative assessment of the sustainability of the sites which sit outside of the spatial strategy. There is therefore no means by which to benchmark the Council's approach.
Bidwells has conducted a SA of the land south of Redrose Lane, and east of Nine Ashes Road Blackmore (SHLAA site G070).
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 792
Received: 02/10/2013
Respondent: Crest Nicholson
Agent: Bidwells
A review of the Council's recently published Sustainability Appraisal (SA) gives no confidence that this approach has been implemented by BBC in preparing its draft Local Plan; which instead seems to be a more pre-emptive approach where evidence appears to be retrofitted to the political aims of the Council. We question the omission of a large number of sites which were assessed as suitable, available and deliverable by the Council's SHLAA and did not present insurmountable constraints in the published 'Supporting Document: Draft Site Assessment' including our client's land at Nags Head Lane, the Council's reasons for discounting remain unknown.
See attached Report.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 905
Received: 01/10/2013
Respondent: Crest Nicholson
Agent: Savills UK
The Sustainability Appraisal (August 2013) "accompanying" (published seven weeks after) the Local Plan does not adequately address the methodology and justification for the selection of their housing target. Further comment on the Sustainability Appraisal will be submitted by Savills UK on behalf of Crest Nicholson Eastern during the amended consultation period for the document.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 940
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
There has been a failure to comply with the relevant requirements of the EU Directive and Regulations. A substantive revisiting of the plan strategy is required. This should include the preparation of a thorough and effective Sustainability Appraisal that takes into account a proper testing of the alternatives for growth. The options for growth should be considered in the context of the objectively assessed needs for housing in the Borough which should give regard to current and future demographic trends and profiles and take into account evidence including the government's latest published household projections.
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 960
Received: 02/10/2013
Respondent: Natural England
There is clear reference to the National Planning Policy Framework (NPPF) as well as the Habitats regulation Assessment and Sustainability Appraisal and this is welcomed and acknowledged.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1287
Received: 01/10/2013
Respondent: JB Planning Associates Ltd.
We have also reviewed the Interim Sustainability Appraisal (SA) and failed to find any assessment of alternative site allocation which should form part of the appraisal. We can therefore only assume no alternative sites were considered by the Council which is contrary to national policy. Transparency should be at the heart of the process and failure to fully explain why some sites were chosen and others not, and to test alternatives, raises serious concerns over how the Plan was prepared.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1624
Received: 02/10/2013
Respondent: Mr Paul Hawkins
I am disappointed that your commissioned URS Scoping Document, on the proposed Sustainability Appraisal, is not easy to find and has not been widely publicised for so an important consultation that appears to set out the ground rules for further consultation on a new Local Plan.
Having read through the Scoping Report for the 'Sustainability Appraisal' I have word searched 'Garden City' and found 11 references to this 'development speak'. I conclude that 'Garden City' is a euphemism for Brentwood Council proposed building on greenbelt as bequeathed to us by wartime generation Planning Policy makers. I am extremely concerned that this wonderful greenbelt legacy will be in terminal decline, through the proposed 'Sustainability' Appraisal, no matter how you couch planning policy terminology.
I am disappointed that your commissioned URS Scoping Document, on the proposed Sustainability Appraisal, is not easy to find and has not been widely publicised for so an important consultation that appears to set out the ground rules for further consultation on a new Local Plan.
The below is my understanding of this very important document and lifted references are in orange.
Under 3.1.2. 'Biodiversity'
'Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, notably to 'retain and enhance landscapes, visual amenity and biodiversity'.
Greenbelt is already defined as established some 60 years ago and in the current Local Plan .
Develop land with the least environmental/amenity value whilst ensuring Green Belt objectives are maintained
With regards to the above the last BRENTWOOD BOROUGH COUNCIL ( BBC ) Local Plan references the below from
Landscape Improvements
9.45 Despite the general attractiveness of the rural parts of the Borough there are also some areas of poor landscape quality. Reasons for this are varied, and include industrial activities, farming practices, loss of trees through development, Dutch Elm disease and other natural events, or simply neglect, in some cases because owners hope that unsightly parts of the Green Belt may then be released for development.
Clearly previous Brentwood planners understood the attempted underhanded ways land owners could attempt to undermine greenbelt in attempts to build on it. Please retain the current Local Plan 9.45 reference in any future planning policy documents
3.2.3 Thames Chase
Community Forest and Red House Lake are both highlighted as sites for protection;
This is the only reference I have been able to find with regards to The Thames Chase. Planting a forest takes time. Please retain the original plans and aspirations of the original Thames Chase project in any new Brentwood policy documents
PAGE 20 of document below
Protect and enhance the rural environment ensur(e)ing the countryside and multifunctional open spaces are accessible to all.
