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 land adjacent to 365 Roman Road, Mountnessing (see attached site location plan), which 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.

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 land to the west of Heathlands, School Road, Kelvedon Hatch (see attached Site Location Plan), which 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.

see attached

Introduction

Since 2009, we have promoted 2.8 hectares (6 acres) of land off Crow Green Lane, Pilgrims Hatch, as a development allocation for inclusion in the local development plan, now known as the Brentwood Borough Local Plan. The land is referred to in the Consultation Document as Site 159. We have also put the site forward through the Council's SHLAA process, under reference G057.

Our main interest in the Consultation Document is its provisions for housing growth and associated community facilities. We have structured these initial representations around the Consultation Document's thirteen questions as set out in Section 7: Summary. However, we would like to comment first on the assessment of housing need on which the Document's Growth options are based.

In our representations on the Council's July 2013 Local Plan Preferred Options for
Consultation, we stated our objection to the Council's intention not to cater for all of the Borough's "objectively assessed" housing need. We described this as a very
risky strategy that would only delay decisions that had to be made on achieving an effective balance between meeting housing need and conserving the environment.

We are pleased to note in the current consultation that the Council now intends to
meet all the objectively identified needs. We have always been aware that Brentwood Borough has a high percentage of Green Belt land, significantly constraining development opportunities. Adjustments therefore need to be made to the current Green Belt boundary, which can be achieved without materially compromising its purpose. This will then accommodate the 3000 new homes that cannot be catered for on brownfield land.

Managing Growth

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

We supported Option 2 as set out in the 2013 Preferred Options Document, which
concentrated growth within the Borough's two main transport corridors. We think this is the best overall growth strategy for the Borough. In naming these corridors, we suggest moving away from using road names, using instead either "transport corridor" or the name of the railway line running through each. This would help shift the emphasis away from road to more sustainable transport modes. We also believe the Borough should be divided into four areas for the purposes of managing growth, as follows:
*The Rural North
*The Brentwood/Shenfield Transport Corridor
*The Rural South
*The West Horndon Transport Corridor.

The Document's Figure 6b shows approximate boundaries for the A12 Corridor. We support the boundary shown between Area (A) North of the Borough and Area (B) the A12 Corridor. This will allow for some modest growth around the edges of Pilgrims Hatch, which is where Site 159 is located. We suggest that the southern boundary is drawn closer to the urban edge of Brentwood and Shenfield, allowing the creation of a new southern rural area between the A12 Corridor and the A127 Corridor.

Sustainable Communities

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

We have promoted Site 159 as representing a relatively modest urban extension that can provide a mix of housing and community facilities in the Pilgrims Hatch area.

We note from the Consultation Document's paragraph 6.5 that the Council is looking to collaborative projects to ensure that appropriate healthcare facilities are provided to serve growth areas. Paragraph 6.8 also says the Council wishes to ensure that "new community facilities are delivered alongside new homes to support sustainable communities". In promoting Site 159 we have consistently stated our clients' willingness to make part of the site available for community use. We have prepared sketch schemes showing that housing and community facilities can easily be accommodated on Site 159. In discussions with Highways Officers, they stated they had no objections with regard to access, which is easily achievable to and from the site. Given the continuing ageing of the Borough's population, we further suggest, amongst other things, a care home in a semi-rural setting that will cater for the needs of older people.

Site 159 is within the Green Belt, immediately next to the existing urban edge. It has wholly defensible boundaries, and is currently used as grassland. There is a mixture of paddocks and buildings to the west. Housing all the way along the site's southern boundary presents a raw urban edge to this part of Pilgrims Hatch.
The Green Belt's main functions are:

*to check the sprawl of large built-up areas
*to prevent neighbouring towns merging into one another
*to assist in safeguarding the countryside from encroachment
*to preserve the setting and special character of historic towns
*to assist in urban regeneration by encouraging the recycling of derelict and
other urban land.

