I am writing to you with regard to your strategic growth options consultation.
As you can see I live in Harold Park which borders Brentwood and I do all my shopping etc in the Brentwood area and spend a good deal of time there. I very much enjoy travelling to Brentwood usually on public transport, and seeing the countryside and areas of green belt which surrounds both Harold Park and Brentwood. This is one of Brentwood's greatest assets, it is what draws people to live here and makes it a pleasant place to live. As such I was extremely upset to think that you would consider building on the green belt. Even this week the Standard newspaper quoted Thurrock and Epping Forest as the two top places that people wish to live in and gave the reason as "because it is surrounded by green belt land" (See Evening Standard Tuesday 3 February 2015, page 13). I believe this emphasises how important green belt land is and why it should not be built upon.

I list my reasons and comments below:
* Your document does not seem to have been approached on a sensible and even basis. Especially concerning the bias running through the document leading towards development to the south of the Borough. For example, the obvious and severe traffic existing problems on the A127 are not stated in the discussion, with development being seen as a possible solution to an inferred need, (3.12) whereas such growth in the A12 corridor 'could have similar negative impacts on infrastructure and services' (3.13) and in the even more so in (2.10) where development in the Brentwood urban area and north of the Borough creates problems whereas in the A127 corridor and West Horndon development "creates opportunities" according to your document.

* For the reason states above the consultation is not objective in terms of presentation and environmental and financial cost.

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

No for the following reasons:

It is arguable whether the Borough needs subdividing at all for growth purposes.
In the absence of evidence relating to transport it is far from certain that this is the key matter to base decisions upon.

Even in the most rural parts of the Borough transport is not particularly poor compared with many parts of Essex let alone the country.

The subdivision is based ostensibly on transport but the north / middle / south land subdivisions is just too coarse a reflection of transport availability, this being predominantly linear in nature.

Even accepting transport led subdivisions in principle, this quickly needs to be refined by considering the questions of available capacity and financial and environmental cost to upgrade to accommodate growth. Without these considerations the basis of the study is unsupported.

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

Partially although the brief analysis 2.14 - 2.19 should be consistent. 2.19 is particularly biased whereby it makes an unsupported link between the character and availability of land for growth being potentially greater (surely this is the ultimate conclusion of considering all aspects of land use) and that the A127 has more scope for improvements than the A12 (and I would add, the A128, B roads and local road network).

To reiterate the point under Q1 if transport really is the key issue then a link is required between problems and solutions before judgements can be suggested.
Issues for the three areas should also concentrate on environmental impacts of the various options.

Q3: Do you have any comments on the appropriateness of particular sites?
I believe it is totally inappropriate to use Green Belt land for such purposes. I agree with the aim to maximise the use of brownfield areas both within urban and rural localities.

Even taking this into account should additional sites be required these should generally be of an infill nature or otherwise to create compact communities. This should apply to both urban and rural areas in order to create built up areas that minimise impact on landscape and facilitate the creation of a focus. The extent to which this principle should be applied would be based on minimising impact vs growth.

In terms of the sites illustrated:

3.12 - The completely new town 'Dunton Garden Suburb' would in my view have disproportionate impacts on the Green Belt in addition to creating a new urban centre which I feel would be detrimental to Brentwood Town centre and the road network. In addition the growth suggested for West Horndon is clearly disproportionate to the suggested aims above. Some smaller growth to West Horndon though could be accommodated whilst keeping the existing community compact and focused.

3.13 - In general both these option should be pursued within the aims I mention above. I would oppose the large scale areas shown south east of Hutton as per my comments on the 'Dunton Garden Suburb'. Further linear expansion at Brook Street termed 'Development options at M25' are also highly detrimental to the Green Belt by eroding this already narrow strip between Brentwood and the edge of the Green Belt in Havering, and that at Coombe Woods, Bereden Lane would be a planning travesty. Some smaller growth opportunities to Pilgrims Hatch, Shenfield and Honeypot Lane would perhaps have the least affect on the Green Belt and be close enough to existing built up areas to keep the built up area as compact as possible and focus activity towards existing urban centres. Small extensions to Mountnessing and Ingatestone that are within the confines of the existing road / rail corridor could also be considered.

