Question 2
Support
Strategic Growth Options
Representation ID: 5960
Received: 16/02/2015
Respondent: Steven Hooper
Yes. I agree with the issues and why I beleive area C A127 corridor is the best development choice.
see attached
Object
Strategic Growth Options
Representation ID: 5972
Received: 16/02/2015
Respondent: Mr George Nichols
No The issues have to be revisited as there are clear inconsistancies
see attached.
Object
Strategic Growth Options
Representation ID: 6054
Received: 16/02/2015
Respondent: Mrs Sandra Mate
No. Road and rail infrastructure in the A127 Corridor is already over capacity.
It is unclear why the A127 Corridor has greater potential for improvements than the A12. The A127 is tightly bounded in Southend and the London area where traffic is extremely heavy. There are also many areas where houses run all the way to the edge of the A127. Thus widening of the A127 is not necessarily easy. The A12 could potentially be expanded in a number of areas without material impact to the surrounding residential properties.
The consultation document implies that the A127 has greater development potential due to it having a "different landscape character". Whilst it does indeed have a different landscape character to say, the North of the Borough, the local residents' value of the open space and farmland should not be considered any lower than residents of the North of the Borough. The open, fenland landscape is valued extremely highly by local residents, and contributes to an open rural feel to this area and local settlements.
Flood risk is not addressed for any of the sites. It is clearly a major problem in the A127 Corridor and needs to be fully assessed before any development decision can be made.
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.
Support
Strategic Growth Options
Representation ID: 6064
Received: 17/02/2015
Respondent: SJ Walsh and Sons
Agent: JTS Partnership LLP
Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area is correct.
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.
Support
Strategic Growth Options
Representation ID: 6088
Received: 16/02/2015
Respondent: Dr. S.J. Jennings
Yes. So far as my knowledge goes.
see attached
Object
Strategic Growth Options
Representation ID: 6102
Received: 16/02/2015
Respondent: David Fairweather
This development will not create any additional job opportunities. Instead it
will blight an area of natural beauty and put more stress on already
overloaded local health related and educational services.
see attached
Support
Strategic Growth Options
Representation ID: 6117
Received: 17/02/2015
Respondent: Robert Mulholland & Co Ltd
Agent: JTS Partnership LLP
Yes.
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.
Comment
Strategic Growth Options
Representation ID: 6118
Received: 16/02/2015
Respondent: Janet Cowing
Yes. Will the council be able to provide further parking in central Brentwood and additional easing of traffic congestion into the town from the A12? Given the greater development capacity along the A127 - perhaps the council should concentrate the additional development and infrastructure requirements on those designated sites for schools housing retail and commercial as much is already in place and would encourage an easing of traffic as some would choose Basildon as a preferred shopping/commuter option to Brentwood, and there is perhaps more scope for "affordable" housing as a larger development will increase the number of affordable houses.
see attached.
Comment
Strategic Growth Options
Representation ID: 6146
Received: 16/02/2015
Respondent: Mrs Carol Holmes
Yes.
see attached.
Object
Strategic Growth Options
Representation ID: 6160
Received: 16/02/2015
Respondent: Mr and Mrs Paul McEwen
No. A12 option is described as a corridor development but is not running parallel to the major road at all. The sites cover areas a mile or two away from the A127 and would involve major green belt sites that must be protected.
see attached
Object
Strategic Growth Options
Representation ID: 6175
Received: 16/02/2015
Respondent: Mr Gregory Wayte
No. I agree with options 1 and 2 regarding centralised growth and transport but
not with options 3 and 4. The infrastructure in the North of the Borough
regarding transport and doctors services could not accommodate the
increase in growth.
see attached
Object
Strategic Growth Options
Representation ID: 6193
Received: 16/02/2015
Respondent: Chris Shepherd
No. The wording of these questions is very unclear and my responses seem
appropriate for many sections. Transport / Employment / Housing. The villages offer only the opportunity for one of these but taking this opportunity would wreck local life !
see attached
Support
Strategic Growth Options
Representation ID: 6216
Received: 17/02/2015
Respondent: Joy Fook Restaurant
Agent: JTS Partnership LLP
Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area is correct.
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.
Object
Strategic Growth Options
Representation ID: 6219
Received: 16/02/2015
Respondent: Mrs Elisabeth Taylor
I agree that transport and local facilities are not as good in the north of the borough, and local roads are very busy and could not cope with the increased volume of traffic. It does not take much for local roads to become gridlocked. There are very limited retail cetres, health centres, schools and public transport in this area.
see attached
Support
Strategic Growth Options
Representation ID: 6234
Received: 16/02/2015
Respondent: Mr Mike Fitch
Yes.
see attached
Support
Strategic Growth Options
Representation ID: 6274
Received: 17/02/2015
Respondent: Maylands Green Estate Co. Ltd
Agent: JTS Partnership LLP
Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area is correct.
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.
Comment
Strategic Growth Options
Representation ID: 6281
Received: 15/02/2015
Respondent: Mrs Janice Holbrook
Roads would need improvements along with public transport.
see attached
Support
Strategic Growth Options
Representation ID: 6299
Received: 15/02/2015
Respondent: Mr James Feeney
Yes
see attached
Object
Strategic Growth Options
Representation ID: 6313
Received: 15/02/2015
Respondent: Mr Gerry Jordan
Growth in the area does not require the levels of houses suggested and
certainly not by using green belt land.
see attached
Support
Strategic Growth Options
Representation ID: 6327
Received: 17/02/2015
Respondent: Mr Lee O'Connor
Agent: JTS Partnership LLP
Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area is correct.
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.
Object
Strategic Growth Options
Representation ID: 6333
Received: 15/02/2015
Respondent: Mr Mark Kelly
These areas are within Green Belt around London, purposefuly identified to prevent urban sprawl. If you accept that only nine percent of current UK land is built upon and Green Belt covers 13 percent of protected land, and that only an additional 2 percent of land needs to be built upon to cope with housing crisis, there is ample land to cope with demand.
Paragraphs 2.16 to 2.19 are bias in wording used to describe difference between A12 and A127 corridors which is unacceptable within such an important document. The use of but, would, only and the heavily weighted 2.19
See attached.
Support
Strategic Growth Options
Representation ID: 6354
Received: 17/02/2015
Respondent: Mr Tom Wells
Agent: JTS Partnership LLP
Yes - These representations concern the A127 Corridor and it is considered that the issues raised in relation to this area is correct.
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.
Object
Strategic Growth Options
Representation ID: 6375
Received: 15/02/2015
Respondent: C Zucconi
Road and rail infrastructure in the A127 corridor is already at capacity. It is unclear why the A127 corridor has greater potential for improvements than the A12. The A127 is tightly bounded by Southend and the London area where traffic is extremely heavy. There are also many areas where houses run all the way to the edge of the A127. As such widening of the A127 is not necessarily easy. The A12 could potentially be expanded in a number of areas without material impact to the surrounding residential properties. The consultation document also implies that the A127 has greater development potential due to it having a "different landscape character". Whilst it does indeed have a different landscape character to say, the north of the Borough, the local residents' value of the open space and farmland should not be considered any lower than residents of the North of the Borough. The open fenland landscape is valued extremely highly by all local residents and it contributes to an open rural feel to the area.
see attached
Comment
Strategic Growth Options
Representation ID: 6401
Received: 15/02/2015
Respondent: Mr Richard Reed
YEs The issues raised do highlight our concerns.
Because ill considered development will adversely affect existing communities
Support
Strategic Growth Options
Representation ID: 6422
Received: 15/02/2015
Respondent: Mr Anthony Nicholson
Yes
see attached
Object
Strategic Growth Options
Representation ID: 6440
Received: 15/02/2015
Respondent: Mrs Joyce Bunker
No. The information gathered should be reviewed as there are discrepancies.
see attached
Comment
Strategic Growth Options
Representation ID: 6462
Received: 15/02/2015
Respondent: Mrs Kim Lucas
Yes I do.
see attached
Support
Strategic Growth Options
Representation ID: 6479
Received: 15/02/2015
Respondent: Mrs Kathryn Hurford
Yes
see attached
Comment
Strategic Growth Options
Representation ID: 6494
Received: 15/02/2015
Respondent: Mr Stuart Moulder
Yes
see attached
Object
Strategic Growth Options
Representation ID: 6508
Received: 15/02/2015
Respondent: Mrs Alicia Clack
No.
see attached