See attachment.

see attached

see attached.

see attached

See attached.

See attached.

Email: Please note I am not in favour of any development in West Horndon Village.

See attached

see attached

See attached

see attached

see attached

See attached

see attached

see attached

I am writing to you with regard to your strategic growth options consultation.
As you can see I live in Harold Park which borders Brentwood and I do all my shopping etc in the Brentwood area and spend a good deal of time there. I very much enjoy travelling to Brentwood usually on public transport, and seeing the countryside and areas of green belt which surrounds both Harold Park and Brentwood. This is one of Brentwood's greatest assets, it is what draws people to live here and makes it a pleasant place to live. As such I was extremely upset to think that you would consider building on the green belt. Even this week the Standard newspaper quoted Thurrock and Epping Forest as the two top places that people wish to live in and gave the reason as "because it is surrounded by green belt land" (See Evening Standard Tuesday 3 February 2015, page 13). I believe this emphasises how important green belt land is and why it should not be built upon.

I list my reasons and comments below:
* Your document does not seem to have been approached on a sensible and even basis. Especially concerning the bias running through the document leading towards development to the south of the Borough. For example, the obvious and severe traffic existing problems on the A127 are not stated in the discussion, with development being seen as a possible solution to an inferred need, (3.12) whereas such growth in the A12 corridor 'could have similar negative impacts on infrastructure and services' (3.13) and in the even more so in (2.10) where development in the Brentwood urban area and north of the Borough creates problems whereas in the A127 corridor and West Horndon development "creates opportunities" according to your document.

* For the reason states above the consultation is not objective in terms of presentation and environmental and financial cost.

Q1: Do you agree with the three broad areas, for the purpose of considering approaches to growth?

No for the following reasons:

It is arguable whether the Borough needs subdividing at all for growth purposes.
In the absence of evidence relating to transport it is far from certain that this is the key matter to base decisions upon.

Even in the most rural parts of the Borough transport is not particularly poor compared with many parts of Essex let alone the country.

The subdivision is based ostensibly on transport but the north / middle / south land subdivisions is just too coarse a reflection of transport availability, this being predominantly linear in nature.

Even accepting transport led subdivisions in principle, this quickly needs to be refined by considering the questions of available capacity and financial and environmental cost to upgrade to accommodate growth. Without these considerations the basis of the study is unsupported.

Q2: Do you agree with the issues raised for each of these three areas?

Partially although the brief analysis 2.14 - 2.19 should be consistent. 2.19 is particularly biased whereby it makes an unsupported link between the character and availability of land for growth being potentially greater (surely this is the ultimate conclusion of considering all aspects of land use) and that the A127 has more scope for improvements than the A12 (and I would add, the A128, B roads and local road network).

To reiterate the point under Q1 if transport really is the key issue then a link is required between problems and solutions before judgements can be suggested.
Issues for the three areas should also concentrate on environmental impacts of the various options.

Q3: Do you have any comments on the appropriateness of particular sites?
I believe it is totally inappropriate to use Green Belt land for such purposes. I agree with the aim to maximise the use of brownfield areas both within urban and rural localities.

Even taking this into account should additional sites be required these should generally be of an infill nature or otherwise to create compact communities. This should apply to both urban and rural areas in order to create built up areas that minimise impact on landscape and facilitate the creation of a focus. The extent to which this principle should be applied would be based on minimising impact vs growth.

In terms of the sites illustrated:

3.12 - The completely new town 'Dunton Garden Suburb' would in my view have disproportionate impacts on the Green Belt in addition to creating a new urban centre which I feel would be detrimental to Brentwood Town centre and the road network. In addition the growth suggested for West Horndon is clearly disproportionate to the suggested aims above. Some smaller growth to West Horndon though could be accommodated whilst keeping the existing community compact and focused.

3.13 - In general both these option should be pursued within the aims I mention above. I would oppose the large scale areas shown south east of Hutton as per my comments on the 'Dunton Garden Suburb'. Further linear expansion at Brook Street termed 'Development options at M25' are also highly detrimental to the Green Belt by eroding this already narrow strip between Brentwood and the edge of the Green Belt in Havering, and that at Coombe Woods, Bereden Lane would be a planning travesty. Some smaller growth opportunities to Pilgrims Hatch, Shenfield and Honeypot Lane would perhaps have the least affect on the Green Belt and be close enough to existing built up areas to keep the built up area as compact as possible and focus activity towards existing urban centres. Small extensions to Mountnessing and Ingatestone that are within the confines of the existing road / rail corridor could also be considered.

