I write in respect of your Strategic Growth Options Consultation

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

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

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

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

No for the following reasons:

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

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

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

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

Further comments on the broad divisions are:

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

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

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

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

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

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

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

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

In terms of the sites illustrated:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

We would have serious concerns about any encroachment on Green Belt land, (as shown
to the east/southeast of Brentwood in the Ingrave/Herongate areas). The area shown consists of
significant good quality farm land, and includes areas of historical interest and natural beauty.
The area to the south and west of Brentwood also incorporates Green Belt land designated as
part of the Thames Gateway project, which is intended to create a demarcation barrier between the
urban sprawl of London and the Essex countryside, so any possible developments on these Sites should
be confined to an absolute minimum and be very small scale.
The proposals also show that the villages of Ingrave and Herongate would lose their identity as they would become part of the urban sprawl of Brentwood.
In spite of the government proposal, we are both of the opinion that new, proposed developments be
confined to 'brownfield' Sites in the Brentwood area and that any building on Green Belt should be
strongly resisted.
Such necessary building sites should contain a reasonable element of affordable housing.
In noting the so called 'need' for Traveller Sites, we believe these should be resisted as many
of these 'so called' Travellers already have homes elsewhere in either this country or abroad.
Having been plagued by Travellers who have set up illegal sites on Common land close to where
we live, and where neighbours have been physically and verbally threatened by them, should sites be required then they should not be sited near people's homes. They could be located on brownfield sites rather than any Green Belt land.

Following a meting with the leader of the Council, The Navestock Parish Council would like to put up a sports pavilion on the land next to the Navestock Village Hall to enhance the 12 acres of sports land surrounding it. (football and cricket pitches). It would, amongst other things, be for indoor cricket , netball, football training and would be available for the people of Navestock and the Borough as a whole. The Navestock Parish Council is well aware that funding for both Borough and Parish Councils will be progressively cut and it is hoped that the sports barn will bring in much needed income and relieve a burden on the Borough by letting the Parish Council become self sufficient. The pavilion would be some 120x60 foot approx. Please can you consider this for inclusion in the Local Dev. Plan. If you require any more info. please don't hesitate to contact me.

COVERING LETTER:

I am instructed by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to submit representations upon the Strategic Growth Options Consultation version of the Brentwood Borough Local Plan. The representations relate to Land at Hook Farm, Hook End.

The representations include the following documents:-
1. Planning statement, prepared by RPS
2. Site location plan dated February 2015
3. Consultation questionnaire

You should note that the representations seek to remove Land at Hook End Farm, Hook End, from the Metropolitan Green Belt and propose that the site be allocated for housing. The reasons for the representation is set out in the enclosed planning statement.

PLANNING STATEMENT:

INTRODUCTION

This planning statement has been produced in support of a representation made by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to Brentwood Borough Council in February 2015. The representation is made in response to the Brentwood Borough Local Plan 2015-2030: Strategic Growth Options Consultation.
Mr M Sidwell, Mr J Bowler and Mrs J Alderton put forward land at Hook End Farm, Hook End, as a potential housing site. The merits of Land at Hook End Farm (representation site) for housing are addressed in this planning statement.
The representation site is located centrally within the village of Hook End. Hook End falls within the administrative district of Brentwood Borough Council and is approximately 8km from Brentwood town centre. The representation site is approximately 9 hectares (22 acres) and is currently in agricultural use, used for grazing.

The site is largely surrounded by existing residential development. The site is bounded by Hook End Lane to the west and Hook End Road to the south. Residential development adjoins the representation site to the north and to the east. Also to the west is Hook End Farm, which falls outside of the representation site.

The site does fall within the Metropolitan Green Belt. However, for reasons set out in this statement, there are very good reasons for removing the site from the Green Belt and allocating the site for housing.

HOUSING BACKGROUND

It is absolutely clear from the Borough Council's work to date on their emerging Local Plan that there is an issue in terms of finding enough land to meet housing requirements. Prior to issuing this Strategic Growth Options document, the Council produced a Preferred Options version of the draft Local Plan, in July 2013.

