Question 13

Showing comments and forms 91 to 120 of 493

Comment

Strategic Growth Options

Representation ID: 5347

Received: 17/02/2015

Respondent: Mr. Christopher Burrow

Representation Summary:

The need for infrastructure is required mainly on maintaining roads and improving the safety for cyclists especially in rural areas - cycle paths/bridal paths would be a good addition with impacting on the environment.

Full text:

See attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 5369

Received: 02/02/2015

Respondent: Mrs Christine Rogers

Representation Summary:

Road layout/maintenance
Hospital/walk in centre
Street Lighting

Full text:

See attached consultation questionnaire.

From Letter dated 2/2/15:
I am both appalled and saddened by the proposed development of the above and strongly oppose these plans.

My association with Hopefield Sanctuary goes back to its beginning as its Founders, the late Paula and Ernie Clark were very dear friends.

I have witnessed the continuing struggle faced by this couple as they fought to keep the sanctuary going, but owing to their physical and mental dedication they left this wonderful legacy not only for the people of Brentwood, but also for many others from near and far to enjoy.

As I am sure you are aware, Hopefield has progressed from its modest beginnings. It is now a remarkable place for both young and old to visit and enjoy whether for recreational or educational purposes.

David Schlaich and Lianne Angliss as managers have worked tirelessly in order to bring about the amazing improvements from which both visitors and the considerably increased numbers of animals, birds and reptiles benefit. I would describe this couple as an inspiration to young people everywhere.

There are many other sites which would be suitable options and I urge you to seriously consider these.

From letter dated 13/2/15

I would refer to the attached letters relating to the above.

I cannot emphasise enough that any building on these green spaces would have any adverse effect on all local residents, many of which, including myself are retired.

The area is regularly used and enjoyed by walkers both with and without dogs. It is vital that the local community does not lose such a valuable asset.

Site Ref: 011a
SHLAA Ref: B025

In October 2013 I was one of many who objected to the proposed building of houses on the above site.

I am now once again stating that this idea should never be considered.
Hullets Farm is Grade II Listed with its curtilage buildings which butt up to the rear gardens of bungalows nos 10-20 Orchard Lane. These curtilage buildings cannot be demolished in order to gain access to the paddock which is Green Belt not Brown Belt.

This area should remain Green Belt.

Site 011B
SHLAA Ref: 6038

I strongly object to any planned development reference the above.

This land is scrubland and nearly always flooded.

It has an abundance of wildlife including some protected species, e.g. Great Crested Newts.

This area should remain Green Belt.

Site Ref: 011C
SHLAA Ref: GO38

This area is definitely Green Belt and must remain so.

Proposed development was unsuccessful in 2009/10 and certainly should not be considered now.

This land supports a variety of wildlife including Badger sets.

Site ref: 0176

This land has a natural spring in it therefore it is almost always flooded.
Access is a huge problem and is adjacent to Gents Farm which is Grade II Listed with its curtilage buildings.

This area should remain Green Belt.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5371

Received: 23/02/2015

Respondent: Mr Richard Sutton

Representation Summary:

Dont know at the moment at this stage in time.

Full text:

See attached.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5389

Received: 23/02/2015

Respondent: Mrs Rita Tuffey

Representation Summary:

My main local spending priorities would be:
better drainage & ditch clearance programmes to alleviate flooding.
improved & regular hedge verge cutting on local roads/country lane junctions, to restore visibility and safety.

Full text:

See attached.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5403

Received: 23/02/2015

Respondent: Mr Ian Tuffey

Representation Summary:

Improved road surfaces, regular ditch cleaning & electrical cable to be dug into the ground to avoid disruption to power supplies.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5454

Received: 09/02/2015

Respondent: Mr Ian Blackburn

Representation Summary:

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.

Full text:

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.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5578

Received: 25/02/2015

Respondent: Jane McCarthy

Representation Summary:

Housing along the A127 - West Horndon way would benefit by becoming a larger community as it has the space and land and would add to the area if it was attractive - hence the infrastructure in this area for education, healthcare, community and transport links could be done with a clean sheet masking sure it fits in without upsetting established areas.

Full text:

See attached document

Attachments:

Comment

Strategic Growth Options

Representation ID: 5579

Received: 25/02/2015

Respondent: Jane McCarthy

Representation Summary:

Cycling lanes to the stations (Brentwood and Shenfield would be good as this would free up traffic as well).