The Council has already considered all possible urban land recycling within the Borough and concluded that there is still a requirement to find land in the Green Belt for some 3,000 homes. Our assessment of Site 159 against the other four Green Belt functions is:

*sprawl - the site has buildings on two sides and definitive boundaries on the
others; contribution to preventing urban sprawl relatively small
*merging of towns - large rural area to the north; contribution to preventing merging of towns negligible
*countryside - buildings on two sides, with strong defensible boundaries to north and east; contribution to safeguarding countryside relatively small
*setting of town - the site is a narrow strip of land on the urban edge of Pilgrims Hatch. It makes a negligible difference to the setting of Brentwood as an historic market town.

Compared to many of the potential development sites shown within the A12 Corridor, allocating Site 159 would have relatively minor consequences for the function of the Green Belt in this part of the Borough. The site provides an ideal opportunity to make an early contribution to the Borough's identified housing needs and improve local community facilities. We have noted in past consultations the Council's identification of changes in local demographics, the most significant being a predicted continuing growth in the numbers of older people. Sites like 159 will provide opportunities for new facilities meeting the needs of older people on a relatively modest development close to the countryside. This would be a direct response to the Consultation Document's call, in paragraph 6.8, for new community facilities delivered alongside new housing.

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?

We have consistently supported the A127 Corridor as an ideal location for a
strategic development land allocation. This situation is now complicated by the proposed Dunton Garden Village, mainly located in Basildon District, but partly in the Borough. We think this is an ill-conceived idea that will seriously undermine the purposes of the Green Belt, especially in preventing the merging of neighbouring towns along the A127 Corridor.

We believe any new strategic development in this area should take the form of a high density, walkable settlement with West Horndon Station being developed as its main transport and commercial hub. The best site for achieving this would be the 2013 Consultation Document's West Horndon Strategic Allocation. To make the best use of West Horndon Station as a hub, it would be sensible to extend the strategic allocation across the Borough boundary into Basildon District.

Q5: Should the A12 Corridor accommodate growth by releasing sites on the
edge of urban areas?

Yes. We believe the search should start around the northern edges of Brentwood
and Shenfield, since it is here that the release of small to moderate sized sites will
have the least impact on the primary functions of the Green Belt.

The countryside between Brentwood and Shenfield, and West Horndon and Basildon to the south and south-east, is relatively narrow. Given the proposed westward expansion of Basildon and strategic growth allocation at West Horndon, it would be sensible to minimise allocations along the southern edges of Brentwood and Shenfield. Some of the sites shown on the Consultation Document's Figure 10, south and south-east of Shenfield and Hutton, would represent major intrusions into the Green Belt. Allocating Sites 028C and 192 would be particularly damaging to Green Belt functions in this area.

Any strategic allocation made at West Horndon will have a long lead in time before it will start to contribute to the Borough's housing needs. This is not the case with Site 159. New allocations in the A12 Corridor should include a mixture of small to medium sized sites, coming on stream earlier in the plan period, to maintain the five year housing land supply required by the National Planning Policy Framework.

Quality of Life & Community Infrastructure

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

We note the Consultation Document's reference in paragraph 6.4 to a growth in demand for school places and that at primary level existing capacity will be exceeded around 2017/2018. We also note what is said in paragraph 6.5 about healthcare provision. We have stated above our clients' willingness to dedicate part of Site 159 to a a new healthcare facility or residential care home to serve Pilgrims Hatch. This is a direct and positive response to the Council's aim, set out in the Consultation Document's paragraph 6.5:

"Plans to mitigate this (population) growth via developer funded and other collaborative working projects will be agreed before planning permissions are granted."

There is a general mention of investment in transport infrastructure. If the Council were to adopt the approach suggested above, developing a strategic allocation around West Horndon, investment in a new station hub and linked pedestrian/cycle networks would be critical to its success.

