Sustainability Appraisal

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Object

Strategic Growth Options

Representation ID: 3953

Received: 10/02/2015

Respondent: Historic England

Representation Summary:

In terms of releasing sites on the edge of urban areas this depends on the location in terms of impact on the historic environment. The large areas of land to the east and south east of Hutton/east of Herongate has implications for a large number of heritage assets. The SA underplays the impact of this location on the historic environment, ranking it third out of five potential options for strategic growth. We would argue that it ranks lower than that.

Full text:

Dear Sir or Madam
Brentwood Strategic Growth Options Consultation (January 2015)
Thank you for your letter dated 5 January consulting English Heritage on the
above document. We would like to make the following comments
Q1: Do you agree with the three broad areas for the purposes of
considering approaches to growth?
We do not have a strong view on the division of the borough into three broad
areas, which we recognise is to help consider growth options. As paragraph
2.13 notes, each of the areas should not be considered in isolation. In the
case of the historic environment, specific heritage assets might be shared
between more than one area (e.g. Thorndon Hall Registered Park and
Garden), and so could be impacted on by growth proposals in each area.
Q2: Do you agree with the issues raised for each of these three areas?
We broadly agree with the issues raised for each area in paragraphs 2.14 to
2.19. The historic environment forms an important part of the issues and
options for each area in terms of where to potentially locate new development.
This includes designated heritage assets but also non-designated assets such
as sites of archaeological interest. We would expect proper assessment of the
historic environment and potential impacts when making decisions about
where to locate development.