Full text:

See attached document

Attachments:

Comment

Strategic Growth Options

Representation ID: 5580

Received: 25/02/2015

Respondent: Jane McCarthy

Representation Summary:

Make the town centre attractive with good big name and independent shops to make people want to go there.

Full text:

See attached document

Attachments:

Comment

Strategic Growth Options

Representation ID: 5599

Received: 13/02/2015

Respondent: Sow & Grow Nursery

Agent: MR ALAN WIPPERMAN

Representation Summary:

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

Full text:

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

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

CONSULTATION QUESTIONNAIRE

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

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

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

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

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

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

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

Q8: Yes - No further comment.

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

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

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

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

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

CONSULTATION QUESTIONNAIRE ADDITIONAL INFORMATION

BACKGROUND.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

COMMENTS ON SITES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Strategic Growth Options

Representation ID: 5656

Received: 13/02/2015

Respondent: Ms Maxine Armiger

Agent: MR ALAN WIPPERMAN

Representation Summary:

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

Full text:

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

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

CONSULTATION QUESTIONNAIRE

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

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

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

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

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

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

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

Q8: Yes - No further comment.

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

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

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

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

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

CONSULTATION QUESTIONNAIRE ADDITIONAL INFORMATION

BACKGROUND.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

COMMENTS ON SITES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Strategic Growth Options

Representation ID: 5715

Received: 13/02/2015

Respondent: Sow & Grow Nursery

Agent: MR ALAN WIPPERMAN

Representation Summary:

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

Full text:

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

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

CONSULTATION QUESTIONNAIRE

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

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

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

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

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

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

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

Q8: Yes - No further comment.

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

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

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

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

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

CONSULTATION QUESTIONNAIRE ADDITIONAL INFORMATION

BACKGROUND.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

COMMENTS ON SITES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Strategic Growth Options

Representation ID: 5721

Received: 16/02/2015

Respondent: Mr & Mrs Crane

Number of people: 2

Representation Summary:

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.....

Full text:

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.....

Comment

Strategic Growth Options

Representation ID: 5814

Received: 17/02/2015

Respondent: East and West Horndon Environment Group

Number of people: 2

Agent: Mrs. Patricia Buckmaster

Representation Summary:

Given the scale of the proposed development within the A127 corridor whilst there will be priorities, the development will require infrastructure spending across all categories: education, health, transport, green space and community facilities.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 5826

Received: 10/02/2015

Respondent: Historic England

Representation Summary:

No comment

Full text:

Dear Sir or Madam
Brentwood Strategic Growth Options Consultation (January 2015)
Thank you for your letter dated 5 January consulting English Heritage on the
above document. We would like to make the following comments
Q1: Do you agree with the three broad areas for the purposes of
considering approaches to growth?
We do not have a strong view on the division of the borough into three broad
areas, which we recognise is to help consider growth options. As paragraph
2.13 notes, each of the areas should not be considered in isolation. In the
case of the historic environment, specific heritage assets might be shared
between more than one area (e.g. Thorndon Hall Registered Park and
Garden), and so could be impacted on by growth proposals in each area.
Q2: Do you agree with the issues raised for each of these three areas?
We broadly agree with the issues raised for each area in paragraphs 2.14 to
2.19. The historic environment forms an important part of the issues and
options for each area in terms of where to potentially locate new development.
This includes designated heritage assets but also non-designated assets such
as sites of archaeological interest. We would expect proper assessment of the
historic environment and potential impacts when making decisions about
where to locate development.