The idea of an additional junction with the A12 to intercept the A128 is so obvious that I'm surprised that this wasn't incorporated back in the 1960s. It is this sort of link to the interrelationship between growth and transport that I was referring above although in this case it would have a significant added benefit to the community rather than just accommodating additional pressure created by growth.

3.14 - Isolated sites should not in general be considered for housing development such as Clapgate Estate and Thoby Priory. Some smaller growth to each of the main communities shown on the plan (except Navestock) could be accommodated whilst keeping the existing community compact and focused.

Q4: Given the greater capacity for growth along the A127 Corridor, which of the sites put forward do you think is the best location for growth?

This is a strange leading statement as the assumption regarding greater capacity for growth along the A127 Corridor remains undemonstrated. On the face of it the same phrase could be used to open a question about any other part of the Borough. For example, if necessary local road improvements could be considered for the area of the 'five villages' in the northern subdivision.

As discussed above in relation to the A127 Corridor limited growth at West Horndon is the only reasonable option for this sub area.

Q5: Should the A12 Corridor accommodate growth by releasing sites in the edge of urban area?

I assume that this is referring to Green Belt land and therefore my answer is no.

Q6: In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt)?

It is in general much more preferable for brownfield sites to be developed over greenfield sites however the impacts and implications of this do need to be taken into consideration. In some cases brownfield sites are best left in employment use and / or are not in a town or village context and in such cases creation of new housing in the countryside should be avoided.

Q7: To enable future employment need to be met do you agree that the most sustainable approach is to allocate new sites close to the strategic highway Network?

I think the link between employment use and the strategic highway network is likely to be sweeping and in cases the opposite is true.

I also believe that we should be looking at sustainable transport such as the railways and not adding to road traffic and pollution.

I would say that future employment need should be met by considering the full range of planning matters including impacts on the landscape and the green environment.

Q8: In order to ensure that the Town Centre remains economically sustainable, do you agree that a "Town Centre First" approach should be taken to retail development?

Definitely. Retail lends itself well to densification of existing land use and I do not feel that release of any green belt land should be necessary to accommodate such growth.

Q9: Are there opportunities for more open space provision in the area where you live?

Not so much provision of open space as the need for better recreational linkages between open spaces.

It would be helpful if the Council were more proactive in terms of the environment and, for example, provided public transport to the parks such as South Weald and Thorndon, or at least provide free parking for the first 2 hours. It is important to replace trees on the edge of roads etc to keep Brentwood feeling rural and not urban. To this end it is important to avoid advertising creep on business premises. I think it is important to not have neon signs for e.g. the Holiday Inn and other businesses. It is important not to allow planning creep, a poor example of this and one which the Council could have prevented is the large Sainsbury store which when it was first built was built away from the main road in quite a laid back position with trees and landscaping. Not long after it was allowed to build the monstrous car park which as well as being an eye sore has meant those arriving on foot have to walk much further to get to the entrance.
The A127 represents a severe block to north - south recreational routes. Effectively there is no sympathetic crossing for the 6.5km from Great Warley Road to Dunton outside of the Borough. This is very regrettable matter as it limits the value of Thorndon Park to residents of West Horndon and any recreational users coming from the south to the Park.

Q10: Please rate the level to which you value the landscape near where you live. (see page 29)

In Harold Park and living very near to the borders of Brentwood the following areas are very important to me.

Being able to see the countryside and not feeling like I live in a town, being able to see wildlife, the need for woods and trees to provide oxygen, to counteract pollution and to act as a sound barrier to prevent noise from the road and the railway. I would therefore rank the following as of equal importance.

Scenic Beauty / Outdoor Recreation / Wildlife interest / Historical interest / Tranquillity

Other - a key aspect omitted is views. As mentioned in my first paragraph it is very important to me to be able to see green fields, deer roaming, etc and I think that Brentwood Council should be doing more to prevent the urbanisation of the area. For example limit the advertising signage and changes which are more in link with an urban area than a semi rural one.

Q11: To what extent do you think the following is present in the landscape near where you live?

Houses - all the houses are in tree lined roads and surrounded by gardens and the estates are green with fields all around.

Commercial buildings - there are very few apart from a small number of local retail.

Nature Reserves - I can get to Thames Chase / South Weald / Thorndon Park in a matter of minutes.