Q3: Do you have any comments on the appropriateness of particular
sites?
Due to time and resource constraints we have not been able to assess every
site in great detail. Our comments on the sites have been based mainly on
desk-top analysis, and we have not been able to judge the potential impacts
more accurately on the ground. Even with the strategic sites, we have only
been able to carry out rapid site visits in limited cases and have not had the
opportunity to ascertain precise impacts. We have focussed on those sites
with the potential for the greatest historic environment impact. This does not mean there are no issues with any other site and we reserve the right to
comment further on any site as and when proposals develop.
Please note that we have not considered areas of archaeological interest
beyond scheduled monuments in most cases, nor have we looked at historic
landscape issues beyond registered historic parks & gardens. However,
wider archaeological and landscape impacts are important considerations and
need to be factored into site assessment. The possible cumulative impact of
a number of site allocations in one location could cause significant harm to the
historic environment. Advice from conservation and archaeological staff at
borough and county levels should be sought, along with consultation of the
County Historic Environment Record (HER) for specific heritage assets.
In terms of site assessments in relation to heritage assets, care should be
taken to avoid merely limiting assessment of impact on a heritage asset to its
distance from, or intervisibility with, a potential site. Site allocations which
include a heritage asset (for example a site within a Conservation Area) may
offer opportunities for enhancement and tackling heritage at risk, while
conversely, an allocation at a considerable distance away from a heritage
asset may cause harm to its significance, rendering the site unsuitable.
The following broad steps might be of assistance in terms of assessing sites:
* Identify the heritage assets on or within the vicinity of the potential site
allocation at an appropriate scale
* Assess the contribution of the site to the significance of heritage assets
on or within its vicinity
* Identify the potential impacts of development upon the significance of
heritage asset
* Consider how any harm might be removed or reduced, including
reasonable alternatives sites * Consider how any enhancements could be achieved and maximised
* Consider and set out the public benefits where harm cannot be
removed or reduced
Q4: Which of the sites along the A127 Corridor is the best location for
growth?
The document notes the potential for larger growth opportunities in the A127
corridor, with a residential-led mixed used allocation at West Horndon or a
cross boundary development at Dunton (English Heritage has responded
separately to the Dunton Garden Suburb consultation). The consultation
suggests that development would only occur at either West Horndon or
Dunton, but in the event that both are pursued, we would have reservations
about the cumulative impact and extent of urbanisation along the A127
corridor, which could harm various heritage assets. We would expect in such
a scenario for an adequate buffer between West Horndon and Dunton and
important heritage assets.
Within West Horndon site 038B includes the southern limits of the Thorndon
Hall Registered Park and Garden (Grade II* listed) and Thorndon Park
Conservation Area. This southerly projection is separated from the main Park
and Garden and conservation area by the A127, but the issue of severance must have been considered at the time of designation (in 1987 and 1993
respectively). Housing development on the designated area would result in
harm to its character and appearance, and development abutting its
boundaries might also result in a degree of harm.
On site 162 at Little Warley there is a proposal for an elderly care facility. This
site abuts Little Warely Hall, which dates from the early 16th century and is
listed at Grade II*, together with the Church of St Peter, which dates from the
15th and 17th centuries and is listed at Grade I. Development of an elderly
care facility on this site is likely to adversely impact on the setting of both
these highly graded heritage assets. Sites 058A and 058B on the east side of
Little Warely Hall Lane are also in close proximity to these assets, but well
designed and appropriately scaled housing may be less harmful compared to
the current recycling and HGV operations on site 058A.
Q5: Should the A12 Corridor accommodate growth by releasing sites on
the edge of urban areas?
The report notes that brownfield land within the urban areas might be
efficiently developed in order to minimise pressure on Green Belt releases.
English Heritage broadly agrees with this approach, though we note that a
number of brownfield sites are in close proximity to designated heritage
assets and the design of any developments would need to have special
regard to the setting of these assets.
In terms of releasing sites on the edge of urban areas, this again depends on
the exact location in terms of impact on the historic environment. Very
significant areas of green belt land to the east and southeast of Hutton/east of
Ingrave and Herongate is included in the report and much of this land has
implications for a large number of heritage assets. The Sustainability
Appraisal seems to underplay the impact of this location on the historic
environment, ranking it third out of five potential options for strategic growth.
We would argue that it ranks lower than that. On the extreme eastern edge of Hutton is the Hutton village conservation
area. This conservation area has an open rural setting apart from where it
abuts existing housing on the northern half of its western boundary, and
includes Hutton Hall (Grade II* listed) and the 14th century Church of All Saints
(Grade II* listed) plus a number of other buildings listed at Grade II. The
conservation area also includes areas of open land that make a positive
contribution to its character and appearance. Development sites 033, 211
and 219 all lie within the conservation area and English Heritage cannot see
how they could come forward for development without resulting in significant
harm to the character or appearance of the conservation area, as well as
adversely impacting on the setting of some of listed buildings. Sites 008,
008B and 008C are all likely to adversely impact on wider setting of the
conservation area and the more immediate setting of Hutton House, along
with its walled garden and stables (all listed at Grade II). Site 028C is a large
site that abuts the south east and southwest boundaries of the conservation
area, where development is likely to result in harm to the rural character and
appearance of the conservation area and would also have the potential to
adversely impact on the setting of the Church of All Saints and Hutton Hall (both Grade II* listed). The western boundary of Site 028C also abuts the
boundary of Heatleys, a 16th century Grade II house, and development in this
area would have implications for the setting of this house.
Sites 028A and 028B abut the southeast built edge of Hutton. Development
in this area would have implications for the setting of a number of listed
buildings including Hare Hall (Grade II listed) Heatleys (Grade II) listed and
Kennel House (Grade II listed). It may also have implications for the wider
setting of the Thorndon Park Conservation Area and Thorndon Hall
Registered Park and Garden (Grade II*), as well as longer views out from
Thorndon Hall (Grade I listed).
Site 192 is another large site which adjoins the south of site 028C and is
located to the east of Ingrave and Herongate. This site completely enclosed a
scheduled moated site at Heron Hall, together with the 17th century Grade II
listed Hall and stables and the Grade II* listed granary. This complex of
heritage assets currently enjoys a remote rural setting, and historically the
medieval house sited within the moat would have commanded all this
surrounding land. Development of the land around these heritage assets
would therefore result in significant change to their setting and harm to their
significance.
Site 212 is located to the southwest of the Great Warley conservation area
and, while this site is unlikely to have an impact on the conservation area, it
has the potential to adversely impact on the setting of the Thatched Cottage
and The Squirrels (both dating from the 19th century and listed at Grade II).