The Preferred Options version of the Local Plan was only able to identify sites to accommodate 3,500 new homes. This figure, and the apparent shortfall of housing, attracted objections from neighbouring authorities, namely Basildon Council, Chelmsford Council and Thurrock Council. The thrust of the objections being that the Preferred Options document did not propose to meet all of Brentwood's housing need, and that these adjoining authorities would not accept any shortfall from Brentwood Borough within their own boundaries.

Under such circumstances, it is known that Brentwood Borough Council recognise that there is a real prospect that the Local Plan would be likely to be found 'unsound' at a Local Plan Examination in Public. Indeed, the consequences of failure to meet full housing need has become clearly evident in decisions both from the Secretary of State and Planning Inspectors, in relation to specific housing proposals and also other Local Plan examinations. Notably, local plans that did not meet full housing needs have been found 'unsound' on the basis that they do not conform with the National Planning Policy Framework (NPPF). Accordingly, Brentwood Borough Council have taken the decision not to proceed to the pre-submission stage with the Preferred Options version of the Local Plan.

Rather, the Borough Council have now decided to proceed with this Strategic Growth Options Consultation document, to which this representation relates. The Strategic Growth Options document provides an overview of the main views to be considered as part of the Local Plan process.

The Strategic Growth Options document recognises a number of important points:-
* The NPPF sets out that local planning authorities should objectively assess their market and affordable housing needs and provide for that in full.
* The capacity of all brownfield sites within urban areas in the Borough could provide for a maximum of 2,500 new homes. That means any housing provision above this would need to consider use of Green Belt land.
* The Council has commissioned a study to identify objectively assessed housing needs for the Borough, which concludes a requirement to provide for around 360 new homes per year. Over 15 years that comes to around 5,500 homes, some 3,000 more than what can be provided from brownfield sites in urban areas.
* It is also important to consider the need for a more affordable housing.

Accordingly, in order to meet its housing requirements, Brentwood Borough Council must release Green Belt land for housing. This representation and the request to remove Land at Hook End Farm from the Green Belt, to be replaced by a housing allocation, is submitted within this context.

Indeed, the Strategic Growth Options document does contemplate the possibility of releasing sites to the north of the Borough, which is made up of a collection of villages, including Hook End. For example, paragraph 2.15 of the document states that it is important to consider allowing villages to grow in order to provide for local need. The same paragraph recognises that sites on the edge of villages could be released. Those points add further support to the release of a site such as the representation site.

MERITS OF LAND AT HOOK END FARM

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. These characteristics are set out below:-

a) Relationship to Built-Up Area

Unlike many other potential Green Belt/housing sites, Land at Hook End Farm is sandwiched between existing residential development. To the north is residential development on the roads of Hook End Lane/Nursery Road/First Avenue. To the east is the residential development on the roads of Hook End Road/Spring Pond Meadow. To the west is Hook End Farm.

As apparent from the site location plan (submitted with this representation), the representation site forms a logical infill between the existing parcels of development that form the village of Hook End. Consequently, the effects of residential development on the representation site will be to consolidate development in Hook End, so as to form a logical and clearly defined settlement.

To the south and west are Hook End Road and Hook End Lane respectively, which are the two principal roads within the village for Hook End. Bus stops are located close to the representation site providing regular services to Brentwood and the surrounding area.

b) Lack of Constraints

Unlike many Green Belt and greenfield sites, the representation site is unconstrained in planning terms. Apart from its position in the Metropolitan Green Belt, the representation site does not contain any prohibitive planning designations. Notably, the representation site is not within a conservation area, a special landscape area, a landscape improvement area, a County wildlife site, a site of special scientific interest or a local nature reserve. These designations apply to a number of sites within Brentwood Borough, outside the built-up area. Furthermore, the representation site is not within a flood zone and does not comprise either Grade I or Grade II agricultural land. On the issue of agricultural land, the representation site has been used for many years for the grazing of horses and therefore is of little value in terms of agricultural quality.

c) Size of Representation Site

At 9 hectares (22 acres), the representation site is reasonably large. At this size, the site is indeed large enough to accommodate well in excess of 100 houses, which can make a meaningful contribution to the Borough's housing requirement. Furthermore, the site is large enough to accommodate other development that may be beneficial to residents of the village. For example, if necessary, it would be possible to accommodate some local shops, areas of open space and other community facilities, albeit such matters would need to be discussed with local residents, the Parish Council and other local groups. Additionally, the site could accommodate a range of house types, including affordable housing.