Q3: Do you have any comments on the appropriateness of particular
sites?
Due to time and resource constraints we have not been able to assess every
site in great detail. Our comments on the sites have been based mainly on
desk-top analysis, and we have not been able to judge the potential impacts
more accurately on the ground. Even with the strategic sites, we have only
been able to carry out rapid site visits in limited cases and have not had the
opportunity to ascertain precise impacts. We have focussed on those sites
with the potential for the greatest historic environment impact. This does not mean there are no issues with any other site and we reserve the right to
comment further on any site as and when proposals develop.
Please note that we have not considered areas of archaeological interest
beyond scheduled monuments in most cases, nor have we looked at historic
landscape issues beyond registered historic parks & gardens. However,
wider archaeological and landscape impacts are important considerations and
need to be factored into site assessment. The possible cumulative impact of
a number of site allocations in one location could cause significant harm to the
historic environment. Advice from conservation and archaeological staff at
borough and county levels should be sought, along with consultation of the
County Historic Environment Record (HER) for specific heritage assets.
In terms of site assessments in relation to heritage assets, care should be
taken to avoid merely limiting assessment of impact on a heritage asset to its
distance from, or intervisibility with, a potential site. Site allocations which
include a heritage asset (for example a site within a Conservation Area) may
offer opportunities for enhancement and tackling heritage at risk, while
conversely, an allocation at a considerable distance away from a heritage
asset may cause harm to its significance, rendering the site unsuitable.
The following broad steps might be of assistance in terms of assessing sites:
* Identify the heritage assets on or within the vicinity of the potential site
allocation at an appropriate scale
* Assess the contribution of the site to the significance of heritage assets
on or within its vicinity
* Identify the potential impacts of development upon the significance of
heritage asset
* Consider how any harm might be removed or reduced, including
reasonable alternatives sites * Consider how any enhancements could be achieved and maximised
* Consider and set out the public benefits where harm cannot be
removed or reduced
Q4: Which of the sites along the A127 Corridor is the best location for
growth?
The document notes the potential for larger growth opportunities in the A127
corridor, with a residential-led mixed used allocation at West Horndon or a
cross boundary development at Dunton (English Heritage has responded
separately to the Dunton Garden Suburb consultation). The consultation
suggests that development would only occur at either West Horndon or
Dunton, but in the event that both are pursued, we would have reservations
about the cumulative impact and extent of urbanisation along the A127
corridor, which could harm various heritage assets. We would expect in such
a scenario for an adequate buffer between West Horndon and Dunton and
important heritage assets.
Within West Horndon site 038B includes the southern limits of the Thorndon
Hall Registered Park and Garden (Grade II* listed) and Thorndon Park
Conservation Area. This southerly projection is separated from the main Park
and Garden and conservation area by the A127, but the issue of severance must have been considered at the time of designation (in 1987 and 1993
respectively). Housing development on the designated area would result in
harm to its character and appearance, and development abutting its
boundaries might also result in a degree of harm.
On site 162 at Little Warley there is a proposal for an elderly care facility. This
site abuts Little Warely Hall, which dates from the early 16th century and is
listed at Grade II*, together with the Church of St Peter, which dates from the
15th and 17th centuries and is listed at Grade I. Development of an elderly
care facility on this site is likely to adversely impact on the setting of both
these highly graded heritage assets. Sites 058A and 058B on the east side of
Little Warely Hall Lane are also in close proximity to these assets, but well
designed and appropriately scaled housing may be less harmful compared to
the current recycling and HGV operations on site 058A.
Q5: Should the A12 Corridor accommodate growth by releasing sites on
the edge of urban areas?
The report notes that brownfield land within the urban areas might be
efficiently developed in order to minimise pressure on Green Belt releases.
English Heritage broadly agrees with this approach, though we note that a
number of brownfield sites are in close proximity to designated heritage
assets and the design of any developments would need to have special
regard to the setting of these assets.
In terms of releasing sites on the edge of urban areas, this again depends on
the exact location in terms of impact on the historic environment. Very
significant areas of green belt land to the east and southeast of Hutton/east of
Ingrave and Herongate is included in the report and much of this land has
implications for a large number of heritage assets. The Sustainability
Appraisal seems to underplay the impact of this location on the historic
environment, ranking it third out of five potential options for strategic growth.
We would argue that it ranks lower than that. On the extreme eastern edge of Hutton is the Hutton village conservation