The highlighted yellow text has been crossed out, though left in the document as attached. There is a world of difference to the preferred original text to that which is left. Please use the original text.
Locate new development in locations that are as close as possible to existing
It is essential that infrastructure implications are considered for any application i.e. building home for the elderly in a village location would entail further demand on resources i.e. dentists, doctors, transport, care services, chemists, shops. Without such shops homes could become, inadvertently, prisons for residents with feelings of isolation and loneliness. Such infrastructure 'improvements' would be associated with that of a town environment and lead to the demise of Brentwood Borough villages. See below box
Ensure sufficient healthcare, social and community facilities are provided to support new development
PAGE 21
Encourage the feeling of community spirit
Please consider the following:
1. Home ownership is plummeting in UK with the advent of the buy to let market...many of which are bought by foreign investors
2. There were 29,000 buy to let mortgages in 1998. In Oct 2011 this had increased to 1.34million and rising.
3. 50% of tenants in rented accommodation move on within 2 years. This does little for 'ownership' of a neighbourhood, community cohesion and does not ' Encourage the feeling of community spirit'.
4. There is very little control/sanction against potential 'neighbours from hell' in private buy to let accommodation on short term tenancies.
5. There is no guarantee that local development will be sold to local people or first time buyers...despite the sales pitch of a developer
I am more than happy to provide authorative evidence based research should anyone ask re the above points.
Page 43
'The greenbelt has successfully prevented urban sprawl - but at a price. Evidence from other countries suggests that it should be operated more flexibly, with boundaries revisited regularly.
Page 44
However, should those sources produce a shortfall then Green Belt release may be necessary.
Allowing above statements like this in the Local Plan signals the slow/possibly fast demise of our forefathers/mothers wonderful legacy and who had the foresight to create such policies that have, thus far, stood the test of time.
There are alternatives to building on greenbelt. With current and future controlled and uncontrolled immigration the population of Brentwood will increase. Current brownfield sites will not sustain population growth in the long term. To retain the the current greenbelt please consider high density housing, in the long term, built to the best possible standards applying the principles of Crime Prevention through Environmental Design in association with ACPO's SecuredbyDesign initiative. Such schemes will avoid the past 1960's and 70's Architectural award winning urban disasters of failed estates that have now been demolished. High density housing succeeds very well in Singapore, Japan and many other countries.
Page 45
Given the limits of the Green Belt, the study concludes that Brentwood cannot meet market demand for new homes. A constrained housing target may have positive and negative implications. There will be less scope to secure affordable homes and contributions towards infrastructure as a result of constrained growth. However, lower housing growth will place less pressure on existing infrastructure, plus a lower requirement for new infrastructure
The above states the obvious though please consider to whom exactly will be buying new property. A large proportion, possibly the majority, will be bought by non Brentwood residents for private rental with transient tenant populations.
Page 50
Protect and enhance valued landscapes, giving particular weight to those identified as being of national importance
What about local importance? It's subjective as to what is a valued landscape. All greenbelt is valued landscape...as previously established
Please do not be instrumental to the destruction of the current greenbelt that is the wonderful legacy left to us and future generations by the wartime generations of 'The Great War' and WW2...Lest we forget.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1628
Received: 02/10/2013
Respondent: Mr Paul Hawkins
Having read through the Scoping Report for the 'Sustainability Appraisal' I have word searched 'Garden City' and found 11 references to this 'development speak'. I conclude that 'Garden City' is a euphemism for Brentwood Council proposed building on greenbelt as bequeathed to us by wartime generation Planning Policy makers. I am extremely concerned that this wonderful greenbelt legacy will be in terminal decline, through the proposed 'Sustainability' Appraisal, no matter how you couch planning policy terminology.
I am disappointed that your commissioned URS Scoping Document, on the proposed Sustainability Appraisal, is not easy to find and has not been widely publicised for so an important consultation that appears to set out the ground rules for further consultation on a new Local Plan.
The below is my understanding of this very important document and lifted references are in orange.
Under 3.1.2. 'Biodiversity'
'Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, notably to 'retain and enhance landscapes, visual amenity and biodiversity'.
Greenbelt is already defined as established some 60 years ago and in the current Local Plan .
Develop land with the least environmental/amenity value whilst ensuring Green Belt objectives are maintained
With regards to the above the last BRENTWOOD BOROUGH COUNCIL ( BBC ) Local Plan references the below from
Landscape Improvements
9.45 Despite the general attractiveness of the rural parts of the Borough there are also some areas of poor landscape quality. Reasons for this are varied, and include industrial activities, farming practices, loss of trees through development, Dutch Elm disease and other natural events, or simply neglect, in some cases because owners hope that unsightly parts of the Green Belt may then be released for development.