Farmland - several farms although Oak Farm has never been seen as a proper farm.

Woodland - Many woods which act as a sound barrier, provide oxygen and look pleasant

Wasteland - none

Infrastructure - A12, A127, M25 nearby but not so near as to disturb the peace, railway nearby Leisure Facilities - sufficient, especially as I enjoy walking and cycling and there is a cycle path and several areas to walk in without needing a car.

Q12: Have we considered the main infrastructure issues? Are there other important issues to consider?

I do not believe that green belt should be built on at all. Instead the borough should be not allowing the building of large accommodation, for example most recent estates are for 3 or 4 bedroom detached houses where there is clearly a need for 1, 2 and 3 bedroom houses to meet the need especially factoring in the change in families, more single people etc.

Q13: What do you think the priorities for infrastructure spending should be?

This requires a study in itself and I note that this is being looked into (6.3). As stated throughout this response though I feel that Strategic Growth options need to come out of the conclusions from the infrastructure study (and studies into other such high level matters) rather than being in a response to a more arbitrarily suggested steer.

As discussed above I believe there are many opportunities for the council to be more pro-active in terms of infrastructure and caring about the environment and restoring and maintaining a sense of community. For example, including sustainable transport in any plans concerning infrastructure, for example, sensible and safe cycle lanes which don't encroach on the pavement. Free parking and transport to local parks. Maintenance of footpaths and public bridleways to encourage people to make use of the fields around. Support for local shops and local post offices. Encouragement for people to shop locally, for shops to sell local produce. Subsidies for milkmen, paper deliveries etc so that the elderly and vulnerable are included in any plans. Creating a community whereby the elderly and vulnerable are not isolated, for example encouraging businesses, banks and libraries to use people and not replace people with systems, e.g. banks in Brentwood high street, Brentwood library etc. This also has the added benefit of creating employment.

I look forward to hearing from you regarding the above in due course.

see attached

See attached

See attached.

See attached.

I write in respect of your Strategic Growth Options Consultation

A general comment is that the document needs to be much more evidence based an even handed. There is a bias running through the document resulting in a leading towards development the south of the Borough. I cannot cite all of these, but as examples:

The obvious and severe traffic existing problems on the A127 are not states in the discussion, with development being seen as a possible solution to an inferred need, (3.12) whereas such growth in the A12 corridor 'could have similar negative impacts on infrastructure and services' (3.13) and in the even more so in (2.10) where development in the Brentwood urban area and north of the Borough creates problems whereas in the A127 corridor and West Horndon development creates opportunities.

To prevent such a bias developing the whole consultation needs to be supported by an objective presentation of localities under 'stress' and the costs (both financial and environmental) to deal with these.

Q1: Do you agree with the three broad areas, for the purpose of considering approaches to growth?

No for the following reasons:

It is arguable whether the Borough needs subdividing at all for growth purposes and the approach to growth needs to be based primarily around Green Belt considerations. I believe that to accommodate growth all steps possible should be taken to limit the release of Green Belt and that this course of action should only be followed in extenuating circumstances where there is no other realistic possibility.

Other models for growth should be considered and I believe that to accommodate growth all steps should be taken to minimize the release of Green Belt. Means of doing this include:

* Maximising the use of derelict or underused urban space;
* Increasing densities within already built up areas;
* Developing brownfield areas both within urban and rural localities

Should any release of Greenfield land be absolutely essential these should be considered through
* Release of infill sites
* Release of many smaller sites on the edge of urban areas
* Application of suitably high densities to any greenfield land released.

Further comments on the broad divisions are:

In the absence of evidence relating to transport I think it unlikely that this is the only or most important matter on which to base decisions. Even in the most rural parts of the Borough transport is not particularly poor compared with many parts of Essex let alone the country. The subdivision is based ostensibly on transport but the north / middle / south land subdivisions is just too coarse a reflection of transport availability, this being predominantly linear in nature.

Even accepting transport led subdivisions in principle, this quickly needs to be refined by considering the questions of available capacity and financial and environmental cost to upgrade to accommodate growth. Without these considerations the basis of the study is unsupported.

Q2: Do you agree with the issues raised for each of these three areas?

Partially although the brief analysis 2.14 - 2.19 should be consistent. 2.19 is particularly biased whereby it makes an unsupported link between the character and availability of land for growth being potentially greater (surely this is the ultimate conclusion of considering all aspects of land use) and that the A127 has more scope for improvements than the A12 (and I would add, the A128, B roads and local road network).

