Please find a paper Response submitted on behalf of Ms Maxine 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.

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.

Q1: Do you agree with the broad areas, for the purpose of considering approaches to growth?
Yes
No X

Comments








?

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

Yes
No X

Comments







?

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

Yes X
No

Comments
Sites 209, 043,080,188 are not appropriate for development sites - there are already significant safety issues with the crossroads adjacent to these proposed development areas and an increase in vehicular movements would only prove to exacerbate the problem. The sites are very rural and there is no connectivity in terms of cycle routes or pedestrian routes to the neighbouring village, so residents are more likely to use conventional forms of transport because of distance and safety issues. Site 209 is also open fields at the moment and development of these would have both a detrimental effect in terms of environmental impact on the area and views for the neighbouring properties.









?

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?



Comments







?

Q5: Should the A12 corridor accommodate growth by releasing sites on the edge of urban areas?
Yes X
No

Comments

This would be more appropriate than the rural areas depending on improvements to local infrastructure and connectivity to arterial routes and M25 junctions





?

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 the Green Belt)?



Comments

Development of brownfield sites






?

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?
Yes X
No

Comments

For the purpose of transport and commuting.






?

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?
Yes X
No

Comments










?

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

Yes

No X

Comments
NO






?

Q10: Please rate the level to which you value the landscape near where you live (on a scale of 1 to 5), as compared to other areas within Brentwood Borough, for the following aspects:
Aspect: Very Low Low Average High Very High
Scenic Beauty / Attractivness 1 2 3 4 5X
Outdoor Recreation / Leisure Use 1 2 3 4 5X
Wildlife Interest 1 2 3 4 5X
Historic Interest 1 2 3 4 5X
Tranquility 1 2 3 4 5X
Other - please specify:

............RURAL............................. 1 2 3 4 5X


?

Q11: To what extent do you think the following are present in the landscape near where you live (on a scale of 1 to 4):
Aspect: Absent Occasional Frequent Predominant
Houses 1 2 3 4X
Commercial / Industrial buildings 2X 3 4
Nature Reserves / Wildlife 1 2 3 4X
Farmland 1 2 3 4X
Woodland 1 2 3 4X
Degraded / Derelict / Waste land 1 X 3 4
Infastructure (Road / Rail / Pylons etc.) 1 2X 3 4
Leisure / Recreation Facilities 1 2X 3 4
Other - please specify:

......................................... 1 2 3 4





?

Q12: Have we considered the main infrastructure issues? Are there other important issues to consider?
Yes
No

Comments







?

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




Comments

see attached

1. Managing Growth

Q1 Do you agree with the three broad areas, for the purpose of considering
approaches to growth.
Q2 Do you agree with the issues raised for each of these three areas.

The whole Borough should be looked at as a whole when considering a coordinated approach to growth. To split the Borough into three broad areas does not achieve the primary objective, which is growth to enable the Borough to grow as a whole. The approach taken by the Council allows it to weight significant growth in the area it wishes, which is predominantly the A127 Corridor and to limit growth elsewhere in the Borough.

In the last consultation document, West Horndon was strongly pushed by the Council as an area that could take significant growth. There was strong objection to this plan, so the Council have decided to move the area slightly eastwards but still achieving its objective of siting the majority of the required housing as far away from the main conurbations of the Borough as possible and calling it Dunton Garden Suburb. The word garden is designed to make the area sound prettier than it really is. Again the Council have ignored the need to spread development throughout the Borough.

The wording of the three areas is misleading and highlights areas of concern for development in the north of the Borough and the A12 Corridor whilst glossing over any issues with development within the A127 Corridor. Why does the Council believe that "although the A127 suffers from congestion problems it has more scope for improvements than the A12 ". The A127 has significant problems and is beset with traffic issues. The amount of money needed and infrastructure changes required to sort either the A127 or the A12 out to handle a new town will/would be massive. The damage caused to the environment whilst the work was being undertaken and the resulting damage to the landscape would be irreparable.

As previously mentioned the issues for the three broad areas are significantly weighted against Option A (North of the Borough) and Option B (A 12 Corridor) in favour of Option C (A127 Corridor). It is accepted that land will have to be released from the Green Belt to allow the Borough to reach its housing target and provide the necessary employment land.

