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.

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.

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.

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 Joy Fook Restaurant, which sits adjacent to Bentley Golf Club, in Kelvedon Hatch (see attached Site Location Plan). The site would fall within criteria 2 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.