To reiterate the point under Q1 if transport really is the key issue then a link is required between problems and solutions before judgements can be suggested.
Issues for the three areas should also concentrate on environmental impacts of the various options.

Q3: Do you have any comments on the appropriateness of particular sites?

I believe that principles regarding the release of Green Belt should be foremost and in principle all steps should be taken to minimize such release. I agree with the aim to maximize the use of brownfield areas both within urban and rural localities. I also feel that release of Green Belt could be further minimized by appropriately increasing the density of existing settlements.

Even taking this into account should additional sites be required these should generally be of an infill nature or otherwise to create compact communities. This should apply to both urban and rural areas in order to create built up areas that minimise impact on landscape and facilitate the creation of a focus. The extent to which this principle should be applied would be based on minimising impact vs growth.

In terms of the sites illustrated:

3.12 - The completely new town 'Dunton Garden Suburb' would in my view have disproportionate impacts on the Green Belt in addition to creating a new urban centre which I feel would be detrimental to Brentwood Town centre and the road network. In addition the growth suggested for West Horndon is clearly disproportionate to the suggested aims above. Some smaller growth to West Horndon though could be accommodated whilst keeping the existing community compact and focused.

3.13 - In general both these option should be pursued within the aims I mention above. I would oppose the large scale areas shown south east of Hutton as per my comments on the 'Dunton Garden Suburb'. Further linear expansion at Brook Street termed 'Development options at M25' are also highly detrimental to the Green Belt by eroding this already narrow strip between Brentwood and the edge of the Green Belt in Havering, and that at Coombe Woods, Bereden Lane would be a planning travesty. Some smaller growth opportunities to Pilgrims Hatch, Shenfield and Honeypot Lane would perhaps have the least affect on the Green Belt and be close enough to existing built up areas to keep the built up area as compact as possible and focus activity towards existing urban centres. Small extensions to Mountnessing and Ingatestone that are within the confines of the existing road / rail corridor could also be considered.

The idea of an additional junction with the A12 to intercept the A128 is so obvious that I'm surprised that this wasn't incorporated back in the 1960s. It is this sort of link to the interrelationship between growth and transport that I was referring above although in this case it would have a significant added benefit to the community rather than just accommodating additional pressure created by growth.

3.14 - Isolated sites should not in general be considered for housing development such as Clapgate Estate and Thoby Priory. Some smaller growth to each of the main communities shown on the plan (except Navestock) could be accommodated whilst keeping the existing community compact and focused.

Q4: Given the greater capacity for growth along the A127 Corridor, which of the sites put forward do you think is the best location for growth?

This is a strange leading statement as the assumption regarding greater capacity for growth along the A127 Corridor remains undemonstrated. On the face of it the same phrase could be used to open a question about any other part of the Borough. For example, if necessary local road improvements could be considered for the area of the 'five villages' in the northern subdivision.
As discussed above in relation to the A127 Corridor limited growth at West Horndon is the only reasonable option for this sub area.

Q5: Should the A12 Corridor accommodate growth by releasing sites in the edge of urban area?

The same general comment applies in that if so this needs to be based on environmental impacts in addition to a more thorough examination of local constraints and the costs / benefits of satisfactorily resolving these. On the face of it though the five main urban area in this subdivision are likely to offer the most from release of Greenfield land because there is

* A greater perimeter to the built up area and urban and semi urban landscape
* A number of existing town facilities
* A closer proximity of brownfield land and areas requiring regeneration in these areas
* A greater choice that investment from growth will go into Brentwood Borough
* In addition transport links this broad area are good

Q6: In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt)?

It is in general much more preferable for brownfield sites to be developed over greenfield sites however the impacts and implications of this do need to be taken into consideration. In some cases brownfield sites are best left in employment use and / or are not in a town or village context and in such cases creation of new housing in the countryside should be avoided.

Q7: To enable future employment need to be met do you agree that the most sustainable approach is to allocate new sites close to the strategic highway Network?

I think the link between employment use and the strategic highway network is likely to be sweeping and in cases the opposite is true. Certain employment uses can be advantageous in creating a positive mixture of land uses and communities. However as stated in the text some employment uses create a number of adverse impacts on communities. I do not think good strategic highway network per se is so important for many employment uses nor for modern business needs' however it may be that such a pattern develops by consequence of considering other aspects of planning. I would say that future employment need should be met by considering the full range of planning matters including impacts on the landscape and the green environment.