If the Borough is considered as a whole instead of splitting it into areas then development on the outskirt of sustainable villages such as Ingatestone, Hutton, Kelvedon Hatch etc along with larger developments on the outskirts of Brentwood and Shenfield would allow the impact on the Green Belt to be minimised. To erect 4000 plus houses along with employment land along the A127 Corridor would create more damage to the Green Belt. The Council seek to minimise the effect by describing the land as of different landscape character and making this a reason for encouraging development. First and foremost it is Green Belt and its different character should be the reason for encouraging its preservation and not destroying it.

In the Council`s latest Sustainability Appraisal it states: "Sites which make up Option 5 would be dispersed around the periphery of towns and villages. While this would lead to adverse landscape effects, it is considered that the smaller scale of developments would reduce the adverse effects compared to the other four options. There would be greater scope to avoid development in areas or particular landscape sensitivity and/or Green Belt value." The preservation of the Green Belt, according to one of the Council`s previous questionnaires, is the primary concern of the residents of the Borough. The potential for development throughout the Borough not just on a few large sites and one in particular would more accurately achieve this concern.

2. Sustainable Communities

Q3 Do you have any comments on the appropriateness of particular sites
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.
Q5 Should the A12 Corridor accommodate growth by releasing sites on the edge of urban areas.
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).

The Appropriateness or not of sites was looked at during the SHLAA Consultation. With over 230 sites put forward during this process it is not possible to comment on the appropriateness of every site. It is considered that a new more up-to-date Consultation should take place due to the time lag and new Government Policy since the original Consultation in 2009.

Site ref no 220 - Collins Farm, Goodwood Avenue, Hutton is a greenfield site that lies on the edge of Hutton. In the original SHLAA assessment it stated; "Availability dependant on the farm tenancy. The site is under option by a developer. The site offers good location for the extension to Goodwood Avenue and Hutton. There is good access to the road network, adjacent to an area of nature conservation to the North and West. The site however is a large extension into open countryside and as such has been discounted".

There was confusion in the original submission hence why the whole farm was shown outlined on the plan submitted. In March 2010 further information was submitted showing the area for development being reduced by approximately 70% of the total area and allowing for an extension of the conservation area onto land adjoining the site. With the increase in housing numbers required by the Borough, this site allows for sustainable growth whilst increasing the area of green open space. There is no farm tenancy affecting the land so the site can meet the existing demand for houses in the Borough.

Question 4 regarding growth along the A127 Corridor is a leading question that assumes that development should take place along the A127. As previously mentioned, it is considered that development can be accommodated throughout the Borough with a proportion of this development along the A127. West Horndon would be considered the most appropriate viable option to take limited development along the A127 Corridor due to existing infrastructure.

Any residential development along the A127 Corridor is likely to have minimal impact on the long term sustainability and stability of Brentwood Town Centre and village communities spread throughout the Borough. The proposed Dunton Garden Suburb may benefit Basildon Town Centre but will not benefit Brentwood. The sustainability of initially the West Horndon Scheme and now Dunton Garden Suburb scheme must be called into question. The infrastructure will need substantial investment and the area of Green Belt lost would not fit in with Council policies.

As part of an integrated scheme sites should be released along the A12 Corridor to encourage the long term prosperity of Brentwood, Shenfield and Ingatestone. This option should be joined with the other options to enable the Borough to grow in a sustainable way. The strategic growth options should enable the Borough to have a long term plan, this will not be achieved by building the majority of houses required at the furthest South Eastern tip of the Borough.

Brentwood Borough, as shown by the recent Strategic Housing Market Assessment (SHMA), is a Borough where people want to live. There is a proven need for more houses throughout the Borough, not just for those wishing to commute into London but for those wishing to work within the Borough. The SHMA described Brentwood as an affluent area with higher than average employment, low unemployment and average pay higher than benchmark
averages.

The question that needs to be asked by the Council is why do people wish to move into the Borough and where do they wish to live and not just where can we build thousands of homes to meet our housing target.

In relation to question 6, it has previously been mentioned that an integrated approach is required to meet the housing demand within the Borough. It is interesting to note that as this option is clearly the least favoured by the Council it mentions land lost within the Green Belt whereas Questions 4 and 5 both fail to mention that development for these options will predominantly be within the Green Belt.