This site currently comprises Coombe Wood, which would appear to be of
some landscape and ecological value. Northwest of Great Warley is site 167.
Again this site is sufficiently remote from the conservation area and
Registered Park and Garden, but abuts the northern boundary of Hill Cottage
(Grade II listed) and is in relatively close proximity to Great Ropers, an 18th
century house listed at Grade II*.
Site 218 on the edge of Shenfield lies close to a cluster of listed buildings at
Shenfield Hall, including the Grade II hall and Grade II* Church of St Mary.
There should be assessment of potential impacts. Q6: In the North of the Borough, is it preferable to release greenfield or
brownfield sites?
As noted in the document, the North of the Borough is made up of a collection
of villages set amidst attractive landscape (although it is wrong to simply
consider the landscape as 'natural', as it will contain many historic elements).
In terms of specific sites:
Blackmore
The village includes a designated conservation area that contains a number of
listed buildings forming this historic core of the settlement and some open
land of historic interest that also makes a positive contribution to the character
and appearance of the conservation area. Site 052 is located in the conservation area on land to the rear of Little
Jericho. Little Jericho is a grade II listed house dating from c1600 and the
vacant barn/farm buildings to its rear may be curtilage listed. They may also
make a positive contribution to the character and appearance of the
conservation area. Whilst a scheme for the careful adaptation of the farm
buildings into residential use may be acceptable, their demolition and
wholesale redevelopment of the site could well result in harm to the historic
environment.
Site 202 is located immediately adjacent to the western boundary of the
conservation area and the loss of open rural views out of the conservation
area (especially from the path that defines this boundary of the conservation
area) is likely to be harmful to the character and appearance of the
conservation area. Site 199 is to the northeast of the conservation area and
would be less likely to impact on its setting, especially if the southern edge of
the development was given a soft and green boundary.
Sites 076 and 077 are both further away from the conservation area, but both
have Grade II listed buildings in close proximity, and development could
adversely impact on the setting of these listed buildings. It might be possible
to bring forward development on both sites that successfully addresses the
issue of setting for these listed building, but it would be necessary to first
understand how setting contributes to their significance.
Hook End
While there is not conservation area in Hook End, there are a number of
Grade II listed buildings that might be affected by development proposals. A
number of these listed buildings are farmhouses that would historically have
been linked to the adjacent open farmland. Loss of this open farmland could
therefore impact on their signficance. In particular site 174 is immediately to
the west of a collection of three Grade II buildings comprising Hook End
Poultry Farmhouse, brewhouse and barn, while Site 183 is to the south west
of Barfield Farmhouse and south east of Deal Tree Farmhouse. Other sites
that may have implications for the setting of designated heritage assets
include 209 (impacting on the Soap House, Grade II), 056A & 056B
(impacting on The Cottage, Grade II) and 196 (impacting on a cluster of
Grade II listed assets comprising a pump, cartlodge, granary and Wyatts
Farmhouse). Thoby Priory
Site 018 incorporates the ruins of Thoby Priory, which is a Scheduled
Monument and listed Grade II. The priory ruins are also on the English
Heritage 'at risk' list. The priory would have been sited in a remote location
suitably for the contemplative life, but that setting has been compromised in
recent years. English Heritage accepts that a development with housing
located to the west and north of the designated assets, whilst retaining an
open aspect to the south and east, could be acceptable, especially if it also
provided for the improved management of the heritage assets.
Kelvedon Hatch A number of possible sites are identified around the periphery of Kelvedon
Hatch. Those on the east side of the settlement have minimal implications for
the historic environment. There are a number of designated heritage assets
(both listed and scheduled) on the west side of the settlement, but most of
these are to the west of A128 and are therefore likely to be adequately
buffered from developments on sites 217 and 194, which are located on the
east side of the A road. There is a smaller site at 074 which may have
implications for the setting of St Nicholas's Church (Grade II). This church is
currently sited on the edge of the settlement and enclosing its open aspect to
the south might result in a degree of harm.
Q7: Do you agree that the most sustainable approach to employment
need is to allocation new sites close to the strategic highway network?
The map on page 22 of the document identifies a number of potential
employment sites. These sites are generally located in close proximity to
existing transport corridors and/or adjacent to current employment sites, and
the majority will have little adverse impact on designated heritage assets. The
exceptions are sites 109 and 187, which are adjacent to East Hordon Hall
(16th and 18th century and Grade II listed). While the setting of the Hall has
already been compromised by the A127 (which passes immediately to the
north) and the existing employment land to the east of the Hall, further
employment buildings in close proximity would exacerbate the existing harm.
Q8: Do you agree that a town centre first approach should be taken to
retail development?
We broadly agree with this approach as it is should help to maintain the vitality
of town centres which in turn can benefit heritage assets within these
locations. It will depend on specific proposals and their impact, but there are
opportunities in places like Brentwood Town Centre to secure enhancements.
In terms of retail site options for Brentwood Town Centre, our 2013 comments
have highlighted specific heritage assets for some of the sites shown in this
consultation. In many respects, Site 100 (Baytree Centre) is the most
important in terms of opportunities to enhance the historic environment, given
its access off the High Street from within the conservation area, and the
proximity of several listed buildings plus a scheduled monument (the chapel).
We would welcome further discussions regarding this site.
Q9: No comments
Q10: Landscape value
Section 5 of this consultation puts heritage into a separate category detached
from other environmental considerations, rather than include it as part of the
overall environmental picture. Figure 15 should include designated heritage
assets, particularly conservation areas, scheduled monuments and registered
parks and gardens. We note the intention to produce further assessment of
landscape capacity surrounding urban areas in paragraph 5.6. We strongly
recommend that this assessment includes the historic environment as a key
component of landscape capacity. Our comments on specific sites reveal the
extent of heritage assets surrounding the urban areas, and this should be
considered in any decisions on suitable sites. The Local Plan evidence base does not appear to contain any specific references to the historic environment,
and we recommend this is addressed.
Q11: No comments
Q12: Infrastructure Issues
The provision of new or improved infrastructure such as transport can have
implications for the historic environment in terms of impact on specific heritage
assets. The Infrastructure Delivery Plan and related work should consider
such issues. In addition, the historic environment can form part of different
types of infrastructure, from community facilities to historic transport
structures. It also contributes to green infrastructure, which is more than just
the natural environment. Publicly accessible parks and gardens,
archaeological sites and spaces within conservation areas and listed buildings
can all form part of existing and proposed green infrastructure networks, with
opportunities to conserve and enhance such elements.
Q13: No comments
We hope that the above comments are of assistance. If you have any queries
or would like to discuss specific points, please do not hesitate to contact me.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5508