Q8: In order to ensure that the Town Centre remains economically sustainable, do you agree that a "Town Centre First" approach should be taken to retail development?

Definitely. Retail lends itself well to densification of existing land use and I do not feel that release of any green belt land should be necessary to accommodate such growth.

Q9: Are there opportunities for more open space provision in the area where you live?

Not so much provision of open space as the need for better recreational linkages between open spaces.

It would be helpful if the Council were more proactive in terms of the environment and, for example, provided public transport to the parks such as South Weald and Thorndon, or at least provide free parking for the first 2 hours. It is important to replace trees on the edge of roads etc to keep Brentwood feeling rural and not urban. To this end it is important to avoid advertising creep on business premises. I think it is important to not have neon signs for e.g. the Holiday Inn and other businesses.

The A127 represents a severe block to north - south recreational routes. Effectively there is no sympathetic crossing for the 6.5km from Great Warley Road to Dunton outside of the Borough. This is very regrettable matter as it limits the value of Thorndon Park to residents of West Horndon and any recreational users coming from the south to the Park.

Q10: Please rate the level to which you value the landscape near where you live. (see page 29)

Q11: To what extent do you think the following is present in the landscape near where you live?

I think it misleading to ask for a comparison between other areas in Brentwood Borough in Q10. The real aim should be to discover what impacts release of any Greenfield land would have. Intrinsic value of the landscape being considered for development is one of these, but the impacts would be a combination of both the nature of the proposed developments (including indirect effects) and aspects related to wider values relating to those areas impacted. The first part needs at least some definition. The second part needs to be judged not just on the parameters listed but also on other factors such as:

Views - this being more about the vistas that can be gained of and from the area under consideration.
Value in providing 'green lungs' to surrounding developed areas
Value in providing green continuity for the purposes of nature conservation recreation
Ability to be viewed and used

To take an example, an urban park may score v low on most of the aspects of question 10 but would suggest that the impacts of developing this space could be huge. My views on impact on landscape are largely answered under question 3.

Q12: Have we considered the main infrastructure issues? Are there other important issues to consider?

I'm not sure that green infrastructure covers the point I wish to make as green infrastructure sounds like a local provision to create a desirable community. The main issues for me surrounds the pattern of any release of Green Belt land to accommodate growth. I firmly believe that even if growth on one or two large scale land releases could be accommodated this model would seriously make Brentwood a poorer Borough compared with a more dispersed growth model. This is because the 'pain' of smaller Green Belt losses can be more easily absorbed and the gain more directly and perhaps fairly directed to the relevant community. With a few large scale developments the 'pain' of growth simply has to be swallowed - no one can ignore the detriment to the Green Belt that would be created by developments the size of that at West Horndon and the Dunton Garden Suburb but the gain is likely to be only too readily swallowed up in dealing with the obvious capacity issues that would be created by such a concentration of living and associated activity.

To restate, a more dispersed growth model can be used to efficiently use existing infrastructure capacity possibly with little intervention whereas large developments will inevitably require greater use of investment into the Borough in solving problems created by the development.

Q13: What do you think the priorities for infrastructure spending should be?

This requires a study in itself and I note that this is being looked into (6.3). As stated throughout this response though I feel that Strategic Growth options need to come out of the conclusions from the infrastructure study (and studies into other such high level matters) rather than being in a response to a more arbitrarily suggested steer.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

see attached

See attached letter

Please see attached letter

See attached document

See attached document

See attached document

Please find a paper Response submitted on behalf of Mr Derek Armiger comprising the following documents all forming part of the response:

1. The completed response form.
2. The attachments being further responses on pages 1-3 on the questions posed, a further 3 pages supporting development on the Sow N Grow Nursery site in Pilgrims Hatch with objections and comments on other sites in Pilgrims Hatch, and a feasibility plan (not to scale) for 42 dwellings for the Sow N Grow Nursery site.

CONSULTATION QUESTIONNAIRE

Q1: Yes - Agreed in principle - However the development plan also requires clear over-arching Borough wide policies to allocate sustainable development with priority given to re-using previously developed land.

Q2: Yes - Broadly yes - However each area requires reference to availably of previously developed land in sustainable locations and appropriate weight and priority is given to re-use for residential housing land, within and outside the Green Belt.