We see the overall priorities for infrastructure as follows:
*new community facilities as determined through consultation with local communities including the community of Pilgrims Hatch
*healthcare facilities, in particular those aimed at meeting the needs of the Borough's ageing population
*a new railway station hub, and footpath and cycleway networks, for the proposed West Horndon strategic growth area.

Conclusions
Sites that are readily available and make negligible contribution to the aims of the
Green Belt, such as Site 159 at Pilgrims Hatch, should be considered for development early in the plan period. Such sites with relatively short development lead in times will relieve pressure on the Council's five year housing land supply, as required in the current National Planning Policy Framework.

If Site 159 is removed from the Green Belt, it will be wholly suitable, achievable and, as stated previously, readily available to satisfy both housing and community
infrastructure needs of the area. No other site in and around Pilgrims Hatch can take all these matters on board.

This initial representation must be read in conjunction with all representations and
correspondence to the previous Plan relating to Site 159 at Pilgrims Hatch. We will
wish to make further representations at the next stage of the Brentwood Borough Local Plan 2015-2030.

see attached

Because ill considered development will adversely affect existing communities

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Explanation
I am using the PDF printed version of the 'Strategic Growth Options Consultation as a basis for my comments as requested. However I have struggled massively in trying to get a word version or to input my comments online so I am 'partially duplicating' the form for ease (I hope) of cross reference.
Before I start I would like to question the nature of the consultation and its description as a strategic study. It has come as a huge surprise to me and my neighbours to find a document that has been written about in the Brentwood Gazette many times and also elsewhere that also includes detailed areas that are suggested as potential development sites. In my line of work and past experience as an IT consultant, that is not a strategy but a tactical document. The strategy should surely be decided (i.e. Centralised development versus distributed development) and then sites sought to comply with that strategy.
The inclusion of suggested sites has worried so many people and since so many are sites that have been rejected previously as unsuitable there is a distinct feeling of impotence and hopelessness about our ability to determine the shape and character of our community and living environment.

Q1: NO - The definitions of the 4 options would seem to define the options for GROWTH but only insofar as growth being dictated by central government. I would however have preferred that ANY future growth is determined ONLY by LOCAL need from organically driven need i.e. the needs of those already resident in the area rather than to accommodate a major influx from other areas. It has been the case for at least 30 years that Brentwood is effectively FULL and now that the major development sites (Old Laundry Site, Warley Hospital, Geary Drive etc.) have been used up then the expression about fitting a quart into a pint pot seems appropriate.
By pure definition and based on the fact that the centre of a circle is infinitely small and the outside infinitely large, then areas such as Brentwood that have undergone radical structural and social change have far less room for additional growth whereas the areas further out from London on the circle have more space to grow with less social impact.
The change form a family based town to a transient population of 'individual flat dwellers' has already brought its issues and further weakening of communities by additional growth is unwelcome and unsettling and definitely NOT SUSTAINABLE.

Q2: YES - as far as they go!
This is the main part of the representations I wish to make.
2.14 and 2.15 give a satisfactory overview of the issues but they are not in this summary put in the context of the history of development of the Northern Villages (which for brevity I will call NV from here on.)
From an emotional viewpoint, and I will concentrate on Doddinghurst and its immediate areas, the community has seen a change in cohesion as have all areas over the 35 years since I moved here. The willingness and ability of residents to not only to participate but also contribute to the activities and social fabric of the village has been greatly impacted by the major trend towards both 'parents' in a family unit working and typically commuting to work outside the area and with no realistic prospect of an increase in 'local' employment so the oft quoted 'sustainability argument' is a very large red herring.
This tendency has huge implications for the 'voluntary' capacity of the village to help with early years child care, school based projects and after school supervision and help of senior age children. There is by locating more housing in the NV's an increase in the commuting not only to work but also to child care and at an older age, major isolation of young people from their friends due to a poor bus service.
Speaking as a parent of children (23 and 26), there is now a desire amongst young people to be located in towns. They don't want the drive to a station and the isolation of the last bus into Brentwood at 6.30 and none on a Sunday.
The villages are not as socially attractive to today's young people as they were to my generation who grew up in the London area and love the rural isolation of the villages. Many of those in the 'social housing' are heard to say that they feel cut off and miss the transport options of the town.