area. This conservation area has an open rural setting apart from where it
abuts existing housing on the northern half of its western boundary, and
includes Hutton Hall (Grade II* listed) and the 14th century Church of All Saints
(Grade II* listed) plus a number of other buildings listed at Grade II. The
conservation area also includes areas of open land that make a positive
contribution to its character and appearance. Development sites 033, 211
and 219 all lie within the conservation area and English Heritage cannot see
how they could come forward for development without resulting in significant
harm to the character or appearance of the conservation area, as well as
adversely impacting on the setting of some of listed buildings. Sites 008,
008B and 008C are all likely to adversely impact on wider setting of the
conservation area and the more immediate setting of Hutton House, along
with its walled garden and stables (all listed at Grade II). Site 028C is a large
site that abuts the south east and southwest boundaries of the conservation
area, where development is likely to result in harm to the rural character and
appearance of the conservation area and would also have the potential to
adversely impact on the setting of the Church of All Saints and Hutton Hall (both Grade II* listed). The western boundary of Site 028C also abuts the
boundary of Heatleys, a 16th century Grade II house, and development in this
area would have implications for the setting of this house.
Sites 028A and 028B abut the southeast built edge of Hutton. Development
in this area would have implications for the setting of a number of listed
buildings including Hare Hall (Grade II listed) Heatleys (Grade II) listed and
Kennel House (Grade II listed). It may also have implications for the wider
setting of the Thorndon Park Conservation Area and Thorndon Hall
Registered Park and Garden (Grade II*), as well as longer views out from
Thorndon Hall (Grade I listed).
Site 192 is another large site which adjoins the south of site 028C and is
located to the east of Ingrave and Herongate. This site completely enclosed a
scheduled moated site at Heron Hall, together with the 17th century Grade II
listed Hall and stables and the Grade II* listed granary. This complex of
heritage assets currently enjoys a remote rural setting, and historically the
medieval house sited within the moat would have commanded all this
surrounding land. Development of the land around these heritage assets
would therefore result in significant change to their setting and harm to their
significance.
Site 212 is located to the southwest of the Great Warley conservation area
and, while this site is unlikely to have an impact on the conservation area, it
has the potential to adversely impact on the setting of the Thatched Cottage
and The Squirrels (both dating from the 19th century and listed at Grade II).
This site currently comprises Coombe Wood, which would appear to be of
some landscape and ecological value. Northwest of Great Warley is site 167.
Again this site is sufficiently remote from the conservation area and
Registered Park and Garden, but abuts the northern boundary of Hill Cottage
(Grade II listed) and is in relatively close proximity to Great Ropers, an 18th
century house listed at Grade II*.
Site 218 on the edge of Shenfield lies close to a cluster of listed buildings at
Shenfield Hall, including the Grade II hall and Grade II* Church of St Mary.
There should be assessment of potential impacts. Q6: In the North of the Borough, is it preferable to release greenfield or
brownfield sites?
As noted in the document, the North of the Borough is made up of a collection
of villages set amidst attractive landscape (although it is wrong to simply
consider the landscape as 'natural', as it will contain many historic elements).
In terms of specific sites:
Blackmore
The village includes a designated conservation area that contains a number of
listed buildings forming this historic core of the settlement and some open
land of historic interest that also makes a positive contribution to the character
and appearance of the conservation area. Site 052 is located in the conservation area on land to the rear of Little
Jericho. Little Jericho is a grade II listed house dating from c1600 and the
vacant barn/farm buildings to its rear may be curtilage listed. They may also
make a positive contribution to the character and appearance of the
conservation area. Whilst a scheme for the careful adaptation of the farm
buildings into residential use may be acceptable, their demolition and
wholesale redevelopment of the site could well result in harm to the historic
environment.
Site 202 is located immediately adjacent to the western boundary of the
conservation area and the loss of open rural views out of the conservation
area (especially from the path that defines this boundary of the conservation
area) is likely to be harmful to the character and appearance of the
conservation area. Site 199 is to the northeast of the conservation area and
would be less likely to impact on its setting, especially if the southern edge of
the development was given a soft and green boundary.
Sites 076 and 077 are both further away from the conservation area, but both
have Grade II listed buildings in close proximity, and development could
adversely impact on the setting of these listed buildings. It might be possible
to bring forward development on both sites that successfully addresses the
issue of setting for these listed building, but it would be necessary to first
understand how setting contributes to their significance.
Hook End
While there is not conservation area in Hook End, there are a number of
Grade II listed buildings that might be affected by development proposals. A