Q3: Yes - The Sow N Grow Nursery site comprises previously developed land in an area where there is limited supply of such land in sustainable locations. It is a sustainable location. Pre-application discussions are at an advanced stage and a draft scheme for 42 dwellings has been prepared and submitted herewith. Greenfield sites are less appropriate - See attached information.

Q4: The reuse of previously developed land at West Horndon is supported as better for redevelopment than use of Greenfield Land - as at Dunton Green. Priority should be given to previously developed land.

Q5: Yes - Sites on the edge of urban areas and urban extensions are preferred against new settlements on Greenfield Land. This is because development adjoining or on edge of a settlement allow better utilisation of existing infrastructure and urban services.

Q6: For identified suitable settlements and villages some small greenfield sites in sustainable locations should be considered for release from the Green Belt but after release and allocation as a preferred site for development where is previously developed land e.g. Sow N Grow site.

Q7: Yes - Sustainable employment areas should be allocated close to / near the strategic highway network, on greenfield sites if need be, where sustainable , to allow unsuitable employment sites to be released where there is poor access to the highway and there are adverse amenity impacts.

Q8: Yes - No further comment.

Q9: Yes - There is scope for existing greenfield land adjacent to settlements which may be poorly utilised for agriculture, e.g. scrubland around Pilgrims Hatch that could provide open and recreational space. These should not be released for development.

Q10:
Scenic Beauty - 3
Outdoor Recreation / Leisure Use - 4
Wildlife Interest - 3
Historic Interest - 3
Tranquility - 2

Q11:
Houses - 4
Commercial / Industrial buildings - 4
Nature reserves / wildlife - 2
Farmland - 2
Woodland - 2
Degraded / Derelict / Waste land - 2
Infrastructure - 4
Leisure / Recreation Facilities - 2

Q12: Yes - Overall policies required with regard to utilising more efficiently existing infrastructure and urban services and new infrastructure and urban services where these are to be provided.

Q13: Sustainable drainage, recreation / education and highways / public transport services.

CONSULTATION QUESTIONNAIRE ADDITIONAL INFORMATION

BACKGROUND.

This response follows pre-application discussions and a draft scheme for the Sow N Grow site submitted for pre-application advice. This is on-going, pending progress with the development plan document being adopted, when the site can be released from the defined Metropolitan Green Belt following National Planning Practice Guidance amended in October 2014.

Following the most recent pre-application advice a possible scheme has been amended to now show both Phase 1 and Phase 2 as was requested, with a feasibility layout for some 42 dwellings. The layout prepared for further discussions is now attached and is shown in the Medusa Design drawing forming part of this response.

This site is owned by the three members of the Armiger family who will act together to seek planning permission and develop the site once the requirements of the National Planning Practice Guidance are met or if the development plan process is sufficiently advanced to then allow for the release of this previously developed land from the Green Belt as a preferred allocation. Development could commence very quickly and be completed with five years.

It is a site in a highly sustainable location well served by public transport and other urban services and facilities within walkable distance.

It would not take any greenfield land away from agricultural use. The proposed redevelopment would give many amenity and visual improvements to the locality as well. The current mature and established treeline will be retained. The scheme would enhance the area.

The remaining small businesses need to expand and relocate to better premises and they are willing to do so on short notice terms . It can therefore be quickly developed to help meet objectively assessed housing needs in the Borough and locally.

It is understood that if the site is taken out of the Green Belt through the development plan process in accord with the NPPF and NPPG, then the local planning authority would have no objection in principle to residential redevelopment.

This response is made with this prospect in mind and the latest feasibility plan is enclosed at A4 print out (not to scale).

In addition to the detail of the comments in the response form MrArmiger would like the following comments including the above are added:

Q1: The broad areas for different approaches to the Strategic Growth Options are agreed. However regard should be had to the necessity for over-arching Borough wide policy guidance as well to ensure coherent treatment of development options and future applications to accord with then NPPF and NPPG.

Q2: The availability of previously developed land within each area needs to be known and assessed before policy can be fully determined, and the availability assessed of sites, whether within or outside the Green Belt.

Within the sub-areas where there is limited previously developed land mostly within the green belt then these should be given more weight in releasing such land than areas where there are greater areas of such land, e.g West Homdon, and there should be an overall requirement to ensure there is policy guidance for development giving weight to previously developed land being used, before the release of greenfield land, whether within or outside the greenbelt.