The idea of an additional junction with the A12 to intercept the A128 is so obvious that I'm surprised that this wasn't incorporated back in the 1960s. It is this sort of link to the interrelationship between growth and transport that I was referring above although in this case it would have a significant added benefit to the community rather than just accommodating additional pressure created by growth.

3.14 - Isolated sites should not in general be considered for housing development such as Clapgate Estate and Thoby Priory. Some smaller growth to each of the main communities shown on the plan (except Navestock) could be accommodated whilst keeping the existing community compact and focused.

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?

This is a strange leading statement as the assumption regarding greater capacity for growth along the A127 Corridor remains undemonstrated. On the face of it the same phrase could be used to open a question about any other part of the Borough. For example, if necessary local road improvements could be considered for the area of the 'five villages' in the northern subdivision.

As discussed above in relation to the A127 Corridor limited growth at West Horndon is the only reasonable option for this sub area.

Q5: Should the A12 Corridor accommodate growth by releasing sites in the edge of urban area?

I assume that this is referring to Green Belt land and therefore my answer is no.

Q6: In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt)?

It is in general much more preferable for brownfield sites to be developed over greenfield sites however the impacts and implications of this do need to be taken into consideration. In some cases brownfield sites are best left in employment use and / or are not in a town or village context and in such cases creation of new housing in the countryside should be avoided.

Q7: To enable future employment need to be met do you agree that the most sustainable approach is to allocate new sites close to the strategic highway Network?

I think the link between employment use and the strategic highway network is likely to be sweeping and in cases the opposite is true.

I also believe that we should be looking at sustainable transport such as the railways and not adding to road traffic and pollution.

I would say that future employment need should be met by considering the full range of planning matters including impacts on the landscape and the green environment.

Q8: In order to ensure that the Town Centre remains economically sustainable, do you agree that a "Town Centre First" approach should be taken to retail development?

Definitely. Retail lends itself well to densification of existing land use and I do not feel that release of any green belt land should be necessary to accommodate such growth.

Q9: Are there opportunities for more open space provision in the area where you live?

Not so much provision of open space as the need for better recreational linkages between open spaces.

It would be helpful if the Council were more proactive in terms of the environment and, for example, provided public transport to the parks such as South Weald and Thorndon, or at least provide free parking for the first 2 hours. It is important to replace trees on the edge of roads etc to keep Brentwood feeling rural and not urban. To this end it is important to avoid advertising creep on business premises. I think it is important to not have neon signs for e.g. the Holiday Inn and other businesses. It is important not to allow planning creep, a poor example of this and one which the Council could have prevented is the large Sainsbury store which when it was first built was built away from the main road in quite a laid back position with trees and landscaping. Not long after it was allowed to build the monstrous car park which as well as being an eye sore has meant those arriving on foot have to walk much further to get to the entrance.
The A127 represents a severe block to north - south recreational routes. Effectively there is no sympathetic crossing for the 6.5km from Great Warley Road to Dunton outside of the Borough. This is very regrettable matter as it limits the value of Thorndon Park to residents of West Horndon and any recreational users coming from the south to the Park.

Q10: Please rate the level to which you value the landscape near where you live. (see page 29)

In Harold Park and living very near to the borders of Brentwood the following areas are very important to me.

Being able to see the countryside and not feeling like I live in a town, being able to see wildlife, the need for woods and trees to provide oxygen, to counteract pollution and to act as a sound barrier to prevent noise from the road and the railway. I would therefore rank the following as of equal importance.

Scenic Beauty / Outdoor Recreation / Wildlife interest / Historical interest / Tranquillity

Other - a key aspect omitted is views. As mentioned in my first paragraph it is very important to me to be able to see green fields, deer roaming, etc and I think that Brentwood Council should be doing more to prevent the urbanisation of the area. For example limit the advertising signage and changes which are more in link with an urban area than a semi rural one.