Accordingly, the release of Green Belt land in this case can bring forward significant benefits, unlike the release of much smaller sites.

d) Availability and Deliverability

The representation site is in the ownership of the three parties making this representation, with additional interests held by other family members. All parties fully support this representation and are content to promote the site for residential development. Furthermore, there are no physical or practical constraints in bringing forward development on this site. Accordingly, the site is available and deliverable and is able to make a significant contribution to meeting the Borough Council's housing requirements, in the short term, if necessary.

GREEN BELT CONSIDERATIONS

The Government's policy on Green Belt is contained in the National Planning Policy Framework (NPPF). Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances, but that any alteration of boundaries should be undertaken through the preparation or review of the local plan. In this case, the need to meet housing requirements is such an exceptional circumstance, which will be addressed through this review of the Brentwood Local Plan.

Importantly, paragraph 80 of the NPPF states that the Green Belt serves five purposes, which are as follows:-
* To check the unrestricted 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 representation site is considered against each of these purposes:-
i) The representation site is an infill site, bringing together two residential areas which form the village of Hook End. Development will not extend the limit of the existing built up area. Consequently, development on the representation site will not have the affect of creating 'sprawl'. In any event, the settlements of Hook End and neighbouring villages do not constitute 'large built-up areas.'
ii) For the reasons set out in (i) above, development on the representation will not have any effect in terms of encouraging the merging of neighbouring towns. Rather, the effect is to join two separate parts of the village.
iii) By the nature of the representation site in relation to the existing built-up area, development will not constitute 'encroachment' in to the countryside.
iv) There are no historic towns nearby and therefore this purpose has no relevance
v) It is clear from work undertaken by the Borough Council that there is not sufficient derelict and other urban land available to meet housing requirements. Consequently, Green Belt land needs to be released for housing and therefore protecting Green Belt sites will not have the desired effect of encouraging the recycling of derelict and other urban land.

Accordingly, it is clear that the representation site does not fulfil any of the five Green Belt purposes. For this reason alone, the representation site has merit and should be considered favourably as a potential housing site.

In addition to the five purposes of Green Belt, paragraph 85 of the NPPF, amongst other points, advises that local planning authorities should define the boundaries of the Green Belt, using physical features that are readily recognisable and likely to be permanent. On the basis of the site's relationship to the built-up area, development will enable a more logical Green Belt boundary to be drawn, which more probably recognises the features of the village.

SUMMARY AND CONCLUSIONS

The representation site is Land at Hook End Farm, Hook End. The representation site is located centrally within the village of Hook End, being largely surrounded by existing residential development. The site falls with the Metropolitan Green Belt.

Brentwood Borough Council have a shortfall of housing in relation to objectively assessed needs. In order to meet this shortfall, the emerging Local Plan recognises that Green Belt land needs to be used. One of the options considered is utilising sites on the edge of villages.

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. It is well related to the built up area, it is unconstrained in planning terms, it is available and deliverable, plus it is large enough to make a meaningful contribution to meeting housing need and in addition provide other facilities to the benefit of the community.

The representation site does not fulfil any of the five Green Belt purposes, as set out in the NPPF. Rather, on the basis of the site's relationship to the built up area, development will enable a more logical Green Belt boundary to be drawn.

In conclusion, the site is of little value in Green Belt terms and can more effectively be used for housing, assisting the Borough Council in meeting housing requirements.

COVERING LETTER:

I am instructed by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to submit representations upon the Strategic Growth Options Consultation version of the Brentwood Borough Local Plan. The representations relate to Land at Hook Farm, Hook End.

