We wish to object in the strongest terms to the proposed development of 11, 11a, 11b, 11c, 176 - Land Rear of 10-20 Orchard Lane and Land at former Bentley Zoo. We feel that development of the greenbelt land will significantly change the character of Pilgrims Hatch. Orchard Lane is already a haven for speeding drivers and we could only expect this to worsen should further homes be built nearby.
The Ongar Road is already overloaded with traffic. The infrastructure clearly could not cope. Having considered the above we do not believe that above sites are suitable for a housing estate.

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.

Introduction

Since 2009, we have promoted 2.8 hectares (6 acres) of land off Crow Green Lane, Pilgrims Hatch, as a development allocation for inclusion in the local development plan, now known as the Brentwood Borough Local Plan. The land is referred to in the Consultation Document as Site 159. We have also put the site forward through the Council's SHLAA process, under reference G057.

Our main interest in the Consultation Document is its provisions for housing growth and associated community facilities. We have structured these initial representations around the Consultation Document's thirteen questions as set out in Section 7: Summary. However, we would like to comment first on the assessment of housing need on which the Document's Growth options are based.

In our representations on the Council's July 2013 Local Plan Preferred Options for
Consultation, we stated our objection to the Council's intention not to cater for all of the Borough's "objectively assessed" housing need. We described this as a very
risky strategy that would only delay decisions that had to be made on achieving an effective balance between meeting housing need and conserving the environment.

We are pleased to note in the current consultation that the Council now intends to
meet all the objectively identified needs. We have always been aware that Brentwood Borough has a high percentage of Green Belt land, significantly constraining development opportunities. Adjustments therefore need to be made to the current Green Belt boundary, which can be achieved without materially compromising its purpose. This will then accommodate the 3000 new homes that cannot be catered for on brownfield land.

Managing Growth

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

We supported Option 2 as set out in the 2013 Preferred Options Document, which
concentrated growth within the Borough's two main transport corridors. We think this is the best overall growth strategy for the Borough. In naming these corridors, we suggest moving away from using road names, using instead either "transport corridor" or the name of the railway line running through each. This would help shift the emphasis away from road to more sustainable transport modes. We also believe the Borough should be divided into four areas for the purposes of managing growth, as follows:
*The Rural North
*The Brentwood/Shenfield Transport Corridor
*The Rural South
*The West Horndon Transport Corridor.

The Document's Figure 6b shows approximate boundaries for the A12 Corridor. We support the boundary shown between Area (A) North of the Borough and Area (B) the A12 Corridor. This will allow for some modest growth around the edges of Pilgrims Hatch, which is where Site 159 is located. We suggest that the southern boundary is drawn closer to the urban edge of Brentwood and Shenfield, allowing the creation of a new southern rural area between the A12 Corridor and the A127 Corridor.

Sustainable Communities

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

We have promoted Site 159 as representing a relatively modest urban extension that can provide a mix of housing and community facilities in the Pilgrims Hatch area.

We note from the Consultation Document's paragraph 6.5 that the Council is looking to collaborative projects to ensure that appropriate healthcare facilities are provided to serve growth areas. Paragraph 6.8 also says the Council wishes to ensure that "new community facilities are delivered alongside new homes to support sustainable communities". In promoting Site 159 we have consistently stated our clients' willingness to make part of the site available for community use. We have prepared sketch schemes showing that housing and community facilities can easily be accommodated on Site 159. In discussions with Highways Officers, they stated they had no objections with regard to access, which is easily achievable to and from the site. Given the continuing ageing of the Borough's population, we further suggest, amongst other things, a care home in a semi-rural setting that will cater for the needs of older people.

Site 159 is within the Green Belt, immediately next to the existing urban edge. It has wholly defensible boundaries, and is currently used as grassland. There is a mixture of paddocks and buildings to the west. Housing all the way along the site's southern boundary presents a raw urban edge to this part of Pilgrims Hatch.
The Green Belt's main functions are:

*to check the sprawl of large built-up areas
*to prevent neighbouring towns merging into one another
*to assist in safeguarding the countryside from encroachment
*to preserve the setting and special character of historic towns
*to assist in urban regeneration by encouraging the recycling of derelict and
other urban land.