Received: 16/02/2015

Respondent: Thurrock Borough Council

Representation Summary:

Thurrock Council considers the approach set out in the Interim Sustainability Appraisal (SA) is flawed and that a number of assumptions on the way that options have been scored is not supported by the available evidence. The SA appraises development on the basis that most development will be in one location at a strategic scale. Whilst this may be useful as an initial approach, it is considered that actual development may result in a hybrid option. A hybrid option may well moderate the scoring and impact of development in these locations therefore giving more positive of negative scores rather than a large scale concentration of development.

A new option should be considered including development north and east south east of Brentwood/Shenfield, or option 3 should be modified.

Some of the scoring for the options in the SA has been based on assumptions. It is unclear why option 1 would score so highly in relation to sustainable transport, given the high level of uncertainty over the deliverability of a railway station for Dunton.

It is uncertain whether the benefits of improved accessibility brought about by Crossrail and longer term the A12 widening are taken into account.

The landscape scoring for West Horndon is too positive as a large scale development would have a significant impact on the landscape.

The scoring of the development options in relation to community and social infrastructure tends to overstate the benefits for new strategic developments without evidence being provided. Conversely the SA understates the ability of existing locations to gain improved and additional capacity in infrastructure.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 5538

Received: 25/02/2015

Respondent: Mid and South Essex STP

Agent: Smart Planning Ltd

Representation Summary:

Of the five options advocated in the accompanying Sustainability Appraisal, it is suggested that a single large site necessitating the need for new facilities specific to that development would be more sustainable than dispersing growth in many settlements. Numerous smaller extensions could have impacts on existing infrastructure left unmitigated, or the level of contribution falling short of the requirements to provide adequate healthcare.

Full text:

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Attachments:

Object

Strategic Growth Options

Representation ID: 5546

Received: 25/02/2015

Respondent: Mid and South Essex STP

Agent: Smart Planning Ltd

Representation Summary:

The Sustainability Appraisal, although interim at present, is non-specific in assessing the sustainability of health care facilities. Paragraphs 7.5.1 onwards (including table 8.1.1) do not give any base line data from which a proper health impact assessment can be undertaken. The appraisal findings at 13.3.1 also do not consider impacts on healthcare infrastructure, focusing only sustainable and healthy lifestyles; the findings in Appendix 1 do not identify baseline health service issues. NHS England and the CCG are willing to work in partnership with the Local Planning Authority to overcome this oversight and to ensure that appropriate comprehensive consideration of sustainable healthcare is fully integrated into the plan making process.

Full text:

See attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 5568

Received: 20/02/2015

Respondent: Essex County Council

Representation Summary:

ECC support the Interim SA report as a useful document and approach to appraise the various options / alternatives. There are specific concerns regarding "Reasonable Alternatives and Historic Environment as follows:
* the status of the evidence base available and whether sufficient evidence exists to suggest that the sites explored at this stage represents all the "reasonable" alternatives for strategic growth; and
* The Sustainability Appraisal fails to assess the Historic Environment to an appropriate level.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 5680

Received: 25/02/2015

Respondent: Natural England

Representation Summary:

The issue and topics identified are those that Natural England would wish to see considered by this document and we acknowledge the reference to the SSSI's in paragraph 7.3.2. Consider in more detail the impact upon Brentwood's Local Wildlife Site network; and Priority Habitats and Species; particularly in the context of the Brentwood Borough Local Wildlife Site Review 2012. SA also needs to consider in more detail the recreational impacts upon the local SSSI network. There is only limited reference to the SSSI's within the borough. Hopefully subsequent iterations of the plan will set out a more ambitious approach to ensure recreational impacts upon existing publically accessible natural spaces are robustly addressed and planned for.