This would be important for the Brentwood and Pilgrims Hatch areas, and any other areas adjoining Brentwood's and other settlement's built up areas.

Q3: For the above reasons and for the reasons given in the first page of this response a previously developed piece of land of limited visual and of no agricultural value or purpose should be given great weight for release for residential redevelopment in new policy even if within the greenbelt, throughout the Borough and for the local area, and for this part of Pilgrims Hatch in particular.

The Sow N Grow site is particularly suitable for release from the Green Belt and residential development as previously developed land. Other Pilgrims Hatch sites are greenfield or scrub open land and not so suitable and should be given lower or no priority.

Such an approach would then allow less favourable sites in greenfield and agricultural use to remain in uses appropriate to the green belt, including open space and recreational use, unless very special circumstances apply. By allowing such sites as Sow N Grow and others comprising previously developed land to be released first for development it follows the need for the use of greenfield sites would be reduced throughout the Borough until essential for release.

Accordingly large green field site are objected to being developed throughout the Borough, and only if demonstrably needed should they be released, and only after all previously developed land is first utilised. A sequential over-arching policy is required.

With regard to Pilgrims Hatch a further two pages submission is made to this document supporting the release of the Sow N Grow Site No.010 with comments.

With regard to Pilgrims Hatch the following sites are not considered suitable for release from the Green Belt and/or residential development with further comments as appended in Response to Question3:

011A, 011B, 011C, 023, 024A, 0248, 053B, 147, 148, 156, 159, 176, 189, and 198.

COMMENTS ON SITES

010 Sow & Grow Nursery, Ongar Road, Pilgrims Hatch - Support development for reasons given in a separate document because this is agreed to be, and is, previously developed land.

011A, 011B & 011C Land rear of 10-20 Orchard Lane, Pilgrims Hatch - Object. 3.47ha in total. Mainly greenfield and or agricultural land. Not previously developed land (PDL).

012 Garage courts adjacent 49 Lavender Avenue, Pilgrims Hatch - No objection.

023 Land off Doddinghurst Road, either side of A12, Brentwood - Object. 7.2 ha. Mainly greenfield/ animal sanctuary land. Not PDL.

024A & 024B Sawyers Hall Farm, Sawyers Hall Lane/Doddinghurst Road, Brentwood - Object. In total some 20.25 ha. Mainly greenfield / animal sanctuary land. Not PDL.

053A Land rear of 146-148 Hatch Road, Pilgrims Hatch - No Comment.

053B Land rear of 146-148 Hatch Road, Pilgrims Hatch - Object. 4.0 ha mainly greenfield or woodland. Not PDL.

054 Garages adjacent 25 Kings George's Road, Pilgrims Hatch - No comment.

086 Land at Sandringham Road, Pilgrims Hatch - No objection.

088 Bishops Hall Community Centre and land & 089 Brentwood Centre and land - No objection to retention of the existing use.

097 Harewood Road bungalows, Pilgrims Hatch - No objection as above (89).

132A & 132B Land at Albany Road, Pilgrims Hatch - No objection if PDL.

134 Land at Gloucester Road, Pilgrims Hatch, Brentwood - No objection of PDL.

137A & 137B Land at Broomwood Gardens and Dounsell Court, Ongar Road - No objection if PDL.

147 Land at Joy Fook restaurant, adjacent Bentley Golf Club, Ongar Road - Object. 0.47 ha. Isolated site. Not a sustainable location.

148 Land at Moat Farm, 48 Crow Green Road, Pilgrims Hatch - Object 0.69 ha. Greenfield land and not PDL.

156 Greenacres Riding Stables & land opposite, Beads Hall Lane - Object 5.5 ha. The site is not fully PDL and in an unsustainable location.

159 Land off Crow Green Lane, Pilgrims Hatch - Object. 2.8 ha Greenfield land and not PDL.

176 Land at former Bentley Zoo, Hullets Lane, Brentwood - Object. Garden land not PDL

189 Former Catrina Nursery, Ongar Road, Pilgrims Hatch - Object. 2.89 ha. Greenfield land and not fully PDL.

198 Land to the south-east of Doddinghurst Road, Pilgrims Hatch - Object. 5.69 ha. Greenfield and agricultural land and not PDL.

227 144 Crow Green Road, Pilgrims Hatch - No comment.

GT009 Cottage Garden, Beads Hall Lane, Pilgrims Hatch - Gypsy site no comment.