The Borough`s population is expanding and is expected to grow by approximately 10% between 2011-2021, this is in fact lower than the average for Essex as a whole. The number of households is expected to grow by a similar figure over the same period, these figures are well below the Boroughs of Colchester and Braintree. This equates to at least 3000 new homes in this period. Migration into the Borough is growing according to the SHMA and this is expected to continue. Migration helps the Borough`s economy through houses built and
sold, new businesses and support for existing businesses within Brentwood and surrounding villages. Development throughout the Borough will provide the necessary diverse housing required by its existing and future residents. Diverse housing is also required by the government.

An extract from the latest government guidance states; ".... Address the need for all types of housing, including affordable housing and the needs of different groups in the community and caters for housing demand and the scale of housing supply necessary to meet demand." By providing new homes throughout the Borough, including on the edge of villages, the Council will be meeting the criteria as set down by the government. It will be providing a variety of houses/sites to meet the varied demand of the population, this will not be met by building thousands of houses in Dunton which lies distant from the heart of the Borough.

Building on the edge of villages will not just be meeting local need, as the question infers, it will be meeting the need of existing residents and those wishing to move into the Borough. In the Council`s own literature it is accepted that the least harm to the Green Belt will be to build on the outskirts of villages, on smallish sites spread throughout the Borough. Within the recent SHMA it recognises the clear need for more houses within the Borough and that one of the main reasons for moving house, for existing householders, is the quality of the neighbourhood. For concealed householders the two main reasons for moving house was to be near family and they had always live here. Whilst the Council is set on building thousands of houses along the A127 Corridor, it is difficult to see how this meets the criteria of existing and concealed householders. An integrated housing policy, with development throughout the Borough would meet the main criteria for people wanting to move.

In the SHMA it was identified that 56.5% of residents travel to work by car, this is lower than all other benchmarks. With development throughout the Borough, increased public transport and a greater reliance on working from home this figure could be reduced further. There has been little/no mention of live/work units, these could be created to encourage people to work from home on a regular basis. With increased technology there is a trend for people to go into the office less and instead work from home. When live/work units were originally introduced they were for craftsmen to have workshops adjacent to their homes, this has progressed to a person having a fully functioning office above their garage or within their house - they are fully connected to their office but do not need to travel in every day. This reduces car usage and encourages the use of local facilities.

3. Economic Prosperity

Q7 To enable future development need to be met do you agree that the most
sustainable approach is to allocate new sites close to the strategic highway network.

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.


Constructing new employment sites near/adjoining the strategic highway network,
throughout the Borough (not just along the A127) will attract multi-national firms to the area whilst providing employment to local residents. To be sustainable it will be necessary to improve/provide public transport to the sites. There must be consideration for local businesses to expand and to encourage new businesses within residential areas providing they are compatible ie office use, shops etc. By providing an integrated approach it will encourage new sites to be developed and for businesses to grow within villages, thereby providing local employment and reducing car usage.

To ensure that the Town Centre remains economically sustainable it is essential that housing development is not solely situated as far from the Town Centre as possible in Dunton. Public transport needs to be improved to enable access to the Town Centre and parking provisions need to be appropriate for those wishing to drive. The Council could consider the approach taken by Chelmsford Council of providing a park and ride scheme, to avoid congestion in and around the City Centre and to encourage shoppers into the City. A coordinated approach that considers the motorist is essential to enable the town to survive and thrive in the long term. There has to be greater access to the Town otherwise residents will drive to Lakeside/Bluewater where there is plentiful parking. The residents of the Borough should be encouraged to see the Town Centre as their main destination whilst using local shops where possible.


4. Environmental Protection and Enhancement

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

Q10 Please rate the level to which you value the landscape near where you live.

Q11 To what extent do you think the following is present in the landscape near
where you live; Houses, Commercial buildings, Nature Reserves, Farmland, Woodland, Wasteland, Infrastructure, Leisure Facilities, Other?


The Borough is well supplied with footpaths and open spaces, there are always
opportunities for more open spaces but are they needed or necessary. Opportunities could arise through more development throughout the Borough with developers providing money for the Parish they are building in. This would go directly to the Parish Council, not the Borough, and spent within the Parish, to provide improved/new local facilities.

The Borough is predominantly Green Belt and therefore small scale development
throughout the Borough will have the least effect on the existing Landscape, as confirmed in the Council`s latest report. The landscape throughout the Borough is valued and offers opportunities to be enjoyed by all. There are Houses, Commercial buildings, Woodland, Farmland and Roads (including Bus stops) all are within 100 metres of the property, there are also footpaths and areas to walk.