Full text:

See Attached.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5861

Received: 17/02/2015

Respondent: Environment Agency

Representation Summary:

We recommend that water quality and RBMP objectives are included in the Sustainability Appraisal to inform the preparation of the Local Plan document.

Full text:

see attached

Attachments:

Object

Strategic Growth Options

Representation ID: 6811

Received: 10/03/2015

Respondent: Mr Paul Hawkins

Representation Summary:

5.2.1 of the Sustainability Appraisal of the Brentwood Local Plan Scoping Report May 2013 states:

Almost all of the population change in Brentwood between 2001 and 2008 was through migration from the EU and UK.

Very clearly the proposed excessive housing does not '...meet the development needs of their ( Brentwoods ) area'. The proposed housing is not for local needs and is contrary to NPPF Para 14. There are plenty of empty homes in other parts of the UK.

Full text:

Dear BBC Planning Policy and Mr Pickles,

I object to that proposed, within this consultation document, for the following reasons;

The Strategic Growth Options Consultation states;

1.4 The Council is required to meet local housing and employment needs, among other needs and further in the document

3 Sustainable Communities ?
The Council is required to meet projected local housing needs

and this is reiterated in Para 14 of the NPPF;

For plan-making this means that:

● local planning authorities should positively seek opportunities to meet the development needs of their area;

As stated in the 'The Local Plan 2015-2030 Preferred Options for Consultation'

2.28 The Borough faces a high level of demand for housing from people seeking to move into the area. Around 80 per cent of projected household growth between 2010 and 2033 arises from people expected to move here, mainly from elsewhere in the UK. The remainder is from natural change - an excess of births over deaths (Office for National Statistics (ONS) 2010 based sub national population projections).

5.2.1 of the Sustainability Appraisal of the Brentwood Local Plan Scoping Report May 2013 states:

Almost all of the population change in Brentwood between 2001 and 2008 was through migration from the EU and UK.

Very clearly the proposed excessive housing does not '...meet the development needs of their ( Brentwoods ) area'. The proposed housing is not for local needs and is contrary to NPPF Para 14. There are plenty of empty homes in other parts of the UK

I object to any re-designation of greenbelt, as stated by the 2005 Brentwood Local Plan, such as the so called Housing Site Options ie greenbelt land to the southeast of the borough and the so called Brentwood Enterprise Park at the A127?M25 junction. BBC should aspire to being No 1, nationally, in percentage terms of having greenbelt as opposed to being only 6th. Both these areas are greenbelt and any development ought to be accordance to the current Local Plan policies, that enhance the existing greenbelt, as per;

GB28 Landscape Enhancement
WHERE APPROPRIATE, TREE PLANTING AND HEDGE SCREENING WILL BE EXPECTED IN PROPOSALS FOR DEVELOPMENT IN THE GREEN BELT. IN ADDITION, BRENTWOOD COUNTRYSIDE MANAGEMENT SERVICE WILL CARRY OUT NEW PLANTING ON PUBLICLY OWNED LAND AND, IN CO-OPERATION WITH THE OWNER, ON PRIVATE LAND. WITHIN SPECIAL LANDSCAPE AREAS AND OTHER AREAS WHERE THE LANDSCAPE NEEDS IMPROVEMENT EMPHASIS WILL BE GIVEN TO RESTORE AND ENHANCE DAMAGED LANDSCAPE AND WILL BE A REQUIREMENT WHERE APPROPRIATE. WHEREVER POSSIBLE, NEW PLANTING SHOULD BE CARRIED OUT USING SPECIES NATIVE TO THE AREA. PROPOSALS SHOULD SAFEGUARD THE EXISTING ECOLOGICAL VALUE OF THE SITE AND INCLUDE MEASURES FOR HABITAT CREATION.

C12 Landscape Improvements
THE COUNCIL WILL, IN CONJUNCTION WITH ITS COUNTRYSIDE MANAGEMENT SERVICE, SEEK TO ENCOURAGE LOCAL LAND OWNERS TO IMPLEMENT SCHEMES TO IMPROVE THE ENVIRONMENT THROUGH PLANTING, HABITAT CREATION, IMPROVED PUBLIC ACCESS, MANAGEMENT AGREEMENTS AND OTHER MEASURES, WHILST ALSO IMPLEMENTING ITS OWN PROGRAMME OF ENVIRONMENTAL IMPROVEMENT SCHEMES THROUGHOUT BOTH THE URBAN AND RURAL AREAS OF THE BOROUGH.
WITHIN THE LANDSCAPE IMPROVEMENT AREA, AS DEFINED ON THE PROPOSALS MAP, ANY DEVELOPMENT PROPOSALS WILL BE EXPECTED TO CONTRIBUTE POSITIVELY TOWARDS THE RESTORATION OF ITS ORIGINAL CHARACTER.