number of these listed buildings are farmhouses that would historically have
been linked to the adjacent open farmland. Loss of this open farmland could
therefore impact on their signficance. In particular site 174 is immediately to
the west of a collection of three Grade II buildings comprising Hook End
Poultry Farmhouse, brewhouse and barn, while Site 183 is to the south west
of Barfield Farmhouse and south east of Deal Tree Farmhouse. Other sites
that may have implications for the setting of designated heritage assets
include 209 (impacting on the Soap House, Grade II), 056A & 056B
(impacting on The Cottage, Grade II) and 196 (impacting on a cluster of
Grade II listed assets comprising a pump, cartlodge, granary and Wyatts
Farmhouse). Thoby Priory
Site 018 incorporates the ruins of Thoby Priory, which is a Scheduled
Monument and listed Grade II. The priory ruins are also on the English
Heritage 'at risk' list. The priory would have been sited in a remote location
suitably for the contemplative life, but that setting has been compromised in
recent years. English Heritage accepts that a development with housing
located to the west and north of the designated assets, whilst retaining an
open aspect to the south and east, could be acceptable, especially if it also
provided for the improved management of the heritage assets.
Kelvedon Hatch A number of possible sites are identified around the periphery of Kelvedon
Hatch. Those on the east side of the settlement have minimal implications for
the historic environment. There are a number of designated heritage assets
(both listed and scheduled) on the west side of the settlement, but most of
these are to the west of A128 and are therefore likely to be adequately
buffered from developments on sites 217 and 194, which are located on the
east side of the A road. There is a smaller site at 074 which may have
implications for the setting of St Nicholas's Church (Grade II). This church is
currently sited on the edge of the settlement and enclosing its open aspect to
the south might result in a degree of harm.
Q7: Do you agree that the most sustainable approach to employment
need is to allocation new sites close to the strategic highway network?
The map on page 22 of the document identifies a number of potential
employment sites. These sites are generally located in close proximity to
existing transport corridors and/or adjacent to current employment sites, and
the majority will have little adverse impact on designated heritage assets. The
exceptions are sites 109 and 187, which are adjacent to East Hordon Hall
(16th and 18th century and Grade II listed). While the setting of the Hall has
already been compromised by the A127 (which passes immediately to the
north) and the existing employment land to the east of the Hall, further
employment buildings in close proximity would exacerbate the existing harm.
Q8: Do you agree that a town centre first approach should be taken to
retail development?
We broadly agree with this approach as it is should help to maintain the vitality
of town centres which in turn can benefit heritage assets within these
locations. It will depend on specific proposals and their impact, but there are
opportunities in places like Brentwood Town Centre to secure enhancements.
In terms of retail site options for Brentwood Town Centre, our 2013 comments
have highlighted specific heritage assets for some of the sites shown in this
consultation. In many respects, Site 100 (Baytree Centre) is the most
important in terms of opportunities to enhance the historic environment, given
its access off the High Street from within the conservation area, and the
proximity of several listed buildings plus a scheduled monument (the chapel).
We would welcome further discussions regarding this site.
Q9: No comments
Q10: Landscape value
Section 5 of this consultation puts heritage into a separate category detached
from other environmental considerations, rather than include it as part of the
overall environmental picture. Figure 15 should include designated heritage
assets, particularly conservation areas, scheduled monuments and registered
parks and gardens. We note the intention to produce further assessment of
landscape capacity surrounding urban areas in paragraph 5.6. We strongly
recommend that this assessment includes the historic environment as a key
component of landscape capacity. Our comments on specific sites reveal the
extent of heritage assets surrounding the urban areas, and this should be
considered in any decisions on suitable sites. The Local Plan evidence base does not appear to contain any specific references to the historic environment,
and we recommend this is addressed.
Q11: No comments
Q12: Infrastructure Issues
The provision of new or improved infrastructure such as transport can have
implications for the historic environment in terms of impact on specific heritage
assets. The Infrastructure Delivery Plan and related work should consider
such issues. In addition, the historic environment can form part of different
types of infrastructure, from community facilities to historic transport
structures. It also contributes to green infrastructure, which is more than just
the natural environment. Publicly accessible parks and gardens,
archaeological sites and spaces within conservation areas and listed buildings
can all form part of existing and proposed green infrastructure networks, with
opportunities to conserve and enhance such elements.
Q13: No comments
We hope that the above comments are of assistance. If you have any queries
or would like to discuss specific points, please do not hesitate to contact me.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5900

