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Havering welcomes the opportunity to comment on the above Local Plan documents.
The comments set out below have Member approval. However, Havering will be submitting further comments to the Strategic Growth Options shortly reflecting additional Member's strong concerns regarding the Green Belt and transport implications of some of the potential development sites identified in the document.
For information, Havering will also be submitting separate comments on the Dunton Garden Suburb proposals currently out for consultation (extended until 16th March 2015) in the light of the strong concerns that this proposal raises in terms of the Green Belt and for the strategic highway network.

Potential development sites (A12 Corridor)
The document identifies a number of sites in the A12 Corridor Housing Site Options section which are adjacent to the Havering borough boundary - specifically sites 175B and 175C (Land at M25, Junction 28, Brook Street) - which are identified as potential mixed-use development sites.

It is acknowledged that all sites in the document are potential development sites only at this stage, and that no detail on the type, scale and form of development is provided. However, if these sites are taken forward into the Draft Brentwood Local Development Plan then Havering will need to carefully consider any proposals for these sites. Depending on the scale and nature of development there are likely to be issues for Havering in terms of, for example, transport and the impact of development on the openness and character of the area.
Potential development sites (A127 Corridor)
The document identifies site 101A (Land at Cobham Hall, including M25 work site at A127/M25 Junction 29) as a potential new employment site - Brentwood Enterprise Park. This is in line with its identification in the 2013 Preferred Options report. As this is adjacent to the Havering borough boundary, the Council will want to see further detail on proposals for this site should it be taken forward into the Draft Brentwood Local Development Plan later in 2015.
Gypsy and traveller sites
Appendix 1 of the documents lists 19 existing gypsy and traveller sites in Brentwood, a number of which are in the Navestock area, close to the Havering borough boundary. However, only 10 of the 19 sites are identified on the maps on pages 16 to 19. Further clarification on where all 19 existing sites are located is necessary. Information on pitch numbers on each existing site should also be included.

The document notes that the Council will need to consider national policy and the conclusions of the 2014 Essex Gypsy and Traveller Assessment when preparing the Draft Brentwood Local Development Plan. This version of the plan should include current and future pitch numbers and details of new or extended existing sites for comment.

Dear BBC Planning Policy and Mr Pickles,

I object to that proposed, within this consultation document, for the following reasons;

The Strategic Growth Options Consultation states;

1.4 The Council is required to meet local housing and employment needs, among other needs and further in the document

3 Sustainable Communities ?
The Council is required to meet projected local housing needs

and this is reiterated in Para 14 of the NPPF;

For plan-making this means that:

● local planning authorities should positively seek opportunities to meet the development needs of their area;

As stated in the 'The Local Plan 2015-2030 Preferred Options for Consultation'

2.28 The Borough faces a high level of demand for housing from people seeking to move into the area. Around 80 per cent of projected household growth between 2010 and 2033 arises from people expected to move here, mainly from elsewhere in the UK. The remainder is from natural change - an excess of births over deaths (Office for National Statistics (ONS) 2010 based sub national population projections).

5.2.1 of the Sustainability Appraisal of the Brentwood Local Plan Scoping Report May 2013 states:

Almost all of the population change in Brentwood between 2001 and 2008 was through migration from the EU and UK.

Very clearly the proposed excessive housing does not '...meet the development needs of their ( Brentwoods ) area'. The proposed housing is not for local needs and is contrary to NPPF Para 14. There are plenty of empty homes in other parts of the UK

I object to any re-designation of greenbelt, as stated by the 2005 Brentwood Local Plan, such as the so called Housing Site Options ie greenbelt land to the southeast of the borough and the so called Brentwood Enterprise Park at the A127?M25 junction. BBC should aspire to being No 1, nationally, in percentage terms of having greenbelt as opposed to being only 6th. Both these areas are greenbelt and any development ought to be accordance to the current Local Plan policies, that enhance the existing greenbelt, as per;

GB28 Landscape Enhancement
WHERE APPROPRIATE, TREE PLANTING AND HEDGE SCREENING WILL BE EXPECTED IN PROPOSALS FOR DEVELOPMENT IN THE GREEN BELT. IN ADDITION, BRENTWOOD COUNTRYSIDE MANAGEMENT SERVICE WILL CARRY OUT NEW PLANTING ON PUBLICLY OWNED LAND AND, IN CO-OPERATION WITH THE OWNER, ON PRIVATE LAND. WITHIN SPECIAL LANDSCAPE AREAS AND OTHER AREAS WHERE THE LANDSCAPE NEEDS IMPROVEMENT EMPHASIS WILL BE GIVEN TO RESTORE AND ENHANCE DAMAGED LANDSCAPE AND WILL BE A REQUIREMENT WHERE APPROPRIATE. WHEREVER POSSIBLE, NEW PLANTING SHOULD BE CARRIED OUT USING SPECIES NATIVE TO THE AREA. PROPOSALS SHOULD SAFEGUARD THE EXISTING ECOLOGICAL VALUE OF THE SITE AND INCLUDE MEASURES FOR HABITAT CREATION.

C12 Landscape Improvements
THE COUNCIL WILL, IN CONJUNCTION WITH ITS COUNTRYSIDE MANAGEMENT SERVICE, SEEK TO ENCOURAGE LOCAL LAND OWNERS TO IMPLEMENT SCHEMES TO IMPROVE THE ENVIRONMENT THROUGH PLANTING, HABITAT CREATION, IMPROVED PUBLIC ACCESS, MANAGEMENT AGREEMENTS AND OTHER MEASURES, WHILST ALSO IMPLEMENTING ITS OWN PROGRAMME OF ENVIRONMENTAL IMPROVEMENT SCHEMES THROUGHOUT BOTH THE URBAN AND RURAL AREAS OF THE BOROUGH.
WITHIN THE LANDSCAPE IMPROVEMENT AREA, AS DEFINED ON THE PROPOSALS MAP, ANY DEVELOPMENT PROPOSALS WILL BE EXPECTED TO CONTRIBUTE POSITIVELY TOWARDS THE RESTORATION OF ITS ORIGINAL CHARACTER.


The proposed movement of West Horndon's industrial premises to the designated greenbelt, as defined in the current 2005 Brentwood Local Plan, to the so called Brentwood Enterprise Park at the M25/A127 junction fails to consider public transport for workers that the current industrial site enjoys via a bus service and the regular train service some 50m away. This will increase local road traffic congestion and exclude potential workers that are unable to travel to the proposed new greenbelt industrial site. There is a sad and unsustainable irony that many industrial sites are re-designated for housing at the expense of greenbelt for for 'employment'/industrial sites shortly afterwards.

As for the temporary works at the A127/M25, that was set up to allow the widening of the M25, I would be grateful that you provide me proof, in response to this email objection, that this site was temporary and that there was, originally, a commitment to return it to its current greenbelt designation. I note from the Strategic Growth Options Consultation that the definition of Brownfield is given as

Brownfield (previously developed land): Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. There are some exclusions to this, such as land occupied by agricultural or forestry buildings and private residential gardens.

Clearly the M25/A127 site is still greenbelt and should remain so as opposed to becoming another jigsaw piece towards the London Borough of Brentwood.

The A127 and A12 are already congested roads much due to the destruction of countryside along their corridors. This destruction continues as evidenced at the Fortune of War Roundabout area of Basildon on the A127. Any further development will exacerbate already dire congestion and will significantly and adversely affect the quality of life of those travelling on and living close to these roads.

Defra has designated all of Brentwoods farmland as 'Good'. The proposed destruction of 'Good' Grade 3 farmland will be a significant loss of food production for a country that is unable to feed itself without importation. Wartime generation politicians that created the greenbelt did so to the point of agricultural yield obsession due to the near starvation of the United Kingdom during WW2. Some of the most fertile and productive land ie the alluvial plains along the Thames, were built on between the wars and these politicians were determined that such shortsightedness ought not happen again. Building on existing farmland is dangerous and exacerbates the inability for UK to feed itself. This, potentially, affects everyone and food security ought to be a primary concern to both planners and politicians. We live in a fragile society and world and we saw a glimpse of this frailty during the fuel strike some 15 years ago.

Any future commitment to greenbelt policy will be permanently undermined given the original 'commitments' to it made by the post-war generation politicians who clearly envisaged situations such as this.

Continuous nibbling away at something ie The Greenbelt inevitably leads to nothing.

Please register my objection to the current Brentwood Strategic Growth Options Consultation

Yours sincerely

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