The proposed movement of West Horndon's industrial premises to the designated greenbelt, as defined in the current 2005 Brentwood Local Plan, to the so called Brentwood Enterprise Park at the M25/A127 junction fails to consider public transport for workers that the current industrial site enjoys via a bus service and the regular train service some 50m away. This will increase local road traffic congestion and exclude potential workers that are unable to travel to the proposed new greenbelt industrial site. There is a sad and unsustainable irony that many industrial sites are re-designated for housing at the expense of greenbelt for for 'employment'/industrial sites shortly afterwards.

As for the temporary works at the A127/M25, that was set up to allow the widening of the M25, I would be grateful that you provide me proof, in response to this email objection, that this site was temporary and that there was, originally, a commitment to return it to its current greenbelt designation. I note from the Strategic Growth Options Consultation that the definition of Brownfield is given as

Brownfield (previously developed land): Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. There are some exclusions to this, such as land occupied by agricultural or forestry buildings and private residential gardens.

Clearly the M25/A127 site is still greenbelt and should remain so as opposed to becoming another jigsaw piece towards the London Borough of Brentwood.

The A127 and A12 are already congested roads much due to the destruction of countryside along their corridors. This destruction continues as evidenced at the Fortune of War Roundabout area of Basildon on the A127. Any further development will exacerbate already dire congestion and will significantly and adversely affect the quality of life of those travelling on and living close to these roads.

Defra has designated all of Brentwoods farmland as 'Good'. The proposed destruction of 'Good' Grade 3 farmland will be a significant loss of food production for a country that is unable to feed itself without importation. Wartime generation politicians that created the greenbelt did so to the point of agricultural yield obsession due to the near starvation of the United Kingdom during WW2. Some of the most fertile and productive land ie the alluvial plains along the Thames, were built on between the wars and these politicians were determined that such shortsightedness ought not happen again. Building on existing farmland is dangerous and exacerbates the inability for UK to feed itself. This, potentially, affects everyone and food security ought to be a primary concern to both planners and politicians. We live in a fragile society and world and we saw a glimpse of this frailty during the fuel strike some 15 years ago.

Any future commitment to greenbelt policy will be permanently undermined given the original 'commitments' to it made by the post-war generation politicians who clearly envisaged situations such as this.

Continuous nibbling away at something ie The Greenbelt inevitably leads to nothing.

Please register my objection to the current Brentwood Strategic Growth Options Consultation

Yours sincerely

Comment

Strategic Growth Options

Representation ID: 6937

Received: 10/03/2015

Respondent: Boyer Planning

Representation Summary:

It is noted that the Interim Sustainability Appraisal which forms part of the emerging evidence base for the Local Plan does not assess any potential strategic allocations within this Growth Area (discussed further below), which confirms its lack of suitability in providing sufficient new development over the plan period in order to contribute on a large strategic scale to the Council's housing or economic needs.

Full text:

See attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6939

Received: 10/03/2015

Respondent: Boyer Planning

Representation Summary:

The Sustainability Appraisal prepared by URS in January 2015 assesses the possible strategic site located to the South East of Brentwood, which the report acknowledges could deliver a large number of new dwellings. In assessing this site against four other strategic sites, the report found that it performs well In terms of economic and employment objective, as well as community and well being considerations, due to its accessibility to community infrastructure. Consideration should therefore be given during the next stage of the Local Plan to further explore the potential for a large scale strategic allocation at South East Brentwood.

Full text:

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Attachments:

Comment

Strategic Growth Options

Representation ID: 6945

Received: 10/03/2015

Respondent: Boyer Planning

Representation Summary:

The Sustainability Appraisal highlights further potential issues in respect of such matters as impact upon SSSls, heritage assets, flooding and climate change. These will all need to be properly considered and assessed.

Full text:

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Attachments:

Object

Strategic Growth Options

Representation ID: 8413

Received: 31/03/2015

Respondent: Crest Nicholson

Agent: AECOM

Representation Summary:

We welcome the Council's review of the Green Belt to accommodate future development to meet housing and employment needs. As such, we believe development coming forward along the A127 Corridor and at PADC 5 can be 'feathered' into the wider landscape, creating an attractive environment for those living in the area, as well as providing a more visually coherent and defensible boundary for the extended urban area. For these reasons, we would disagree with the findings of the interim SA Report (January 2015) which states that west of Basildon performs poorly on landscape issues and that part of the 'area has low relative capacity to accommodate development without adverse landscape impacts'.