Received: 17/02/2015

Respondent: Miss Zoe Sheaf

Representation Summary:

The priority should be on more public transport, and turning brownfield sites into protected Green Belt areas.

Full text:

see attached.

Attachments:

Comment

Strategic Growth Options

Representation ID: 5932

Received: 16/02/2015

Respondent: Mr Kevin Mate

Representation Summary:

Given the scale of development proposed within the A127 Corridor, whilst there will be priorities, the development will require infrastructure spending across all categories (education, healthcare, transport, green space, community facilities etc.). Failure to provide any one element of this infrastructure will have a materially negative impact on both existing residents, and the new development. As such, whilst there may be priorities in areas where development is expected to be lower/less significant, in areas expected to see high levels of development, a holistic infrastructure plan needs to be delivered to ensure the development is undertaken in a sustainable manner.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 5982

Received: 16/02/2015

Respondent: Mr George Nichols

Representation Summary:

Appraisal required, not an arbitrary consideration. This question is ill-conceived.

Full text:

see attached.

Attachments:

Comment

Strategic Growth Options

Representation ID: 6019

Received: 17/02/2015

Respondent: Zada Capital

Representation Summary:

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

Full text:

1. Managing Growth

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

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

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

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

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

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

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

2. Sustainable Communities

Q3 Do you have any comments on the appropriateness of particular sites
Q4 Given the greater capacity for growth along the A127 Corridor, which of the sites put forward do you think is the best location for growth.
Q5 Should the A12 Corridor accommodate growth by releasing sites on the edge of urban areas.
Q6 In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt).

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

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

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

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

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

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

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

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

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

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

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

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

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

3. Economic Prosperity

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

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


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

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


4. Environmental Protection and Enhancement

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

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

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


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

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



5. Quality of Life & Community Infrastructure

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

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

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

Attachments:

Comment

Strategic Growth Options

Representation ID: 6077

Received: 16/02/2015

Respondent: Mrs Sandra Mate

Representation Summary:

Given the scale of development proposed within the A127 Corridor, whilst there will be priorities, the development will require infrastructure spending across all categories (education, healthcare, transport, green space, community facilities etc.). Failure to provide any one element of this infrastructure will have a materially negative impact on both existing residents, and the new development. As such, whilst there may be priorities in areas where development is expected to be lower/less significant, in areas expected to see high levels of development, a holistic infrastructure plan needs to be delivered to ensure the development is undertaken in a sustainable manner.

Full text:

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.

Attachments:

Comment

Strategic Growth Options

Representation ID: 6086

Received: 17/02/2015

Respondent: SJ Walsh and Sons

Agent: JTS Partnership LLP

Representation Summary:

No comment.

Full text:

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.

Attachments:

Comment

Strategic Growth Options

Representation ID: 6100

Received: 16/02/2015

Respondent: Dr. S.J. Jennings

Representation Summary:

Flood risk in Blackmore. Schools/health/transport/elderly living accommodation- bungalows, ground floor apartments, sheltered accommodation.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6113

Received: 16/02/2015

Respondent: David Fairweather

Representation Summary:

Improving existing facilities such as road repairs.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6142

Received: 16/02/2015

Respondent: Janet Cowing

Representation Summary:

Roads - to ease traffic bottlenecks, maintenance of existing refuse sites eg
in Mountnessing in order to prevent an increase in fly tipping, additional
doctor surgeries and schools.

Full text:

see attached.

Attachments:

Comment

Strategic Growth Options

Representation ID: 6166

Received: 17/02/2015

Respondent: Robert Mulholland & Co Ltd

Agent: JTS Partnership LLP

Representation Summary:

No comment.

Full text:

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: 6173

Received: 16/02/2015

Respondent: Mr and Mrs Paul McEwen

Representation Summary:

ROADS and parking.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6191

Received: 16/02/2015

Respondent: Mr Gregory Wayte

Representation Summary:

Improved public transport. Better road maintenance.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6205

Received: 16/02/2015

Respondent: Chris Shepherd

Representation Summary:

Developing space within or near the centre of Brentwood.
Sites near the A127 / M25 junctions.
Sites along the A127.
These areas offer great access to major routes and are already served to
public transport.

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6214

Received: 16/02/2015

Respondent: Julia O'Farrell

Representation Summary:

Drainage issues (see issues about previous flooding)
Doctors surgery
Schools
Transport and road safety

Full text:

see attached

Attachments:

Comment

Strategic Growth Options

Representation ID: 6230

Received: 16/02/2015

Respondent: Mrs Elisabeth Taylor

Representation Summary:

On improving the main roads around already established towns.

Full text:

see attached

Attachments: