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.

see attached

I was told to write in on my view about the planning developing in Blackmore village, Redrose Lane and Woollards Way, and second being other side of Fingrith Hall Road, linking with Orchard Piece. I would like to say I am all for it, the development should go ahead, I know people that would like to move into the village to be near their families where they have been brought up and my daughter has been waiting for 12 years to move into the village. I know many people in similar situations, so yes I am for it.

[See attached completed consultation questionnaire]

see attached

see attached

see attached

I am writing with my views on the Local Development Plan.

The great length and detail of the report makes it difficult to go over all of the options, so I am focusing my views on the proposed site "South of Red Rose Lane, north of Woollard Way, Blackmore (Site Ref 077).

As a resident of Woollard Way in Blackmore, and having spoken to many other residents of Blackmore as well as other villagers, I would like to strongly object to any plans to build on this site, or indeed any sites within the parish that consist of more than 1 or 2 houses.

Of course part of my reason is selfish. I chose to live in Blackmore so that I could live in a small pretty village community surrounded by green belt land (which I thought would always be the case). Also I am 1 house away from the proposed site, so my views across the field will of course be ruined and I would expect house prices to be detrimentally effected.

However, my reasons are not all selfish. As I see it there are several other practical reasons why I don't think building here would make sense.

* It is Green Belt land, as your "SO7" states, you would like to preserve green belt land
* Blackmore is a pretty and in many ways an "archetypal" English Village, and a new development would clearly diminish the character of the village. Surely nobody wants to see our villages all turned into urban areas.
* I believe the proposed development is not for the entire site, but realistically, I think we can all assume that once a "first wave" is built, attempts will soon be made to build on the rest
* The land is prone to flooding and I am told that previous attempts to develop the land many yeas ago were not pursued because the drainage issues. Building on the land will exacerbate this and is bound to have a knock on effect on the existing houses in Woollard Way, many of which already suffer from flooding and drainage problems. (The regular presence of "Dynorod" prove this.)
* The local school has already grown rapidly in recent years, and I don;t see that it has the capacity to take any more children. Anecdotally, I hear that the Head of the school might be happy to increase numbers further, but she may have her own agenda for doing this.
* The argument I have heard that it will help local business doesn't really stand up either. Blackmore has 2 pubs, a tea shop, a post office (which may soon be closing down despite already being extremely busy) and a "convenience" shop. We know that only a small percentage of people will use these businesses, so I don't see that their business will be materially affected by the numbers of households being suggested.
* Regarding the Housing Association element of the proposed site. Who would these people be. HA houses that were built in the Stondon Massey area were generally given to people outside of the area, and that were used to large towns. I know that many of these people have not adjusted to "village life" and are not happy living here and want to return to more urbanised areas.
* There is no train service, and very patchy bus services so most of these households will have cars which will increase traffic flow around the narrow country lanes around the village.
In short, this proposed development will spoil the feel of the village, therefore having a detrimental effect on all those that live here, and particularly those close by and surely we need to protect these kinds of villages as best we can. Many of the other proposed site are already within built up areas where the residents and infrastructure are already used to, and capable of coping with the extra houses so I would urge you to prioritise these sites over Green Belt sites.

See attached

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

Q1: Yes.

Q2: Yes.

Q3: Yes - Site ref 076 & 077 to much for village, school already full.

Q4: Yes.

Q5: Yes - Only brownfield sites.

Q6: Only brownfield sites.

Q7: Yes.

Q8: Yes.

Q9: No.

Q10:
Scenic Beauty: 4
Outdoor Recreation/ Leisure Use: 5
Wildlife Interest: 4
Historic Interest: 5
Tranquility: 5

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

Q12: Yes.

Q13:
1. Using appropriate methods to remove unauthorised Traveller Sites.
2. Acquire as many unused/ empty houses. In Blackmore there are at least 6 empty houses.

Q1: Yes.

Q2: Yes.

Q3: Yes - See answer to questions 5 and 6.

Q4: Agree with the comments especially in the light of the Dunton Garden Suburb proposal which would seem to be the ideal growth solution.

Q5: Yes - But only after careful consideration of the sites impact on the Green Belt.

Q6: No - Any development in respect of the villages should be contained within the existing envelopes of these villages which in almost all respects have reached their capacity for growth. That apart from a few brownfield sites within the existing village boundaries i.e. no encroachment onto the Green Belt. Site nos 76 and 77 on the outskirts of Blackmore are in the Green Belt and should therefore NOT be considered for development.

Q7: Yes - Essential for the growth of new business.

Q8: Yes - Essential for the benefit of the Town Centre's future.

Q9: No - Blackmore has over the years maintained and interested in open space provision which is now, to the credit of the Parish Council proved to be more than adequate.