Is it therefore sensible to create yet more housing in the NV's that only compound that problem? (the relative house prices and the trends will I think justify my comments that the villages are not seen as so desirable as they were with the time and cost of driving to the train and facilities.)

Q3: As a high level overview, there are no sites defined in the document that are suitable with the exception of the 'doctors surgery site' in Outings Lane.
It is my firm belief and opinion that ALL of the rest are based on long term attempts to build on sites to the benefit ONLY of the developer and NOT the community of Doddinghurst.
They are in general Trojan horse developments that would set a DEVASTATING precedent for very major ongoing development and in many cases are on sites which have been repeatedly and firmly rejected by both Doddinghurst residents and by BDC planning.

In particular, site 070 has been repeatedly rejected as creating a new area for housing and extending the natural boundary of the village. The road at that point is treacherous and the wall at the side of the road supports the earthen bank that was put in place many years ago in order to widen the road. It is a blind bend and the local residents have REPEATEDLY come out is force to oppose development of the site.

I will now turn to the most important, to me, suggested developments - 143, 224, 185.

Together these developments threaten to completely destroy the rural character of the area. I acknowledge that 143 and 224 would have a major impact on me at 25 Park Meadow due to their location.

It is my contention that together, the three suggested sites are very definitely an attempt to build along the entire length of the unmade up part of Brook Lane. Brook Lane probably represents the best and most defining nature and character of the village. As its name suggests, the untarmaced road follows the Brook stream until it reaches a point where vehicles can no longer get through. It has been a beautiful walk for generations and certainly with my children as they grew up.
There have been repeated and ever increasing numbers of attempts recently to ride roughshod over the fact that the properties in Brook Lane were originally weekend 'sheds' made typically of wood and used by those

Putting aside emotion, the potential for developing even a small amount of this i.e. 143, 224 and 185 is effectively NIL since suitable access and egress for any of the sites is not available.

SITE 143 - this is bounded by Lime Grove and Peartree Lane (both parts). Lime Grove is a narrow Road that is already frequently difficult to get through with parked cars. It is doubtful if a fire engine could gain access to 143 in an emergency.
Peartree Lane (near Post Office) is similar in nature to Lime Grove and has no capacity for more traffic to site 143.
Peartree Lane (unmadeup part exiting onto Doddinghurst Road between Apple tree crescent and Mountnessing Lane - this has long been a local concern. It was unused for 30 years and was overgrown and impassable for vehicles but has at times in the past few years been used by some in suitable vehicles to gain access to the bottom of Lime Grove. It is a 'lethal' turnout onto the Doddinghurst Road on a blind bend without potential for improvement.
It might be thought that access could be made from my road, Park Meadow, but even if a very narrow strip of land at the bottom were used and even if it provided a sufficiently wide access, then the resultant traffic onto Mountnessing Lane and then onto the Doddinghurst Road would increase further this already dandgerous set of junctions.
Likewise with access through somewhere in Peartree Close. Peartree Close was the result of 2 successive developments of the long gardens of houses on the Doddinghusrt Road and has already increased the traffic in the top of Park Meadow at the junction mentioned above and is for local residents the final acceptable development to be tolerated.
This junction is almost blind and is a derestricted road with 'just' enough for 2 passing cars at this point. Traffic uses it as a cut through from Mountnessing to Brentwood and it can be very dangerous to turn out of safely. In addition a double decker school bus turns at the top and then reverses into the top of Park Meadow. It is a dangerous junction and cannot take further traffic.

This then causes me to turn to suggested site 224 which is one of those sites mentioned previously as having been developed from original weekend 'getaway' shacks where the amount of land was as we learned from a milkman years ago 'as much as you want and can walk around'. The resultant long gardens are in the green belt but the owners (and developers) have regularly tried to get around the limitations for their own benefit and frequently built first and asked for planning permission later (though I am not suggesting this in the case of this property but generally with these properties.)