The representations include the following documents:-
1. Planning statement, prepared by RPS
2. Site location plan dated February 2015
3. Consultation questionnaire

You should note that the representations seek to remove Land at Hook End Farm, Hook End, from the Metropolitan Green Belt and propose that the site be allocated for housing. The reasons for the representation is set out in the enclosed planning statement.

PLANNING STATEMENT:

INTRODUCTION

This planning statement has been produced in support of a representation made by Mr M Sidwell, Mr J Bowler and Mrs J Alderton to Brentwood Borough Council in February 2015. The representation is made in response to the Brentwood Borough Local Plan 2015-2030: Strategic Growth Options Consultation.
Mr M Sidwell, Mr J Bowler and Mrs J Alderton put forward land at Hook End Farm, Hook End, as a potential housing site. The merits of Land at Hook End Farm (representation site) for housing are addressed in this planning statement.
The representation site is located centrally within the village of Hook End. Hook End falls within the administrative district of Brentwood Borough Council and is approximately 8km from Brentwood town centre. The representation site is approximately 9 hectares (22 acres) and is currently in agricultural use, used for grazing.

The site is largely surrounded by existing residential development. The site is bounded by Hook End Lane to the west and Hook End Road to the south. Residential development adjoins the representation site to the north and to the east. Also to the west is Hook End Farm, which falls outside of the representation site.

The site does fall within the Metropolitan Green Belt. However, for reasons set out in this statement, there are very good reasons for removing the site from the Green Belt and allocating the site for housing.

HOUSING BACKGROUND

It is absolutely clear from the Borough Council's work to date on their emerging Local Plan that there is an issue in terms of finding enough land to meet housing requirements. Prior to issuing this Strategic Growth Options document, the Council produced a Preferred Options version of the draft Local Plan, in July 2013.

The Preferred Options version of the Local Plan was only able to identify sites to accommodate 3,500 new homes. This figure, and the apparent shortfall of housing, attracted objections from neighbouring authorities, namely Basildon Council, Chelmsford Council and Thurrock Council. The thrust of the objections being that the Preferred Options document did not propose to meet all of Brentwood's housing need, and that these adjoining authorities would not accept any shortfall from Brentwood Borough within their own boundaries.

Under such circumstances, it is known that Brentwood Borough Council recognise that there is a real prospect that the Local Plan would be likely to be found 'unsound' at a Local Plan Examination in Public. Indeed, the consequences of failure to meet full housing need has become clearly evident in decisions both from the Secretary of State and Planning Inspectors, in relation to specific housing proposals and also other Local Plan examinations. Notably, local plans that did not meet full housing needs have been found 'unsound' on the basis that they do not conform with the National Planning Policy Framework (NPPF). Accordingly, Brentwood Borough Council have taken the decision not to proceed to the pre-submission stage with the Preferred Options version of the Local Plan.

Rather, the Borough Council have now decided to proceed with this Strategic Growth Options Consultation document, to which this representation relates. The Strategic Growth Options document provides an overview of the main views to be considered as part of the Local Plan process.

The Strategic Growth Options document recognises a number of important points:-
* The NPPF sets out that local planning authorities should objectively assess their market and affordable housing needs and provide for that in full.
* The capacity of all brownfield sites within urban areas in the Borough could provide for a maximum of 2,500 new homes. That means any housing provision above this would need to consider use of Green Belt land.
* The Council has commissioned a study to identify objectively assessed housing needs for the Borough, which concludes a requirement to provide for around 360 new homes per year. Over 15 years that comes to around 5,500 homes, some 3,000 more than what can be provided from brownfield sites in urban areas.
* It is also important to consider the need for a more affordable housing.

Accordingly, in order to meet its housing requirements, Brentwood Borough Council must release Green Belt land for housing. This representation and the request to remove Land at Hook End Farm from the Green Belt, to be replaced by a housing allocation, is submitted within this context.

Indeed, the Strategic Growth Options document does contemplate the possibility of releasing sites to the north of the Borough, which is made up of a collection of villages, including Hook End. For example, paragraph 2.15 of the document states that it is important to consider allowing villages to grow in order to provide for local need. The same paragraph recognises that sites on the edge of villages could be released. Those points add further support to the release of a site such as the representation site.