5. Quality of Life & Community Infrastructure

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

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

The main infrastructure issues have been considered however it is important that the money is directed in the right way. The priorities should be new schools, health facilities and improved road network including public transport. It is important for the Council to remember that the majority of the population still drive to work and therefore the roads in the Borough must be maintained to a high standard. The Borough is well served by its Green infrastructure and this should be at the low end of its priorities. The level of money spent on the infrastructure of the Borough must be kept at a level commensurate with an expanding population.

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Covering Letter

We act on behalf of Asphaltic Developments Ltd and write in respect of the above consultation, to
which we are instructed to submit representations.

As you are aware, our client has an interest in the Brentwood Leisure Park, in Warley, Brentwood, which is detailed on the enclosed site location plan (drawing ref: 159/30/3_SLP01). We previously submitted representations on the Preferred Options Local Plan consultation document in October 2013, to promote Brentwood Leisure Park's opportunity for housing development to be considered in the emerging Local Plan for the Borough.

Brentford Leisure Park is identified as one of the A12 corridor housing site options (site ref: 141) in the current consultation document. We consider that the Leisure Park site is a suitable and appropriate site for residential development in order to meet the Council's objectively assessed housing needs, which have increased to 5,500 homes in the plan period. As such, we request that the site's suitability and potential for housing development is recognised in the Local Plan through an allocation, as set out in the enclosed Consultation Questionnaire.

We request that our response to the "Consultation Questionnaire" is taken into account as part of the consultation exercise.

We respectfully request that the Council considers the representations in full and that those considerations will be reflected in the next stage of the document's preparation. We request that we are kept informed and updated of the forthcoming stages of the preparation of the Brentwood Borough Local Plan.

We will be pleased to provide further information or explanation on these representations should it assist. In the meantime, we look forward to receiving written confirmation that these representations have been received and duly made as part of this consultation excercise, marked for the attention of Wakako Hirose at this office.

Consultation Questionnaire

Q1 - With regard to the growth options, we agree that brownfield land should be utilised efficiently as part of future growth options for the Borough, and that there are brownfield development opportunities adjoining/surrounding the urban areas within the Green Belt.

We consider that in order to meet the Borough's objectively assessed housing needs, available brownfield land within the Green Belt should be utilised, which in turn would minimise the pressure on development of greenfield and undeveloped Green Belt sites. We therefore agree that brownfield development opportunities within the Green Belt should be actively promoted and utilised as part of the Borough's growth.

The Sustainability Appraisal ('SA') of the Brentwood Borough Local Plan (Interim SA Report January 2015) considers 5 options for growth, which include strategic sites on greenfield and agricultural land, as well as urban extensions (option 5). It states that it is appropriate to appraise Option 5, which would involve dispersing growth between a number of smaller sites, within or on the edge of existing urban areas, and more work would need to be undertaken to determine precisely which sites are best performing and should be developed, if it did transpire that the Council's preferred approach is Option 5. We consider that non-strategic brownfield sites which are connected to, or close to urban areas, thereby providing sustainable urban extensions, should be considered as one of the preferred options for the delivery of the Council's housing requirement. This is necessary to ensure a flexible and responsive supply of land, and to prioritise the re-use of previously developed land in line with national policy.

Q3 - Site Reference: 141: Brentwood Leisure Park

Brentwood Leisure Park is brownfield land within the Metropolitan Green Belt, in Warley, south of Brentwood. The site extends to 7.825ha in total (with that area of the site excluding the wooded area) extending to approximately 5.6ha. That part of the site, comprising the existing leisure park, including dry ski-slope, driving range, outdoor karting centre, a restaurant, a vacant indoor leisure centre and car park, represents brownfield land.

As advised in our previous representations, the Leisure Park site could come forward for redevelopment in the short to medium term, should the existing uses become vacant or unviable in terms of their ongoing operation. The site represents an available location for redevelopment and is a suitable (previously developed) site for residential use, at such a time when the existing uses become vacant or unviable.