Q11: To what extent do you think the following is present in the landscape near where you live?

Houses - all the houses are in tree lined roads and surrounded by gardens and the estates are green with fields all around.

Commercial buildings - there are very few apart from a small number of local retail.

Nature Reserves - I can get to Thames Chase / South Weald / Thorndon Park in a matter of minutes.

Farmland - several farms although Oak Farm has never been seen as a proper farm.

Woodland - Many woods which act as a sound barrier, provide oxygen and look pleasant

Wasteland - none

Infrastructure - A12, A127, M25 nearby but not so near as to disturb the peace, railway nearby Leisure Facilities - sufficient, especially as I enjoy walking and cycling and there is a cycle path and several areas to walk in without needing a car.

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

I do not believe that green belt should be built on at all. Instead the borough should be not allowing the building of large accommodation, for example most recent estates are for 3 or 4 bedroom detached houses where there is clearly a need for 1, 2 and 3 bedroom houses to meet the need especially factoring in the change in families, more single people etc.

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

This requires a study in itself and I note that this is being looked into (6.3). As stated throughout this response though I feel that Strategic Growth options need to come out of the conclusions from the infrastructure study (and studies into other such high level matters) rather than being in a response to a more arbitrarily suggested steer.

As discussed above I believe there are many opportunities for the council to be more pro-active in terms of infrastructure and caring about the environment and restoring and maintaining a sense of community. For example, including sustainable transport in any plans concerning infrastructure, for example, sensible and safe cycle lanes which don't encroach on the pavement. Free parking and transport to local parks. Maintenance of footpaths and public bridleways to encourage people to make use of the fields around. Support for local shops and local post offices. Encouragement for people to shop locally, for shops to sell local produce. Subsidies for milkmen, paper deliveries etc so that the elderly and vulnerable are included in any plans. Creating a community whereby the elderly and vulnerable are not isolated, for example encouraging businesses, banks and libraries to use people and not replace people with systems, e.g. banks in Brentwood high street, Brentwood library etc. This also has the added benefit of creating employment.

I look forward to hearing from you regarding the above in due course.

see attached

see attached

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.

I write in respect of your Strategic Growth Options Consultation

A general comment is that the document needs to be much more evidence based an even handed. There is a bias running through the document resulting in a leading towards development the south of the Borough. I cannot cite all of these, but as examples:

The obvious and severe traffic existing problems on the A127 are not states in the discussion, with development being seen as a possible solution to an inferred need, (3.12) whereas such growth in the A12 corridor 'could have similar negative impacts on infrastructure and services' (3.13) and in the even more so in (2.10) where development in the Brentwood urban area and north of the Borough creates problems whereas in the A127 corridor and West Horndon development creates opportunities.

To prevent such a bias developing the whole consultation needs to be supported by an objective presentation of localities under 'stress' and the costs (both financial and environmental) to deal with these.

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

No for the following reasons:

It is arguable whether the Borough needs subdividing at all for growth purposes and the approach to growth needs to be based primarily around Green Belt considerations. I believe that to accommodate growth all steps possible should be taken to limit the release of Green Belt and that this course of action should only be followed in extenuating circumstances where there is no other realistic possibility.

Other models for growth should be considered and I believe that to accommodate growth all steps should be taken to minimize the release of Green Belt. Means of doing this include:

* Maximising the use of derelict or underused urban space;
* Increasing densities within already built up areas;
* Developing brownfield areas both within urban and rural localities

Should any release of Greenfield land be absolutely essential these should be considered through
* Release of infill sites
* Release of many smaller sites on the edge of urban areas
* Application of suitably high densities to any greenfield land released.

Further comments on the broad divisions are:

In the absence of evidence relating to transport I think it unlikely that this is the only or most important matter on which to base decisions. Even in the most rural parts of the Borough transport is not particularly poor compared with many parts of Essex let alone the country. The subdivision is based ostensibly on transport but the north / middle / south land subdivisions is just too coarse a reflection of transport availability, this being predominantly linear in nature.