MERITS OF LAND AT HOOK END FARM

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. These characteristics are set out below:-

a) Relationship to Built-Up Area

Unlike many other potential Green Belt/housing sites, Land at Hook End Farm is sandwiched between existing residential development. To the north is residential development on the roads of Hook End Lane/Nursery Road/First Avenue. To the east is the residential development on the roads of Hook End Road/Spring Pond Meadow. To the west is Hook End Farm.

As apparent from the site location plan (submitted with this representation), the representation site forms a logical infill between the existing parcels of development that form the village of Hook End. Consequently, the effects of residential development on the representation site will be to consolidate development in Hook End, so as to form a logical and clearly defined settlement.

To the south and west are Hook End Road and Hook End Lane respectively, which are the two principal roads within the village for Hook End. Bus stops are located close to the representation site providing regular services to Brentwood and the surrounding area.

b) Lack of Constraints

Unlike many Green Belt and greenfield sites, the representation site is unconstrained in planning terms. Apart from its position in the Metropolitan Green Belt, the representation site does not contain any prohibitive planning designations. Notably, the representation site is not within a conservation area, a special landscape area, a landscape improvement area, a County wildlife site, a site of special scientific interest or a local nature reserve. These designations apply to a number of sites within Brentwood Borough, outside the built-up area. Furthermore, the representation site is not within a flood zone and does not comprise either Grade I or Grade II agricultural land. On the issue of agricultural land, the representation site has been used for many years for the grazing of horses and therefore is of little value in terms of agricultural quality.

c) Size of Representation Site

At 9 hectares (22 acres), the representation site is reasonably large. At this size, the site is indeed large enough to accommodate well in excess of 100 houses, which can make a meaningful contribution to the Borough's housing requirement. Furthermore, the site is large enough to accommodate other development that may be beneficial to residents of the village. For example, if necessary, it would be possible to accommodate some local shops, areas of open space and other community facilities, albeit such matters would need to be discussed with local residents, the Parish Council and other local groups. Additionally, the site could accommodate a range of house types, including affordable housing.

Accordingly, the release of Green Belt land in this case can bring forward significant benefits, unlike the release of much smaller sites.

d) Availability and Deliverability

The representation site is in the ownership of the three parties making this representation, with additional interests held by other family members. All parties fully support this representation and are content to promote the site for residential development. Furthermore, there are no physical or practical constraints in bringing forward development on this site. Accordingly, the site is available and deliverable and is able to make a significant contribution to meeting the Borough Council's housing requirements, in the short term, if necessary.

GREEN BELT CONSIDERATIONS

The Government's policy on Green Belt is contained in the National Planning Policy Framework (NPPF). Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances, but that any alteration of boundaries should be undertaken through the preparation or review of the local plan. In this case, the need to meet housing requirements is such an exceptional circumstance, which will be addressed through this review of the Brentwood Local Plan.

Importantly, paragraph 80 of the NPPF states that the Green Belt serves five purposes, which are as follows:-
* To check the unrestricted 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 representation site is considered against each of these purposes:-
i) The representation site is an infill site, bringing together two residential areas which form the village of Hook End. Development will not extend the limit of the existing built up area. Consequently, development on the representation site will not have the affect of creating 'sprawl'. In any event, the settlements of Hook End and neighbouring villages do not constitute 'large built-up areas.'
ii) For the reasons set out in (i) above, development on the representation will not have any effect in terms of encouraging the merging of neighbouring towns. Rather, the effect is to join two separate parts of the village.
iii) By the nature of the representation site in relation to the existing built-up area, development will not constitute 'encroachment' in to the countryside.
iv) There are no historic towns nearby and therefore this purpose has no relevance
v) It is clear from work undertaken by the Borough Council that there is not sufficient derelict and other urban land available to meet housing requirements. Consequently, Green Belt land needs to be released for housing and therefore protecting Green Belt sites will not have the desired effect of encouraging the recycling of derelict and other urban land.