The Council has already considered all possible urban land recycling within the Borough and concluded that there is still a requirement to find land in the Green Belt for some 3,000 homes. Our assessment of Site 159 against the other four Green Belt functions is:

*sprawl - the site has buildings on two sides and definitive boundaries on the
others; contribution to preventing urban sprawl relatively small
*merging of towns - large rural area to the north; contribution to preventing merging of towns negligible
*countryside - buildings on two sides, with strong defensible boundaries to north and east; contribution to safeguarding countryside relatively small
*setting of town - the site is a narrow strip of land on the urban edge of Pilgrims Hatch. It makes a negligible difference to the setting of Brentwood as an historic market town.

Compared to many of the potential development sites shown within the A12 Corridor, allocating Site 159 would have relatively minor consequences for the function of the Green Belt in this part of the Borough. The site provides an ideal opportunity to make an early contribution to the Borough's identified housing needs and improve local community facilities. We have noted in past consultations the Council's identification of changes in local demographics, the most significant being a predicted continuing growth in the numbers of older people. Sites like 159 will provide opportunities for new facilities meeting the needs of older people on a relatively modest development close to the countryside. This would be a direct response to the Consultation Document's call, in paragraph 6.8, for new community facilities delivered alongside new housing.

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?

We have consistently supported the A127 Corridor as an ideal location for a
strategic development land allocation. This situation is now complicated by the proposed Dunton Garden Village, mainly located in Basildon District, but partly in the Borough. We think this is an ill-conceived idea that will seriously undermine the purposes of the Green Belt, especially in preventing the merging of neighbouring towns along the A127 Corridor.

We believe any new strategic development in this area should take the form of a high density, walkable settlement with West Horndon Station being developed as its main transport and commercial hub. The best site for achieving this would be the 2013 Consultation Document's West Horndon Strategic Allocation. To make the best use of West Horndon Station as a hub, it would be sensible to extend the strategic allocation across the Borough boundary into Basildon District.

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

Yes. We believe the search should start around the northern edges of Brentwood
and Shenfield, since it is here that the release of small to moderate sized sites will
have the least impact on the primary functions of the Green Belt.

The countryside between Brentwood and Shenfield, and West Horndon and Basildon to the south and south-east, is relatively narrow. Given the proposed westward expansion of Basildon and strategic growth allocation at West Horndon, it would be sensible to minimise allocations along the southern edges of Brentwood and Shenfield. Some of the sites shown on the Consultation Document's Figure 10, south and south-east of Shenfield and Hutton, would represent major intrusions into the Green Belt. Allocating Sites 028C and 192 would be particularly damaging to Green Belt functions in this area.

Any strategic allocation made at West Horndon will have a long lead in time before it will start to contribute to the Borough's housing needs. This is not the case with Site 159. New allocations in the A12 Corridor should include a mixture of small to medium sized sites, coming on stream earlier in the plan period, to maintain the five year housing land supply required by the National Planning Policy Framework.

Quality of Life & Community Infrastructure

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

We note the Consultation Document's reference in paragraph 6.4 to a growth in demand for school places and that at primary level existing capacity will be exceeded around 2017/2018. We also note what is said in paragraph 6.5 about healthcare provision. We have stated above our clients' willingness to dedicate part of Site 159 to a a new healthcare facility or residential care home to serve Pilgrims Hatch. This is a direct and positive response to the Council's aim, set out in the Consultation Document's paragraph 6.5:

"Plans to mitigate this (population) growth via developer funded and other collaborative working projects will be agreed before planning permissions are granted."

There is a general mention of investment in transport infrastructure. If the Council were to adopt the approach suggested above, developing a strategic allocation around West Horndon, investment in a new station hub and linked pedestrian/cycle networks would be critical to its success.

We see the overall priorities for infrastructure as follows:
*new community facilities as determined through consultation with local communities including the community of Pilgrims Hatch
*healthcare facilities, in particular those aimed at meeting the needs of the Borough's ageing population
*a new railway station hub, and footpath and cycleway networks, for the proposed West Horndon strategic growth area.

Conclusions
Sites that are readily available and make negligible contribution to the aims of the
Green Belt, such as Site 159 at Pilgrims Hatch, should be considered for development early in the plan period. Such sites with relatively short development lead in times will relieve pressure on the Council's five year housing land supply, as required in the current National Planning Policy Framework.

If Site 159 is removed from the Green Belt, it will be wholly suitable, achievable and, as stated previously, readily available to satisfy both housing and community
infrastructure needs of the area. No other site in and around Pilgrims Hatch can take all these matters on board.

This initial representation must be read in conjunction with all representations and
correspondence to the previous Plan relating to Site 159 at Pilgrims Hatch. We will
wish to make further representations at the next stage of the Brentwood Borough Local Plan 2015-2030.