Clearly previous Brentwood planners understood the attempted underhanded ways land owners could attempt to undermine greenbelt in attempts to build on it. Please retain the current Local Plan 9.45 reference in any future planning policy documents
3.2.3 Thames Chase
Community Forest and Red House Lake are both highlighted as sites for protection;
This is the only reference I have been able to find with regards to The Thames Chase. Planting a forest takes time. Please retain the original plans and aspirations of the original Thames Chase project in any new Brentwood policy documents
PAGE 20 of document below
Protect and enhance the rural environment ensur(e)ing the countryside and multifunctional open spaces are accessible to all.
The highlighted yellow text has been crossed out, though left in the document as attached. There is a world of difference to the preferred original text to that which is left. Please use the original text.
Locate new development in locations that are as close as possible to existing
It is essential that infrastructure implications are considered for any application i.e. building home for the elderly in a village location would entail further demand on resources i.e. dentists, doctors, transport, care services, chemists, shops. Without such shops homes could become, inadvertently, prisons for residents with feelings of isolation and loneliness. Such infrastructure 'improvements' would be associated with that of a town environment and lead to the demise of Brentwood Borough villages. See below box
Ensure sufficient healthcare, social and community facilities are provided to support new development
PAGE 21
Encourage the feeling of community spirit
Please consider the following:
1. Home ownership is plummeting in UK with the advent of the buy to let market...many of which are bought by foreign investors
2. There were 29,000 buy to let mortgages in 1998. In Oct 2011 this had increased to 1.34million and rising.
3. 50% of tenants in rented accommodation move on within 2 years. This does little for 'ownership' of a neighbourhood, community cohesion and does not ' Encourage the feeling of community spirit'.
4. There is very little control/sanction against potential 'neighbours from hell' in private buy to let accommodation on short term tenancies.
5. There is no guarantee that local development will be sold to local people or first time buyers...despite the sales pitch of a developer
I am more than happy to provide authorative evidence based research should anyone ask re the above points.
Page 43
'The greenbelt has successfully prevented urban sprawl - but at a price. Evidence from other countries suggests that it should be operated more flexibly, with boundaries revisited regularly.
Page 44
However, should those sources produce a shortfall then Green Belt release may be necessary.
Allowing above statements like this in the Local Plan signals the slow/possibly fast demise of our forefathers/mothers wonderful legacy and who had the foresight to create such policies that have, thus far, stood the test of time.
There are alternatives to building on greenbelt. With current and future controlled and uncontrolled immigration the population of Brentwood will increase. Current brownfield sites will not sustain population growth in the long term. To retain the the current greenbelt please consider high density housing, in the long term, built to the best possible standards applying the principles of Crime Prevention through Environmental Design in association with ACPO's SecuredbyDesign initiative. Such schemes will avoid the past 1960's and 70's Architectural award winning urban disasters of failed estates that have now been demolished. High density housing succeeds very well in Singapore, Japan and many other countries.
Page 45
Given the limits of the Green Belt, the study concludes that Brentwood cannot meet market demand for new homes. A constrained housing target may have positive and negative implications. There will be less scope to secure affordable homes and contributions towards infrastructure as a result of constrained growth. However, lower housing growth will place less pressure on existing infrastructure, plus a lower requirement for new infrastructure
The above states the obvious though please consider to whom exactly will be buying new property. A large proportion, possibly the majority, will be bought by non Brentwood residents for private rental with transient tenant populations.
Page 50
Protect and enhance valued landscapes, giving particular weight to those identified as being of national importance
What about local importance? It's subjective as to what is a valued landscape. All greenbelt is valued landscape...as previously established
Please do not be instrumental to the destruction of the current greenbelt that is the wonderful legacy left to us and future generations by the wartime generations of 'The Great War' and WW2...Lest we forget.
Having read through the Scoping Report for the 'Sustainability Appraisal' I have word searched 'Garden City' and found 11 references to this 'development speak'. I conclude that 'Garden City' is a euphemism for Brentwood Council proposed building on greenbelt as bequeathed to us by wartime generation Planning Policy makers. I am extremely concerned that this wonderful greenbelt legacy will be in terminal decline, through the proposed 'Sustainability' Appraisal, no matter how you couch planning policy terminology.
I am disappointed that your commissioned URS Scoping Document, on the proposed Sustainability Appraisal, is not easy to find and has not been widely publicised for so an important consultation that appears to set out the ground rules for further consultation on a new Local Plan.