Accordingly, it is clear that the representation site does not fulfil any of the five Green Belt purposes. For this reason alone, the representation site has merit and should be considered favourably as a potential housing site.

In addition to the five purposes of Green Belt, paragraph 85 of the NPPF, amongst other points, advises that local planning authorities should define the boundaries of the Green Belt, using physical features that are readily recognisable and likely to be permanent. On the basis of the site's relationship to the built-up area, development will enable a more logical Green Belt boundary to be drawn, which more probably recognises the features of the village.

SUMMARY AND CONCLUSIONS

The representation site is Land at Hook End Farm, Hook End. The representation site is located centrally within the village of Hook End, being largely surrounded by existing residential development. The site falls with the Metropolitan Green Belt.

Brentwood Borough Council have a shortfall of housing in relation to objectively assessed needs. In order to meet this shortfall, the emerging Local Plan recognises that Green Belt land needs to be used. One of the options considered is utilising sites on the edge of villages.

The representation site benefits from a number of characteristics which make it particularly suitable as a site for housing. It is well related to the built up area, it is unconstrained in planning terms, it is available and deliverable, plus it is large enough to make a meaningful contribution to meeting housing need and in addition provide other facilities to the benefit of the community.

The representation site does not fulfil any of the five Green Belt purposes, as set out in the NPPF. Rather, on the basis of the site's relationship to the built up area, development will enable a more logical Green Belt boundary to be drawn.

In conclusion, the site is of little value in Green Belt terms and can more effectively be used for housing, assisting the Borough Council in meeting housing requirements.

ALTERNATIVE SITE SUBMISSION

Site boundary submitted for Ashwells Cottages, Pilgrims Hatch.

ALTERNATIVE SITE SUBMISSIONS

Submission 1:
We would like to submit our site for development as part of the Local Plan Process.

Site map enclosed.

EHS Metals also 141, 139, 147, 149 Telex Ex.

It is used as scrapyard also property numbers above for housing.

Submission 2:
We would like to submit our site for development as part of the local planning process.

Site Map enclosed.

Land rear of 109 Roman Road, Mountnessing for housing.

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It has come to my attention that there is a proposed development of land at end of Peartree Lane and Lime Grove of up to 50 dwellings under the council's strategic growth plan.
Firstly I want to vent my anger that this proposed development was bought to my attention by a neighbour and not Brentwood Council, considering this has I believe been planned since 2013 without any consultation to immediate neighbours who will be considerably impacted.

I wish to make you aware of a number of strong objections that I have with regard to the proposed development of additional properties to the land at end of Peartree Lane and Lime Grove. As an immediate neighbour to the site of the proposed development, we are of the view that the proposed development will have a serious impact on our standard of living. Our specific objections are as follows:

I would like to oppose the development of this site on the below factors:-


1) I will no longer be able to let my children play out as their safety will be compromised , firstly due to the building work that these dwellings will entail along with lorries and diggers etc. and then once building have been completed and houses inhabitated , there will be faster and more traffic to get to the new development. The proposal would demonstrably harm the amenities enjoyed by local residents, in particular safe and available on-road parking , valuable green space , privacy, and the right to enjoy a quiet and safe residential environment.

2) Lime Grove is a narrow road and parking is already an issue, with all new housing developments the key is to put as many houses onto an one area as possible and thus compromising on parking allocations , this I would imagine these new dwellings cars parking leaking into Lime Grove and Peartree Lane. Insufficient parking space will adversely affect the amenity of surrounding properties through roadside parking on this narrow road.

3) It would also put more strain on the Doctors surgery, which at present is difficult to get an appointment when needed.

4) Doddinghurst Infants and Junior school is a wonderful little Village school, but at present my 2 children's classes have 30 children which is the maximum, where would all these new children go?

5) I would also like to know what kind of housing is being proposed - Is it private builder or social housing.

I do hope that all the objections will be taken seriously and we as residents will be kept up to date with all progress on this issue.

I'm emailing you say that I object to Brentwood's Strategic growth options Consultation.