Full text:

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Attachments:

Comment

Strategic Growth Options

Representation ID: 11151

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

The 2013 SA concluded that the growth option that focused development primarily at Brentwood, Shenfield and West Horndon was the most preferable. An Interim Sustainability Appraisal (ISA) January 2015 has been produced. The Interim Sustainability Appraisal determines that the West Horndon SGL is ranked the most sustainable growth option overall. Furthermore, it ranks as the most sustainable option in terms of Economy and Employment, Housing, and Soil and Contamination.

Full text:

See attached documentation.

Attachments:

Comment

Strategic Growth Options

Representation ID: 11232

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

With the three broad growth areas identified (North, A12 and A127 corridors), the preferred options focused on the A127 corridor. The Interim SA supports this approach. EA Strategic has commissioned a review of the Interim SA which will be submitted to the Council shortly.

Full text:

See attached documentation.

Attachments:

Comment

Strategic Growth Options

Representation ID: 11245

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

In the context of the review of the Interim Sustainability Appraisal, it is clear that the LPPO preferred option of a West Horndon Opportunity Area (Policy CP4) continues to be the most sustainable approach of the three option areas (North, A12, and A127) to accommodating the required growth.
Sub options of the A127 option - Dunton Garden Suburb or West Horndon are also considered.

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Object

Strategic Growth Options

Representation ID: 11276

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

We disagree with the assessment undertaken by the SA as we are concerned with the assessments ranking of DGS above West Horndon in terms of community and well being, air quality and climate change mitigation.

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Comment

Strategic Growth Options

Representation ID: 11279

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

It is noted that West Horndon is assessed in the SA as the most sustainable location overall, and most notably is ranked higher or equal to DGS in terms of biodiversity, cultural heritage, economy and employment, flooding, housing, landscape and soil and contamination (7 out of the 10 topic areas assessed). Significantly, DGS is identified as having the potential to lead to significant negative effects on the Green Belt, rural character, and the countryside, with low capacity to accommodate growth.

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Comment

Strategic Growth Options

Representation ID: 11283

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

The SA makes the fundamental assumption that DGS will have a new railway station, when it is understood that this is not necessarily the case. This could have a significant effect on the ranking of DGS for both climate change mitigation and air quality. The location of growth around West Horndon would focus development around existing transport infrastructure with capacity to expand, and local services and facilities reducing the need to travel far afield. The option of enhancing existing infrastructure in West Horndon seems to be disregarded by the SA, which instead concludes that DGS would have the greatest potential to offset the increase in car travel locally by supporting more sustainable patterns of travel. This conclusion is reached without explanation, and it is not clear how this could have been reached given the presence of existing employment and transport infrastructure at West Horndon.

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Comment

Strategic Growth Options

Representation ID: 11284

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

With regards to community and well-being, the SA suggests that both West Horndon and DGS (amongst others) perform similarly in the context of being larger more concentrated development, offering greater potential to provide new community infrastructure. However, there is no explanation as to why West Horndon then scores significantly lower in this topic area. It is important that this is clarified and that the SA is revised appropriately.

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Comment

Strategic Growth Options

Representation ID: 11285

Received: 17/02/2015

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

It is not that Basildon's Revised Preferred Options SA Report (2013) describes the land now known as DGS as PADC 5 (West Basildon Urban Extension). It considers that it would be likely to have a "significant effect on conserving and enhancing the diverse natural and urban landscape, countryside and green spaces" and concludes that "overall a mixed range of scores are given to the SA objectives which reflects the fact that the PADC is separated from existing services / facilities by existing transport and rail infrastructure which could act as a barrier to new residents and the policy does not include a range of new services and facilities considered to be in keeping with the scale of development". This reinforces the concern that the area earmarked for DGS is not suitable for the scale of development now proposed by DGS

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Comment

Strategic Growth Options

Representation ID: 11779

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Representation Summary:

The Interim Sustainability Appraisal (SA) represents a useful start to the assessment of reasonable alternatives. It is noted that Option 1 (Dunton) is identified as ranking high in the order of preference under a number of appraisal headings. It is worth noting that where Option 1 might be seen as scoring less well there are likely to be appropriate mitigation solutions. This would be likely to apply for example in the cases of cultural heritage, flooding and soil / contamination. The attached Appendix A represents an early and more detailed assessment of the potential delivery advantages of development at Dunton.

