I wish to register my objections to any proposed housing or commercial/industrial development at the following locations in the Strategic Growth Options consultation document:
Woodlands School Warley Street (ref 016A and 016B)
Land fronting at Warley Street - Dickinsons Farm (ref 082)
Land at Warley Road adj Hill Cottage (ref 167)
Coombe Woods Beredens Lane (ref 212)
Chep Pallets (Peri site) Warley Street (ref 228)
Land adjacent Carmel, Mascalls Lane (ref 027)

see attached

The proposed Strategic Growth Local Plan was discussed in full at a recent meeting of the committee of the Great Warley Conservation Society. The following decisions were reached:

1. The purpose of our Society, which has been active since 1972, is to help the residents of Great Warley to protect the Green Belt and the open environment of our village. We therefore vigorously object to the sites listed below, which have been put forward for future development.

2. It is our opinion that building on these sites would be both visually poor for the approaches to the villages and to Brentwood town, and also remote and lacking in the services and facilities which are required for substantial development.

3. It is fully appreciated that any future development will still require detailed planning permission. However, future planners at Brentwood Council would be in a very difficult position when considering applications if these sites have already been allocated for development in the Local Plan.

The following suggested sites are of most concern to the Conservation Society:

a) Coombe Woods, Beredens Lane, No. 212. This is a woodland area of special natural landscape interest. Building here would involve losing a large number of trees, plants and wildlife, as well as detrimentally affecting the vistas of the periphery of Brentwood. This would have a negative impact on the quality of life.

b) Land adjacent to Hill Cottage, Warley Road, No. 167, and extending down to Mascalls Lane to Mill House, and

c) Land adjoining Carmel, Mascalls Lane, No.027

Both of these sites, as well as being in the Green Belt, provide a pleasing outlook on the edge of existing buildings. The inevitable resultant requirements for amendments to the road layouts would further urbanise one of the few remaining landscapes which make Brentwood so appealing.

d) Woodlands School, Warley Street, No. 16 A and B and

e) Land at Dickensons Farm fronting Warley Street, No. 082.

Both of these sites are too remote from any reasonable transport links and other facilities, and housing construction is incompatible with the surrounding Green Belt area.

We therefore wish to register our formal objection to these sites being included in the proposed Strategic Growth Options Plan.

This consultation contains infringements of the Green Belt and developments which are too remote from essential service such as at Woodlands School #16A/B and Dickenson Farm #082. In addition to Green Belt and remoteness concerns, Coombe Woods (Breedens Lane) #212 and land adjoining Carmel #027 on Marscalls Lane involve loosing unacceptable numbers of trees and plants.
Also development of the Ford's Warley site should be strongly resisted as this puts many high quality local jobs at risk with the additional risk to the Ford Dunton site in Basildon. Also considerable upgrade to health, schooling, transport etc would be necessary before this could be considered.

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

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

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

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

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

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

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

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

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

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

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

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

Q7: Yes - No further comment.

Q8: Yes - No further comment.

Q9: Yes - No further comment.

Q12: Yes - No further comment.

Q13: No comment.

See attached.

see attached