Q10:
Scenic Beauty/ Attractiveness: 5
Outdoor Recreation/ Leisure Use: 5
Wildlife Interest: 5
Historic Interest: 4
Tranquility: 5

Q11:
Houses: 3
Commercial/ Industrial buildings: 2
Nature Reserves/ Wildlife: 3
Farmland: 4
Woodland: 4
Degraded/ Derelict/ Waste land: 1
Infrastructure: 2
Leisure/ Recreation facilities: 3

Q12: Yes.

see attached

Q1: Yes. A12 and A127 should be promoted.

Q2: Yes.

Q3: Yes. It is not appropriate to develop sites 76 [Land south of Redrose Lane, north of Orchard Piece, Blackmore], 77 [Land south of Redrose Lane, north of Woollard Way, Blackmore], 199 [Land to the East of Ingatestone Road, Blackmore], 202 [Land to the South of Blackmore, off Blackmore Road] and 203 [Land to the West of Blackmore, off Blackmore Road] as this is a conservation area and within the Green Belt.

Q4: Dunton Garden Suburb.

Q5: Yes.

Q6: Brownfield sites must be developed in preference to green sites.

Q7: Yes.

Q8: Yes. Promote Town Centres as this reduces traffic.

Q9: No.

Q10: Scenic Beauty Attractiveness: 5
Outdoor Recreation / Leisure Use: 5
Wildlife Interest: 5
Historic Interest: 5
Tranquility: 5
Other - A Tourist Attraction: -

Q11: Houses: 3
Commercial / Industrial Buildings: 2
Nature Reserves / Wildlife: 3
Farmland: 3
Woodland: 2
Degraded / Derelict / Waste Land: 1
Infrastructure: 2
Leisure / Recreation Facilities: 3
Other - Historic Buildings including Church: 2

Q12: No.

Q13: Health provision.

Q1: Yes. A12 and A127 Corridors should be encouraged and not North due to lack of infrastructure.

Q2: Yes.

Q3: Yes. Blackmore is in a conservation area and within the Green Belt. Sites 076, 077, 199, 202 and 203. So are not suitable.

Q4: Dunton Garden Suburb.

Q5: Yes.

Q6: In borough villages, if land needs to be released at all, then brownfield sites should be used.

Q7: Yes.

Q8: Yes. Reduce traffic by promoting town centres.

Q9: No.

Q10: Scenic Beauty Attractiveness: 5
Outdoor Recreation / Leisure Use: 5
Wildlife Interest: 5
Historic Interest: 5
Tranquility: 5
Other - Tourist Attraction: 2

Q11: Houses: 3
Commercial / Industrial Buildings: 2
Nature Reserves / Wildlife: 3
Farmland: 3
Woodland: 2
Degraded / Derelict / Waste Land: 1
Infrastructure: 2
Leisure / Recreation Facilities: 2
Other - Historic Buildings including Church & Priory: 2

Q12: No.

Q13: Health provisions.

Q1: No. I think the government need to look at unused inner city buildings, derelict land and so forth. Keep our Green Belt identify, protect our heritage and not overbuild.

Q2: No.

Q3: Yes. Keep our villages especially Blackmore as it is. We haven't the resources and the roads would become dangerous, congested and like a town.

Q4: Not sure.

Q5: No.

Q6: Is this a question or a statement? I do not agree with using Green Belt at all. I strongly believe that Brentwood or elsewhere could be developed more.

Q7: No.

Q8: Yes.

Q9: As in what provision? Don't know.

Q10: Scenic Beauty Attractiveness: 5
Outdoor Recreation / Leisure Use: 4
Wildlife Interest: 5
Historic Interest: 5
Tranquility: 5
Other - Green Belts saved re Woollard Way - my road and my children's view and safety: 5

Q11: Houses: 2
Commercial / Industrial Buildings: 1
Nature Reserves / Wildlife: 4
Farmland: 4
Woodland: 4
Degraded / Derelict / Waste Land: 1
Infrastructure: 2
Leisure / Recreation Facilities: 2
Other - Space and Tranquillity, English Heritage: 4

Q12: Quality of life, enjoying greenery of a natural environment. Safety for our children to grow up more free, not a built up area - this is why we moved to Blackmore, Woollard Way.

Q13: Don't know.


These questions are very biased and vague.

I do not want Woollard Way - the brownfield area of Green Belt to be developed / built on. This will devastate us. We moved here for the greenery and views. This will devalue our homes, effect our children's freedom and security. A close made into a noisy road would be categorically wrong and devastating. All the children love watching the horses, wildlife in the field next to use, they play out with no through traffic.

See attached documents.

See attached documents.