The site offers a number of benefits, which lends it suitably for future residential development. These are as follows:

- The site can sustainably accommodate residential development, supporting the borough's objectively assessed housing needs;
- The site is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt;
- The site is well placed in relation to the existing built form, and constitutes previously developed land, and is therefore a suitable location for growth as an extension of the urban area; and
- The site currently contains dry-ski slope, driving range, and go-kart track, which do not contribute to the characteristics of Green Belts, and housing redevelopment has the potential to facilitate the provision of appropriate landscaping, which would contribute to the landscape value and the characteristics of the Green Belt in the surrounding area.

The SA undertook a sustainability appraisal of Option 5, as a whole, rather than individual sites. In order to inform the allocation of sites for housing development, sustainability of each sites considered under Option 5 would need to be assessed individually. Brentwood Leisure Park is a sustainable site, when assessed against sustainability criteria, and does not have many of the constraints as identified in the SA Site Specific Baseline Issues for Option 5, as follows:

- There is no Air Quality Monitoring Area in the surrounding area and road
network.

- The nearest station is less than 1.5 miles away (c. 1.2 miles). Additionally, the nearest bus stop, which provides bus serves to Brentwood Railway Station and the town centres, is within easy walking distance of the site (0.3 mile). Therefore, the site is accessible in terms of public transport provision.

- The site is accessible in terms of local facilities - the nearest local centre, including Post Office, and General Practice are approximately 1.1 miles and 0.9 mile from the site.

- The site is not within or adjoins Flood Zones 2 or 3.

- The site is previously developed land.

Accordingly, the site is considered to be more sustainable as a housing site than other sites under Option 5 or other strategic sites on greenfield and agricultural land.

As the site is very close to the existing urban area, it is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt, as set out in the National Planning Policy Framework (NPPF). Accordingly, the removal of the site from the Green Belt boundaries would not alter the position in terms of:

i) Checking unrestricted sprawl;
ii) Preventing neighbouring towns from merging;
iii) Assisting in safeguarding the countryside from encroachment;
iv) Preserving the setting and special character of historic town in the locality, and
v) Assisting urban regeneration.

We therefore consider that Brentwood Leisure Park is an appropriate, suitable and sustainable site for housing development to deliver the Council's housing requirements, without undermining the fundamental aim of the Green Belt policy for the borough through preventing urban sprawl and encroachment to the openness of the Green Belt.

Q5 - Yes. As commented under Question 1, we consider that the A12 corridor area, which has the majority of the existing towns and urban areas, should be the focus for growth to meet the Council's housing needs. This should be realised through the release of sustainable sites on edge of urban areas, including appropriate brownfield sites within Green Belt, such as Brentwood Leisure Park (as detailed in our comments under Question 3). It is considered that sustainable urban extensions are in line with national policy, through prioritising the utilisation of previously developed and are necessary to ensure a flexible and sufficient supply of land.

Please find attached my completed consultation questionaire for the Strategic Growth Options Consultation.
I support the principles set out in the National Planning Policy Framework for the protection of the Green Belt to prevent urban creep.
I strongly oppose inappropriate development in the green belt except in exceptional circumstances where the benefits clearly outweigh the harm and we also support the view that housing need alone does not constitute exceptional benefit.
However, I acknowledge the challenge that the Strategic Housing Allocation numbers present to Brentwood Borough Council. I recognise that without clear locations for the necessary houses identified by the Strategic Housing Allocation, Brentwood Borough Council will be highly unlikely to have a robust Local Development Plan approved. That presents the risk of aggressive speculative developers attempting to obtain planning approval anywhere in the borough and that the appeals system could result in inappropriate and poorly coordinated development taking place.
Thus in the unfortunate circumstance where Green Belt does have to be sacrificed in order to meet the statutory obligations of the Strategic Housing Allocation it is essential that only the minimum amount of land is sacrificed and that this is done in locations and in such a way that harm and urban creep is kept to an absolute minimum.
All my responses to the questions in the consultation must be viewed in this light.

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities.

The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area is correct.

Q3: Yes - Concern is raised at the prospect of the West Horndon strategic allocations, particularly in regard to the development on employment sites. Whilst the development of those sites is supported, the Council must ensure that sufficient employment land is brought forward alongside the allocation of these sites to ensure that employment is not lost in the Borough. The existing, undesignated, land at East Horndon Hall is ideally suited to provide additional employment land to accommodate those lost through brownfield redevelopment.

Q4: Proposals for development at West Horndon are supported, in principle. Representations will be made separately to the Dunton Garden Suburb Consultation, however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon;
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128;
* Failing to encourage the recycling of derelict and other urban land.