The below is my understanding of this very important document and lifted references are in orange.
Under 3.1.2. 'Biodiversity'
'Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, notably to 'retain and enhance landscapes, visual amenity and biodiversity'.
Greenbelt is already defined as established some 60 years ago and in the current Local Plan .
Develop land with the least environmental/amenity value whilst ensuring Green Belt objectives are maintained
With regards to the above the last BRENTWOOD BOROUGH COUNCIL ( BBC ) Local Plan references the below from
Landscape Improvements
9.45 Despite the general attractiveness of the rural parts of the Borough there are also some areas of poor landscape quality. Reasons for this are varied, and include industrial activities, farming practices, loss of trees through development, Dutch Elm disease and other natural events, or simply neglect, in some cases because owners hope that unsightly parts of the Green Belt may then be released for development.
Clearly previous Brentwood planners understood the attempted underhanded ways land owners could attempt to undermine greenbelt in attempts to build on it. Please retain the current Local Plan 9.45 reference in any future planning policy documents
3.2.3 Thames Chase
Community Forest and Red House Lake are both highlighted as sites for protection;
This is the only reference I have been able to find with regards to The Thames Chase. Planting a forest takes time. Please retain the original plans and aspirations of the original Thames Chase project in any new Brentwood policy documents
PAGE 20 of document below
Protect and enhance the rural environment ensur(e)ing the countryside and multifunctional open spaces are accessible to all.
The highlighted yellow text has been crossed out, though left in the document as attached. There is a world of difference to the preferred original text to that which is left. Please use the original text.
Locate new development in locations that are as close as possible to existing
It is essential that infrastructure implications are considered for any application i.e. building home for the elderly in a village location would entail further demand on resources i.e. dentists, doctors, transport, care services, chemists, shops. Without such shops homes could become, inadvertently, prisons for residents with feelings of isolation and loneliness. Such infrastructure 'improvements' would be associated with that of a town environment and lead to the demise of Brentwood Borough villages. See below box
Ensure sufficient healthcare, social and community facilities are provided to support new development
PAGE 21
Encourage the feeling of community spirit
Please consider the following:
1. Home ownership is plummeting in UK with the advent of the buy to let market...many of which are bought by foreign investors
2. There were 29,000 buy to let mortgages in 1998. In Oct 2011 this had increased to 1.34million and rising.
3. 50% of tenants in rented accommodation move on within 2 years. This does little for 'ownership' of a neighbourhood, community cohesion and does not ' Encourage the feeling of community spirit'.
4. There is very little control/sanction against potential 'neighbours from hell' in private buy to let accommodation on short term tenancies.
5. There is no guarantee that local development will be sold to local people or first time buyers...despite the sales pitch of a developer
I am more than happy to provide authorative evidence based research should anyone ask re the above points.
Page 43
'The greenbelt has successfully prevented urban sprawl - but at a price. Evidence from other countries suggests that it should be operated more flexibly, with boundaries revisited regularly.
Page 44
However, should those sources produce a shortfall then Green Belt release may be necessary.
Allowing above statements like this in the Local Plan signals the slow/possibly fast demise of our forefathers/mothers wonderful legacy and who had the foresight to create such policies that have, thus far, stood the test of time.
There are alternatives to building on greenbelt. With current and future controlled and uncontrolled immigration the population of Brentwood will increase. Current brownfield sites will not sustain population growth in the long term. To retain the the current greenbelt please consider high density housing, in the long term, built to the best possible standards applying the principles of Crime Prevention through Environmental Design in association with ACPO's SecuredbyDesign initiative. Such schemes will avoid the past 1960's and 70's Architectural award winning urban disasters of failed estates that have now been demolished. High density housing succeeds very well in Singapore, Japan and many other countries.
Page 45
Given the limits of the Green Belt, the study concludes that Brentwood cannot meet market demand for new homes. A constrained housing target may have positive and negative implications. There will be less scope to secure affordable homes and contributions towards infrastructure as a result of constrained growth. However, lower housing growth will place less pressure on existing infrastructure, plus a lower requirement for new infrastructure
The above states the obvious though please consider to whom exactly will be buying new property. A large proportion, possibly the majority, will be bought by non Brentwood residents for private rental with transient tenant populations.
Page 50
Protect and enhance valued landscapes, giving particular weight to those identified as being of national importance
What about local importance? It's subjective as to what is a valued landscape. All greenbelt is valued landscape...as previously established
Please do not be instrumental to the destruction of the current greenbelt that is the wonderful legacy left to us and future generations by the wartime generations of 'The Great War' and WW2...Lest we forget.