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Comment

Strategic Growth Options

Representation ID: 11781

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Representation Summary:

All of the Options assessed in the interim SA and any development in the three broad areas will require the release of greenbelt land. The evidence base has always indicated that the strategic objective to "safeguard the greenbelt ..." cannot mean no encroachment into the greenbelt. There are clearly 'exceptional circumstances' to justify the alteration of the greenbelt. Under paragraph 83 of the NPPF a review should be undertaken through the preparation of the Local Plan taking into account the five purposes of the greenbelt (paragraph 80 of the NPPF) and the need to adopt a sound plan - 'positively prepared', 'justified', 'effective' and 'consistent with national policy'.

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Comment

Strategic Growth Options

Representation ID: 11788

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Representation Summary:

In our view there is also a sixth reasonable alternative option to investigate as part of the evidence base which could be designed to concentrate on the delivery of Brentwood Borough Council's requirements only. A standalone settlement at Dunton which is not dependent on the delivery of other land to the east in the adjacent Borough Council area or on the development of land to the west of the A128. Assessment of such an option does not have to commit the Council at this stage to such a form of development but in order to make any subsequent plan 'sound' an objective assessment should be undertaken.

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Object

Strategic Growth Options

Representation ID: 12415

Received: 23/04/2015

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

It is noted that five alternatives were considered by the SA. Potential sites have been identified in Brentwood, Hutton, Pilgrims Hatch, Shenfield and Warley that together comprise 151 hectares of land that might accommodate circa 4,500 new dwellings. Consideration is also given to some 42 sites in the rural area. No explanation is given as to how the potential capacities were derived.

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Object

Strategic Growth Options

Representation ID: 12470

Received: 23/04/2015

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

The assessment of the alternatives within the SA is flawed, particularly in terms of air quality; climate change; and community and wellbeing. In relation to transport, the issue of accessibility and limiting the need for vehicular travel is a key consideration. West Horndon has an existing railway station and there is only a proposed station at Dunton. A new station at Dunton is not capable of delivery due to the proximity of other stations, Network Rails technical requirements and viability issues.

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Object

Strategic Growth Options

Representation ID: 12481

Received: 23/04/2015

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

In general terms we agree with the SA that options providing larger, more highly concentrated development offers greater potential to provide new community structure through developers contributions.
Whilst large scale developments at these locations would be required to provide services and facilities to serve new homes and jobs, in the case of West Horndon an early phase of growth on land to the east could utilise existing provision which could then be added to and enhanced as the later phases of growth are added. Dunton scores more positively in terms of spare primary school capacity, however we maintain that development of the scale proposed in both options would generate a need for additional schools to meet the demand of new homes.

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Comment

Strategic Growth Options

Representation ID: 12485

Received: 23/04/2015

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

In considering matters of biodiversity we confirm that our individual assessment of land east of West Horndon shows that there are sufficient opportunities to enhance the landscape and increase local ecological biodiversity by providing woodland buffer and links to ancient woodland. The broad brush SA is not capable of considering this level of detail.

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Comment

Strategic Growth Options

Representation ID: 12487

Received: 23/04/2015

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

An initial review of the SA comparison of sites would appear to rule out options 4 and 5.

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Comment

Strategic Growth Options

Representation ID: 12519

Received: 23/04/2015

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

Consideration of transport and access, urban and landscape design, landscape and visual impact, green belt, flood risk and, land use and soils has been made of the 5 SA options considered by the SA.
Pilgrims Hatch would require area wide traffic modelling, development here would result in the loss of Green Belt. Urban extensions generally have poor transport connection and lower levels of general infrastructure, allocation of some of the smaller sites will help ensure that the delivery of a 5 year housing supply comes forward where larger development would take longer.

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Comment

Strategic Growth Options

Representation ID: 12833

Received: 30/04/2015

Respondent: Crest Nicholson

Agent: Bidwells

Representation Summary:

Of the five suggested alternative growth options put forward in the Interim SA, three are within the A12 corridor; Option 3 - south-east of Brentwood-Shenfield, Option 4 - Pilgrims Hatch, and Option 5 - numerous smaller extensions. Development at Nag's Head Lane qualifies under this assessment as falling within Option 5, but we consider that each option should not be considered in isolation through assessment against each other. Options 3 and 4 would have significantly more damaging Green Belt impacts than development at Nag's Head Lane, but so would Option 1 in its totality (refer to section 3 below). It may therefore be the case that a combination of, or the most favourable components from the options are considered, but the SA as drafted does not appreciate that some Option 5 sites are inherently better placed to take a proportion of the Borough's housing requirement than other Option 5 sites. Our Design Development Framework's assessment of the other available sites on the edge of the Brentwood urban area (on pages 8 and 9) indicates that the land east of Nag's Head Lane performs better in terms of landscape and Green Belt impacts, impact upon infrastructure, it is more sustainable, and could be delivered quicker than many of the other sites.

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