Q5: The focus of this submission is centred on the A127 Corridor and employment sites. This firm makes representations on housing issues in separate representations.

Q7: Yes - It is a logical decision to seek to allocated employment sites close to the strategic highway network and away from the higher populated areas of residential development. The site at East Horndon Hall meets those requirements, being located on the junction of the A127 and A128. The land is already currently partly used for industrial purposes.

The Company requests that their site at East Horndon Business Park is considered as a site allocated for general employment, either as existing or as a preferred allocation. This is a previous developed land, providing an excellent opportunity for new employment land to form a business park, incorporating some leisure opportunities. An Indicative Masterplan has been prepared and, whilst it has been previously submitted to the Council, we attach to this report for ease of reference.

It is proposed that the site can form a new business park, providing a mix of B-uses together with a leisure use, such as a hotel, as a feature building on the corner of the A128 and A127 roundabout.

The range of uses suggested is predominantly B1 office and light industrial uses. The proposals provide an opportunity to regulate the existing industrial uses and, whilst the site is heavily screened from the west and north, further landscaping and planting can be provided to create a buffer between the site and the A128.

The site is in a highly sustainable location in terms of highway networks, being located adjacent to the roundabout with the A127 and A128, with direct links to the M25, Brentwood, Thurrock and east Essex.

When considered in relation existing allocated employment land this site;
* Is in a strong location for accessibility where country lanes and residential roads are avoided, but easy access to the main arterial routes including A127, M25 and A12 (via M25 or A130);
* Requires limited landscaping and screening on the eastern boundary;
* Is of a size that allows for a comprehensive development, whilst being of a scale and nature appropriate to the locality;
* It is readily constrained by the A128, A127 and Tilbury Road, and thus makes a logical release from the Green Belt.

Furthermore, with the potential proposed allocation for housing within West
Horndon, replacing the existing employment land, this site is ideally located for an
increase in employment numbers resulting from the additional housing.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

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see attached.

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dunton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.

LAND SOUTH OF EAST HORNDON HALL
Concern is raised at the prospect of the West Horndon strategic allocations, particularly in regard to the development on employment sites. Whilst the development of those sites is supported, the Council must ensure that sufficient employment land is brought forward alongside the allocation of these sites to ensure that employment is not lost in the Borough. The existing, undesignated, land at East Horndon Hall is ideally suited to provide additional employment land to accommodate those lost through brownfield redevelopment.

FAIRVIEW, MAGPIE LANE
We would like as part of this submission to confirm support for the allocation of a parcel of land at Fairview, Magpie Lane, Brentwood. (see attached Site Location Plan). The site would fall within criteria 2 of the above approach to identifying land. The site is a brownfield site and is harmful to character and visual amenity in its locality. It is predominantly used as a waste transfer station and generates excessive heavy goods vehicle traffic on the local rural road network. The allocation of the site for residential use possibly with a small element of appropriate employment space would improve local amenity and provide resources to relocate the business.

A preliminary assessment indicates that up to 25 dwellings of range of sizes and tenures could be accommodated on the site, helping meet local housing need and improving the character and appearance of the area.

CHITRAL, SWALLOWS CROSS
We would like as part of this submission to confirm support for the allocation of a parcel of land at Chitral, Swallows Cross, Brentwood (see attached Site Location Plan). The site would fall within criteria 2 of the above approach to identifying land. The site is a brownfield site and is harmful to character and visual amenity in its locality

Our client has prepared a masterplan study including an indicative layout, indicative elevations and perspectives to demonstrate an appropriate formof development that can be achieved on this site. The proposals also show the provision of some employment space for local rural businesses The site delivers a range of planning benefits including providing towards housing need, making efficient use of a brownfield site and improving visual amenity . The preliminary proposals indicates approximately 20 houses and 2 commercial units.



Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period.

Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.

Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is appropriate to consider brownfield sites within villages, on the edge of villages and within smaller hamlets for development to meet housing need. Whilst less sustainable than town centre development such schemes can contribute to housing supply for local rural needs and affordable housing. Greenfield sites in sustainable locations are likely to need to be considered for development even after appropriate brownfield sites are developed.

It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - It is a logical decision to seek to allocated employment sites close to the strategic highway network and away from the higher populated areas of residential development. The site to the south of East Horndon Hall meets those requirements, being located on the junction of the A127 and A128. The land is currently partly used for industrial purposes, however there is potential for the land to the south to also be considered for employment use.

