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 land to the west of Heathlands, School Road, Kelvedon Hatch (see attached Site Location Plan), which would fall within criteria 3 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.

The Kelvedon Hatch Parish Council discussed the Local Plan at both our January and February Council Meetings held on the 8th and 12th respectively. We have a series of observations to make.

In general we accept that more residential and employment sites are required over the next few decades, but would still prefer to protect the Green Belt where ever possible in line with the new NPPF guidance. We would favour development within "brown field" sites where previously green or agricultural activities have not been carried out for some time. We felt that of the four options given on page 11 of the Consultation Document either Nos. 3 or 4 would be preferable in order that "the pain was to be shared out more equally".

With particular reference to our parish of Kelvedon Hatch we realise that "brown field" development opportunities are very limited and nearly all the suggested sites given within the appendix on page 43 lie within the Green Belt. In general we felt that the preferable sites should be limited to the "in-fill" sites round the ragged development curtilege of the village itself. The most acceptable sites being those with three sides of attachment, reducing to two sides as less acceptable and with only one side or totally separated as least acceptable. We prefer infill sites as this is in agreement with the new NPPF guidance on Green Belt considerations.

Without going into consideration of each individual suggested site for our parish some examples would illustrate. The number of each site is as given in your appendix 2 for the Brizes and Doddinghurst Ward. Examples of more acceptable in-fill sites are 066, 168, 182, 194, 075 and 217. Although site 182, land adjacent to Heathlands, School Road, has recently been refused permission by the Borough Council, but it is still at appeal with the Inspectorate. Land to the rear of the Spinney, School Road (site 139) has been refused permission by the Borough Council and the subsequent appeal was dismissed by the Inspectorate. We would also like to point out that Woodlands, School Road (site 009) is privately owned, within the development envelope of the village and was the subject of an uproar within the village at the presentation of the earlier consultation in 2013. This was due to the fact that the first the owners had heard about their "redevelopment" was from the Brentwood Gazette. At the meeting the owners were reassured by the Borough Council Officers stating that no compulsory purchases were to be made.

Least acceptable sites are those such as 201, GT004, GT013 and those isolated areas to the south of the village such as 191, 221 and 210. A possible site that has yet to be included, which has more of an appropriate in-fill aspect is land to the west of Ongar Road between the Whitehouse (already granted planning permission, but with stringent conditions attached with regard to land decontamination) and Fairview. Ownership of this land would have to be established, but the land is in a neglected condition and has been so for many decades. Whilst the above examples are by no means a definitive list they give a flavour of the Parish Councils deliberations. In the fullness of time we would appreciate being consulted on each individual site that the Authority chooses to recommend if any at all.

The Consultation also requested our views on the proposed Dunton Garden Suburb. Much was made of the fact that we should not deign to comment on someone else's patch, however, it was noted that much of the area was brown field and also that the relevant Parish Council has been reported in the local press as having reluctantly agreed to the proposal after reassurances were made about suitable infrastructures considerations and improvements. It was also observed that such a large development would relieve pressure on the rest of the borough. It was felt that the Parish Council should be in favour of the Garden Suburb. In all these discussions mention was made of the need to properly assess and provide upgrades to the required infrastructure for any developments within the Borough. This would include all services such as sewerage, electricity, gas, internet as well as roads, cycle paths and pavements. Considerations should also be made with regard to schools and medical service provision. Such upgrades would of course be part of the developer's conditions in order not to overload, any further, the existing services.

The Parish Council hopes that these views will be helpful to the consultation and we would appreciate receiving the results and any further decisions by the Borough Council on the Local Plan.

See attached

See attached