If 224 was developed then supposing that around 50 (as a complete guess!) houses were built on 143 and 224 then they would either have to exit via the routes described for 143 or through the Brook Lane junction with Mountnessing Lane / Pettits Lane. This is a terrible turning without any visibility to the fast traffic from the left (from Mountnessing) at up to 60mph and Mountnessing Lane is only just suitable for 2 cars to pass slowly and that supposes that the edge of the road is complete without deep ruts and potholes which it suffers from terribly.
Mountnessing Lane is not regarded as important enough currently to get winter gritting and with the overflowing river at the low point there is frequently sheet ice on the bend just before a very damaged bridge and before a right hand bend that cars speed around. I could go on but suffice to say that exiting from either end of Mountnessing Lane / Pettits Lane is dangerous already with the current traffic levels.

Site 185 - I will only say that this is a peculiar and opportunistic suggestion. It cannot by itself be viable and it suggests that this and the 224 site are considered as a way of developing all along Brook Lane. The issues of traffic, access, water, sewerage, electricity, gas etc etc that this would raise would I imagine count this out of any serious consideration.

Sites 143 and 224
I have addressed the ruinous result on the rural nature of the area that these suggested sites would cause and the damage to the quality of life and small community feel they would cause. I will now turn to practical issues of services.
Sewerage and other 'piped' services - it has long been the case that there is no ability for anything but the conversion of an occasional property in the village because of the lack of sewerage capacity. This has been upheld by many planning enquiries.
Likewise, I believe that the availability of water is also limited.
I know from my professional training that the cabling for telephony / broadband is seriously in need of replacement and is limited in capacity at itsd local point (i.e. from the green cabinets to houses.)
The gas mains in Doddinghurst Road are like most of the old local infrastructure groaning at the continued additions of houses over the past 40 years and indeed have on one stretch more repairs than original pipe.
To continue to add to existing additions is as non sensical as adding electrical extension to extension blocks and as dangerous and uneconomical.

To upgrade the infrastructure would be inefficient use of capital compared to the number of extra properties gained and the huge impact on residents and particularly given that one of the strategies calls for 'filling in around the edge of villages' so that a huge amount of new infrastructure would be needed.

It would be far more efficient to create a new infrastructure such as that suggested at Dunton where there is real benefit from the dedication of such investment and the resultant (new) community benefits as a whole. (This however is still based on the diktat that central government is imposing on residents not of their own free will !!

Schools, Doctors and other local essential provision.
The schools are full and it is impossible to get a doctors' appointment. How are these to be addressed if there is more housing built?

Buses and public transport + Hospital visits
The 261 is our only remaining lifeline to Brentwood. It finishes at 18.30 and doesn't run on a Sunday. Residents and particularly older residents are forced onto taxis and in addition we are 'lumped together' with the outer London health services so that a patient may be at Queens or worse at Goodmayes hospital



IMPACT on new residents
It is my opinion that the inconvenience of many of these factors which we as long term residents have accepted will not be OK with a new generation and this therefore suggests that it is preferable to build new communities where they are addressed at the outset rather than impose new housing on us so ruining our way of life without benefit to potential new residents.


Q4: It is the least of the evils to develop along the A127 where there is a need for infrastructure and which would be the most efficient use of capital reaching the greatest number of new homes. The same investment in other areas would be away from natural transport lines and provide for less and more dispersed homes.

Q5: It is a misnomer that the A12 is an accessible corridor onto which the traffic from new homes can safely and easily gain access. The A12 being a 2 lane highway already has issues with access on and off at the junctions and the majority of the road in the Brentwood area is either at high level, single direction access or on the border of Chelmsford. The build at the fringes is therefore illogical.