An Indicative Masterplan has been prepared together with a Highway Feasibility Summary (both attached), demonstrating that a mixed employment development of up to approximately 21 acres and potentially 34,000 sq m of new employment floorspace can be accommodated within the constraints of imposed by the highway and junction capacities.

The range of uses suggested is predominantly B1 light industrial uses, with elements of B2 and B8 use incorporated.

The proposals provide an opportunity to regulate the existing industrial uses and, whilst the site is heavily screened from the west and north, further landscaping and planting can be provided to create a buffer between the site and the A128.

The site is in a highly sustainable location in terms of highway networks, being located adjacent to the roundabout with the A127 and A128, with direct links to the M25, Brentwood, Thurrock and east Essex.

Furthermore, with the potential proposed allocation for housing within West Horndon, replacing the existing employment land, this site is ideally located for an increase in employment numbers resulting from the additional housing.

Given the lawful uses of the northern element of the site, the condition of the land, the containment around primary roads and the existing screening, the site currently makes only a minor contribution to the purposes of the Green Belt as set out in paragraph 80 of the NPPF.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

see attached.

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Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the area to the north of Brentwood and it is considered that the issues raised in regard to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.
We would like as part of this submission to confirm support for the allocation of the Joy Fook Restaurant, which sits adjacent to Bentley Golf Club, in Kelvedon Hatch (see attached Site Location Plan). The site would fall within criteria 2 of the above approach to identifying land.

Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period. Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.

Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - No further comment.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

see attached

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see attached

Q1: Yes - The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Q2: Yes - These representations concern the area to the north of Brentwood and it is considered that the issues raised in regard to this area are correct.

Q3: Yes - As stated within Question 1, the growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

It is evident therefore, that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.

The Green Belt boundary should be established on a strong defensible line. This should be a clearly defined and reasonably permanent physical feature in the landscape, such as a river, road or railway. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. At the very least, the Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' the entire village) and this exclusion must extend to the whole of the residential curtilage. What is required is not a straight line but a clearly defined and readily defensible boundary.

The Council should follow a hierarchical approach to identifying land to meet residential need, along the following lines:
1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the reasons that we indicate in the following question) it is very unlikely that it will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.
We would like as part of this submission to confirm support for the allocation of the land to the south of #, Mascalls Lane, Great Warley (see attached Site Location Plan). The site would fall within criteria 3 of the above approach to identifying land.

Q4: The focus of this submission is centred on the A12 Corridor. However, proposals for development at West Horndon are supported, in principle. Questions continue to be raised regarding viability, sustainability and deliverability of these sites and whether there is sufficient evidence to demonstrate that they could come forward within the plan period. Representations will be made separately to the Dunton Garden Suburb Consultation; however it is considered that this development fails in four of the five purposes of the Green Belt (Paragraph 80 of the NPPF). Such a suburb would: -
* Encourage the sprawl of large built-up areas (Basildon/Laindon);
* Potentially merge Laindon with East Horndon and West Horndon. Laindon itself is already merged with Basildon
* Further encroaches upon the countryside, creating a continuous stretch of development on the southern side of the A127, running from Nevendon to the A128.
* Failing to encourage the recycling of derelict and other urban land.

Questions are also raised over the deliverability of The Dunton Garden Suburb. Basildon Borough Council's Local Plan process has been set back, with the Council not expecting adoption until late 2018. Brentwood Borough Council will not be able to adopt their cross-boundary Development Plan Document until it is agreed and adopted by Basildon Borough Council. The proposals do not provide sufficient detail to demonstrate the deliverability of such a scheme and whether there is reasonable prospect of the full delivery of 2,500 dwellings within the 15 year period.

Q5: Yes - As part of the review of the existing Green Belt boundaries, development on sites on the edge of urban areas within the A12 corridor is supported.

Q6: It is questioned as to the extent of brownfield land available within villages. Given currently Green Belt restrictions, most of that land which was previously in brownfield use is likely to have been considered for development (under Paragraph 89 of the NPPF, an exception to inappropriate development is the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt). The brownfield land that is available within the Green Belt is generally found in more unsustainable locations outside of village boundaries. As a result, it is considered that, if in more suitable locations, Greenfield sites on the edge of villages should be considered.

Q7: Yes - No further comment.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

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