Even accepting transport led subdivisions in principle, this quickly needs to be refined by considering the questions of available capacity and financial and environmental cost to upgrade to accommodate growth. Without these considerations the basis of the study is unsupported.

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

Partially although the brief analysis 2.14 - 2.19 should be consistent. 2.19 is particularly biased whereby it makes an unsupported link between the character and availability of land for growth being potentially greater (surely this is the ultimate conclusion of considering all aspects of land use) and that the A127 has more scope for improvements than the A12 (and I would add, the A128, B roads and local road network).

To reiterate the point under Q1 if transport really is the key issue then a link is required between problems and solutions before judgements can be suggested.
Issues for the three areas should also concentrate on environmental impacts of the various options.

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

I believe that principles regarding the release of Green Belt should be foremost and in principle all steps should be taken to minimize such release. I agree with the aim to maximize the use of brownfield areas both within urban and rural localities. I also feel that release of Green Belt could be further minimized by appropriately increasing the density of existing settlements.

Even taking this into account should additional sites be required these should generally be of an infill nature or otherwise to create compact communities. This should apply to both urban and rural areas in order to create built up areas that minimise impact on landscape and facilitate the creation of a focus. The extent to which this principle should be applied would be based on minimising impact vs growth.

In terms of the sites illustrated:

3.12 - The completely new town 'Dunton Garden Suburb' would in my view have disproportionate impacts on the Green Belt in addition to creating a new urban centre which I feel would be detrimental to Brentwood Town centre and the road network. In addition the growth suggested for West Horndon is clearly disproportionate to the suggested aims above. Some smaller growth to West Horndon though could be accommodated whilst keeping the existing community compact and focused.

3.13 - In general both these option should be pursued within the aims I mention above. I would oppose the large scale areas shown south east of Hutton as per my comments on the 'Dunton Garden Suburb'. Further linear expansion at Brook Street termed 'Development options at M25' are also highly detrimental to the Green Belt by eroding this already narrow strip between Brentwood and the edge of the Green Belt in Havering, and that at Coombe Woods, Bereden Lane would be a planning travesty. Some smaller growth opportunities to Pilgrims Hatch, Shenfield and Honeypot Lane would perhaps have the least affect on the Green Belt and be close enough to existing built up areas to keep the built up area as compact as possible and focus activity towards existing urban centres. Small extensions to Mountnessing and Ingatestone that are within the confines of the existing road / rail corridor could also be considered.

The idea of an additional junction with the A12 to intercept the A128 is so obvious that I'm surprised that this wasn't incorporated back in the 1960s. It is this sort of link to the interrelationship between growth and transport that I was referring above although in this case it would have a significant added benefit to the community rather than just accommodating additional pressure created by growth.

3.14 - Isolated sites should not in general be considered for housing development such as Clapgate Estate and Thoby Priory. Some smaller growth to each of the main communities shown on the plan (except Navestock) could be accommodated whilst keeping the existing community compact and focused.

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?

This is a strange leading statement as the assumption regarding greater capacity for growth along the A127 Corridor remains undemonstrated. On the face of it the same phrase could be used to open a question about any other part of the Borough. For example, if necessary local road improvements could be considered for the area of the 'five villages' in the northern subdivision.
As discussed above in relation to the A127 Corridor limited growth at West Horndon is the only reasonable option for this sub area.

Q5: Should the A12 Corridor accommodate growth by releasing sites in the edge of urban area?

The same general comment applies in that if so this needs to be based on environmental impacts in addition to a more thorough examination of local constraints and the costs / benefits of satisfactorily resolving these. On the face of it though the five main urban area in this subdivision are likely to offer the most from release of Greenfield land because there is

* A greater perimeter to the built up area and urban and semi urban landscape
* A number of existing town facilities
* A closer proximity of brownfield land and areas requiring regeneration in these areas
* A greater choice that investment from growth will go into Brentwood Borough
* In addition transport links this broad area are good

Q6: In order to provide for local need is it preferable for greenfield sites on the edge of villages to be released, or to develop brownfield sites (both within Green Belt)?