Q6: Neither. To build on Greenfield Greenbelt sites at the edge of villages destroys the very aspect that makes them communities and places of belonging. The greenbelt was established in order to prevent the never ending sprawl of development threatened in the 1930's and it is not in this generations remit to 'steal' that preserved environment from future generations.
To build on brown field sites has been seen in this area a golden opportunity for unscrupulous developers and landowners to destroy sites so that they get planning permission to replace an 'eyesore' with new homes. This cynical disregard for the views wishes and needs of local residents should be strongly resisted except in very isolated cases such as the old Doddinghurst Doctors Surgery site in Outings Lane which encapsulates a small area defined as green belt but which most residents would be surprised to find so.

Q7: Yes but I would go further in encouraging the use of public transport and therefore the sites should have good road and rail access and a good bus service.

Q8: Yes this seems sensible to avoid a high street that only contains night time venues and cheap shops.

Q9: Doddinghurst has managed its resources well over the years through local action and dedicated volunteers to provide sport and recreation areas as well as open areas. I believe that this current provision is OK.

Q10: This question gives no scale or metric so I will just say that I value the landscape as 10 out of 10 and know that my family have appreciated that landscape and surroundings as they have grown up. However I also believe from local conversations that this love of the countryside including its associated deprivations may not cross all generations and some who have moved into the village bemoan the lack of transport, lighting and other facilities they were used to in their former homes.
I would therefore question why we are considering building new homes in an area that many no longer appreciate and in so doing destroy the landscape and environment and community that the current residents value so much.

Q11: What a strange question!
The landscape consists of Houses in the Doddinghurst direction; no obvious commercial buildings as such; Farmland; Woodland; very little infrastructure and parks as leisure facilities in addition to playgrounds and a village hall at the centre of the village.

Q12: The principle 'services' based infrastructure issues relate to the availability of water and sewerage which particularly sewerage is already over burdened; Gas / electricity both of which creak as the additions to the village over the past 30+ years put further demands on their ancient infrastructure typically to the point of failure.
The road system both within the village and at its access points of Church Lane, Outings Lane, Doddinghurst Road and Mountnessing Lane have as much traffic as can safely be accommodated and with little opportunity for improvement.
The nature of the village is such that spines come off the Doddinghurst Road and Church Lane (going into Mill Lane which most people think of as Church Lane). These spines are typically long and may have 1 or 2 further roads off them. The main spines and particularly Lime Grove are very difficult to get through at times due to the 'necessary' parking outside houses.
Speaking as a network designer in a previous career, the ability to provide to these spines is already past the natural design point and the accesses to the core Doddinghurst Road / Church Lane is dangerous. Additionally, the other routes in such as Outings Lane have their own dangers as has been proven by accidents over the years especially in icy weather (look at the numbers of cars that end up in the ditches at Park Wood each month.)
The needs for new infrastructure in Doddinghurst compared to the cost versus new homes served would suggest that this is not the area for development.
That point and others has been at the heart of the planning rejections for almost all of the 'suggested' sites in the current consultation and why I am so concerned that previously refused planning applications seem to have gained a new life as if rising from the dead to haunt us!

Q13: Put the money into areas where it will give the greatest return i.e. benefit the greatest number of residents which equates to new areas not piecemeal additions onto unwilling areas such as Doddinghurst where it will only destroy and not benefit residents.

Provide sufficient affordable parking near stations to enable residents to use public transport and also improve bus services to a point where they are a viable alternative to the car. Where possible and sensible, provide safe cycle routes. Unfortunately this is effectively impossible form the villages as has been demonstrated by previous attempts by the council and voluntary bodies.

Stop the illogical trend to send people to far-away hospitals! Many or most residents have moved out of London and have little or no affinity to it now. However for some reason we are expected to get to Goomayes hospital or Queens or Basildon. It is hard enough for young people to achieve this but when an elderly person needs to visit a spouse in hospital say on a Sunday it is VERY expensive and tiring for them and massively increases their sense of isolation which ultimately causes additional care costs for them. We are a part of Essex to whom we pay council tax and although I acknowledge that Health is from Taxation it seems often to be a fact that is ignored.