I am fearing that this would have a huge negative on the current surroundings. The schools will not be able to deal with the amount of extra space needed and likewise all other services ie doctors, dentists etc. This will also create congestion a through what at the moment can be congested enough at peak times and obviously destroying our greenbelt.

I hugely object

I object to Brentwoods Strategic
Growth Options Consultation for the following reasons

1. The greenbelt was set
up by better planners and politicians than you so as to enable food supply and retain our wonderful countryside. I object to you and greedy land owners and developers trashing this wonderful legacy.

2. Unless you fly in by helicopter,
and dont look down, you cannot help but notice that the A127 and surrounding road network are becoming more and more congested. Building on greenbelt will further exacerbate this existing problem and seriously and adversely affect mine and other local peoples quality of life.

3. We dont need all this
housing. If your Govt didnt allow millions of newcomers into the UK in recent years there would be no demand for this housing. The Conservatives and many of their party donors clamour for growth when it is in fact artificial and a way of making money for landowners and the buy to let market at the expense of local populations.

I object to building on any greenbelt as it is designated today.

I object to Brentwoods Strategic
Growth Options Consultation for the following reasons

1. The greenbelt was set
up by better planners and politicians than you so as to enable food supply and retain our wonderful countryside. I object to you and greedy land owners and developers trashing this wonderful legacy.

2. Unless you fly in by helicopter,
and dont look down, you cannot help but notice that the A127 and surrounding road network are becoming more and more congested. Building on greenbelt will further exacerbate this existing problem and seriously and adversely affect mine and other local peoples quality of life.

3. We dont need all this
housing. If your Govt didnt allow millions of newcomers into the UK in recent years there would be no demand for this housing. The Conservatives and many of their party donors clamour for growth when it is in fact artificial and a way of making money for landowners and the buy to let market at the expense of local populations.

I object to building on any greenbelt as it is designated today.

I object to the above plan to build on green belt land AND prime farming land on the grounds that this will ruin Old Brentwood and Shenfield. Our green areas should be preserved for next generations PLUS should the economic situations abroad change , this country will not be able to feed itself once we build on our farmland.

We object to the development on Plot 143 Land East of peartree lane & North of peartree close.

The shear weight of traffic will all travel through Peartree Lane as Lime Grove is much nearer & is already congested & troublesome to travel through on a daily basis.
I noticed,particularly in the last five years a deterioration in the fabric of our countryside.
Cuts in services everywhere, even to the extent of disposing of essential services such as vermin control.
We are witnessing the destruction of our countryside by Politicians and Councillors who ignore the views of the people they are supposed to serve. How many accidents have been caused by turning street lights off, it may not be what central and local Politicians want to hear but there has been an increase in the number of suicides due to Government and Local Authority policies. If you want to rely on consultants and advisers,recents reports to Government have warned against development or buildings on main roads ,because of pollution levels,particularly affected are children and the elderly and of course adults with underlying conditions........in fact most citizens!.

Green belt land, as far as I am concerned is sacrosanct, and I want my grandchildren to be able to enjoy the open countryside, as I have been able to. My property will be available to them when I and my wife die, and they can then take the walks that I enjoy today, in green belt land. It matters not what the land was like when my property was built, it was in the 1950's and the rules that were in place then, applied.

In addition I was told by a Brentwood Cllr that there is Brownfield sites available in Brentwood for 2500-3000 homes! Basildon Council has Brownfield sites for 6000 homes so we must ask ourselves the question if this Dunton Suburb is needed or fair.

Tracey ~ isn't Brownfield an alternative solution? Basildon could accommodate 6000 homes on brownfield & Brentwood 3000 - this was told to me by a Brentwood Cllr! I am very concerned that the children & grandchildren you mention will know no green... and the Urban sprawl will engulf us - as Government expand the London boundary. There has been some Echo coverage - but were you aware this plan has been around for a year? I certainly was not and I live a mile from the proposed boundary. The residents of the semi-rural villages have made a choice to live in those particular surroundings and all it brings to them. With respect, would you want someone to pitch a tent in your garden because they could?