It is in general much more preferable for brownfield sites to be developed over greenfield sites however the impacts and implications of this do need to be taken into consideration. In some cases brownfield sites are best left in employment use and / or are not in a town or village context and in such cases creation of new housing in the countryside should be avoided.

Q7: To enable future employment need to be met do you agree that the most sustainable approach is to allocate new sites close to the strategic highway Network?

I think the link between employment use and the strategic highway network is likely to be sweeping and in cases the opposite is true. Certain employment uses can be advantageous in creating a positive mixture of land uses and communities. However as stated in the text some employment uses create a number of adverse impacts on communities. I do not think good strategic highway network per se is so important for many employment uses nor for modern business needs' however it may be that such a pattern develops by consequence of considering other aspects of planning. I would say that future employment need should be met by considering the full range of planning matters including impacts on the landscape and the green environment.

Q8: In order to ensure that the Town Centre remains economically sustainable, do you agree that a "Town Centre First" approach should be taken to retail development?

Definitely. Retail lends itself well to densification of existing land use and I do not feel that release of any green belt land should be necessary to accommodate such growth.

Q9: Are there opportunities for more open space provision in the area where you live?

Not so much provision of open space as the need for better recreational linkages between open spaces.

It would be helpful if the Council were more proactive in terms of the environment and, for example, provided public transport to the parks such as South Weald and Thorndon, or at least provide free parking for the first 2 hours. It is important to replace trees on the edge of roads etc to keep Brentwood feeling rural and not urban. To this end it is important to avoid advertising creep on business premises. I think it is important to not have neon signs for e.g. the Holiday Inn and other businesses.

The A127 represents a severe block to north - south recreational routes. Effectively there is no sympathetic crossing for the 6.5km from Great Warley Road to Dunton outside of the Borough. This is very regrettable matter as it limits the value of Thorndon Park to residents of West Horndon and any recreational users coming from the south to the Park.

Q10: Please rate the level to which you value the landscape near where you live. (see page 29)

Q11: To what extent do you think the following is present in the landscape near where you live?

I think it misleading to ask for a comparison between other areas in Brentwood Borough in Q10. The real aim should be to discover what impacts release of any Greenfield land would have. Intrinsic value of the landscape being considered for development is one of these, but the impacts would be a combination of both the nature of the proposed developments (including indirect effects) and aspects related to wider values relating to those areas impacted. The first part needs at least some definition. The second part needs to be judged not just on the parameters listed but also on other factors such as:

Views - this being more about the vistas that can be gained of and from the area under consideration.
Value in providing 'green lungs' to surrounding developed areas
Value in providing green continuity for the purposes of nature conservation recreation
Ability to be viewed and used

To take an example, an urban park may score v low on most of the aspects of question 10 but would suggest that the impacts of developing this space could be huge. My views on impact on landscape are largely answered under question 3.

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

I'm not sure that green infrastructure covers the point I wish to make as green infrastructure sounds like a local provision to create a desirable community. The main issues for me surrounds the pattern of any release of Green Belt land to accommodate growth. I firmly believe that even if growth on one or two large scale land releases could be accommodated this model would seriously make Brentwood a poorer Borough compared with a more dispersed growth model. This is because the 'pain' of smaller Green Belt losses can be more easily absorbed and the gain more directly and perhaps fairly directed to the relevant community. With a few large scale developments the 'pain' of growth simply has to be swallowed - no one can ignore the detriment to the Green Belt that would be created by developments the size of that at West Horndon and the Dunton Garden Suburb but the gain is likely to be only too readily swallowed up in dealing with the obvious capacity issues that would be created by such a concentration of living and associated activity.

To restate, a more dispersed growth model can be used to efficiently use existing infrastructure capacity possibly with little intervention whereas large developments will inevitably require greater use of investment into the Borough in solving problems created by the development.

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

This requires a study in itself and I note that this is being looked into (6.3). As stated throughout this response though I feel that Strategic Growth options need to come out of the conclusions from the infrastructure study (and studies into other such high level matters) rather than being in a response to a more arbitrarily suggested steer.

see attached