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Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

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.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

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Q1: Yes - The Borough logically splits itself into three identified areas, which are also of different character. It is sensible to look at the main infrastructure corridors as individual areas. In particular to identify the central A12 Corridor as this includes the main settlements of Brentwood and Shenfield and which is favourable in sustainability terms.

Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites contributing to the relevant small local communities as well as indirectly established community facilities. In this respect this submission and link to the Thorndon Park Golf Club, which has a potential small housing site not previously submitted in the earlier SHLAA consultation.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate
representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - These representations have been submitted with respect to land ownership of Thorndon Park Golf Club (TPGC). TPGC has served the community for many years and is acknowledged as one of the finest golf clubs in the South East of England. Created by the legendary Harry Colt in 1920. TPGC is the only golf club in Essex in the top 100 in England, which is a major accolade for the Club and Borough and is a good marketing point for the Club. With a thriving membership of 698 (including 50 players who are under 18 years of age). TPGC attracts visitors from overseas and throughout the UK with 3,835 visitors enjoying this remarkable parkland course in 2014.

The Members see the course as a community asset of which they are the custodians of. They are very conscious not to create a development that would detract and are adamant that any monies raised would be ploughed back into the course for the benefit of future generations. Additionally, in the short term, such funds would ensure that TPGC remains Essex's premier course.

The Club has extensive land ownership which we show identified on the O.S. base
provided, which includes important woodland areas that contributes to the overall
environmental character of this part of Brentwood.

It is highlighted that any policies in the Plan to be brought forward should seek to
encourage associated developments of such clubs alongside other similar recreation facilities i.e. Hartswood Golf Club Pay as you Play, offering a different leisure opportunity.

As self-promotion of the Borough in terms of tourism, ecology and the ability please refer to the historic importance of Thorndon Park Golf Club and it's now recognised position as one of the top golf clubs in the country is an important consideration that should be reflected in the emerging plan.

Alongside this representation we have identified a small housing site that could
contribute up to 4 dwellings. It is a logical rounding off of the Green Belt and an
extension of a small existing cul-de-sac where the infrastructure is all in place. It is highlighted that the additional benefit to community services as all the sale proceeds will be utilised in maintaining the golf course's high quality thus securing greater improvements to bring it to a higher recognised golfing standard as well as securing the maintenance of the Club's woodlands and quality golf course.

Q13: No comment.

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We refer to the above consultation and respond on behalf of our client, Mr M Brown, of Jericho Priory, Church Street, Blackmore as follows:

Consultation Questions

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

Response: Yes, but with greater emphasis on expansion of villages, such as Blackmore to ensure they are fully sustainable.

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

Response: In respect of any land releases this should follow a sequential test, with urban areas first then Green Belt land in or on the edge of the Village before any major Green Belt releases.

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

Response: Mr Brown has land within the Village of Blackmore (see attached plan) which has an area suitable for small scale residential development (0.167 hectares). This site is promoted for sustainable housing and has road access and a footpath link direct into the heart of the village. The land reads as part of the village and adjoins other housing.

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?

Response: No response

Q5: Should the A12 Corridor accommodate growth by releasing sites on the edge of urban areas?

Response: No response

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

Response: Yes, as villages are tightly constrained by village development boundaries to achieve a balance of sustainable development it will be necessary to have both brownfield and greenfield releases of land within the Green Belt.

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?

Response: No response

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?

Response: No response

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

Response: No response

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

Response: No response

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? (See Page 29)

Response: No response

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

Response: No response

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

Response: There is a need to ensure that Villages are fully sustainable and therefore infrastructure needs to be provided in appropriate locations to support this objective. This will ensure that short term housing needs can be met in Villages as natural growth rather than long term large scale development.

We trust this will assist the Council in the preparation of its Local Plan. Should you have any queries or questions please contact Tony Collins at this office.

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