Brownfield sites more preferable for development: Fords at Dagenham, West Thurrock generally where industries have ceased, Fords at South Ockendon, Aveley Bypass. Vast acreage, all in Essex.

I attended the public meeting when two Council representatives came to Herongate to answer questions.
The questions I asked were:-
additional Rail and Bus provision......no plan!
Where will the Hospital be?.......what Hospital.?..
okay ;Clinic then,?......what Clinic.?...
okay Doctor's surgery.?...what surgery?
Police Station?...what Police Station?..
Schools?...what schools
Fire Station?.......doh!
They could not answer any questions on infrastructure.

Common sense will tell you all these services will be essential,but for the civil servants who have produced this plan the only certainty is the devastating development will include accommodation for travellers.....

I only yesterday received notification by delivery of a newsletter produced by the local parish council of the above, having received no communication from Brentwood council.

Having read the paper, the following obversations should be noted

Traffic congestion along the A128 has deteriorated considerably over recent years & whilst reference is made to the A127, A12 & M25; there doesn't appear to be any reference to A128, which already seems at full capacity & therefore developments to this part of Brentwood should be limited.

Whilst reference is made to Brentwood enjoying the 6th highest total area of Green belt in the country, this is something that should be applauded & protected for future generations.

It appears that a large number of residents commute to London to work. Therefore,, brown field sites & change of use from commercial to residential should take priority over development on both agricultural & green belt.

We moved to Herongate to enjoy village life & the use of two beautiful country parks. It seems that the proposed plans will move Brentwood one step nearer to becoming part of Greater London.

I only yesterday received notification by delivery of a newsletter produced by the local parish council of the above, having received no communication from Brentwood council.

Having read the paper, the following obversations should be noted

Traffic congestion along the A128 has deteriorated considerably over recent years & whilst reference is made to the A127, A12 & M25; there doesn't appear to be any reference to A128, which already seems at full capacity & therefore developments to this part of Brentwood should be limited.

Whilst reference is made to Brentwood enjoying the 6th highest total area of Green belt in the country, this is something that should be applauded & protected for future generations.

It appears that a large number of residents commute to London to work. Therefore,, brown field sites & change of use from commercial to residential should take priority over development on both agricultural & green belt.

We moved to Herongate to enjoy village life & the use of two beautiful country parks. It seems that the proposed plans will move Brentwood one step nearer to becoming part of Greater London.

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Thank you for the opportunity to comment on the strategic growth options.

Please find attached RAG sheet summarising Anglian Water's initial thoughts on the sites included in Appendix 1:'List of Suggested Sites'. It should be noted each site is assessed individually and the collective impact of sites on the Water Recycling Centre ( previously referred to as Sewage Treatment Works or Wastewater Treatment) or the foul sewerage network for sites in the same catchment has not been assessed.

Encroachment

It is noted sites 028b,30,34,36,38b,107,173,179,183,192 and 215 all have pumping stations on site or close by. A 15 metre distance between the boundary of the pumping station and the curtilage of any new dwelling should be maintained in order to reduce the risk of nuisance or loss of amenity. The design layout should take this into account.

Surface Water disposal
All developments should adhere to the drainage hierarchy and utilise sustainable drainage systems (SUDS) as much as possible. Disposal to the public surface water piped network should be seen as a last resort. Under no circumstances will surface water be accepted into the foul sewerage network. It is noted that Brentwood propose to develop around 2500 dwellings on brownfield sites and this could be an opportunity to reduce the overall flood risk in Brentwood through re-development by applying the same design standards on developments on previously developed sites as undeveloped sites. Evidence that the developments had followed the surface water management hierarchy will help to ensure infiltration is considered ahead of maintaining connection to sewers. Early engagement is key to ensuring adequate surface water management measures are included.


Pre development service
We offer a pre development service to developers and would encourage the prospective developer to contact us at the earliest opportunity to discuss drainage requirements to serve their proposal. Details including application form can be found at:

http://www.anglianwater.co.uk/developers/planning/

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