Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.

Site West of Thorndon Avenue, West Horndon is fully in accordance with the spatial strategy focused on transit orientated growth and should be allocated. No significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village was identified by the Sustainability Appraisal. If Brentwood is to attempt to meet the housing needs, this approach is required.

Attachments include:
Completed comment form
Part 1 of 2 Reps Brentwood LP-merged-compressed-1-83
Part 2 of 2 Reps Brentwood LP-merged-compressed-84-199
The representations from above documents can be summarised as followed:
The NPPF is clear that where the plan-maker has identified that exceptional circumstances exist to release land from the Green Belt the 'first consideration' should be given to land which is 'previously developed and/or well-served by public transport'. The Plan itself seeks 'transportorientated growth.' The subject land at West Horndon is considered the most sustainable undeveloped site in the borough given its proximity to West Horndon rail station (one of just four rail stations in the borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads.
There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. Notwithstanding the above, Brentwood Council remain steadfast against allocating the land in the current Local Plan. The Plan fails the test of soundness in this respect as it is not consistent with national policy. The assertion that Brentwood is a self-contained HMA is highly questionable. In any event this does not preclude Brentwood from accommodating unmet housing needs from either London or other adjoining authorities in Essex. These representations identify the extent of unmet need in adjoining boroughs including Basildon, Havering and from the London Plan, particularly in the short to medium term which the Brentwood Local Plan fails to address. On this matter the Draft Local Plan fails the soundness test as it is neither justified nor effective in terms of cross boundary strategic matters. Aside from unmet housing need in adjoining boroughs it is considered that Brentwood has significantly under estimated its own housing need having failed to take account of the 'uncapped' housing requirement and the effects of Crossrail. Furthermore, the proposed stepped housing trajectory is unjustified and simply reinforces the affordability challenges in the borough which need to be urgently addressed. From a review of the evidence it is considered that the Council cannot demonstrate a Five-Year Housing Land Supply. Moreover, there are a range of delivery issues with the housing trajectory for the first five year of the plan period which further demonstrates that the Council need to allocate additional land in order to meet their housing requirements. Furthermore, Iceni consider that Brentwood Borough Council has under estimated the need for B class employment land in the Borough, and that its employment land supply is insufficiently flexible. Land at Thorndon Avenue, West Horndon could support new employment provision including a data centre and other B-class uses incorporated as part of the overall mixed-use development, meeting an identified need; supporting flexibility of supply and also contributing towards local employment generation and supply for local businesses, mitigating the impact of the loss of the West Horndon Industrial Estate for new residential development. The Council's spatial strategy seeks to accommodate growth in locations which are sustainable and will maximise the value of railway connectivity. However, the spatial strategy also details that the sequential approach to allocating development was adopted. The sequential test methodology proposes after urban and brownfield sites, growth should be focused on strategic sites (removed from existing services and infrastructure) and then followed by urban extensions (areas close to existing transport infrastructure). This approach conflicts with the wider policies contained in the Plan which all seek first and foremost to develop land next to existing infrastructure and services, provided there are no detrimental impacts on important environmental designations. In this respect the Local Plan policies conflict with one another. The evidence base including the Green Belt Study; the Sustainability Appraisal; the Landscape Sensitivity and Capacity Study and the Housing and Economic Land Availability Assessment all support the allocation of the subject land at West Horndon for housing. In fact, the Council's own landscape assessment considers due to the characteristics of the subject site, that it should be prioritised for housing development. The development of this unfettered site at West Horndon is fully in accordance with the spatial strategy focused on transit - orientated growth and will act as a catalyst for the redevelopment of the Industrial Estate and Dunton Hills Garden Village. The evidence base, particularly the Sustainability Appraisal, does not identify any significant constraints with developing an urban extension at West Horndon, in addition to Dunton Hills Garden Village. If Brentwood is to attempt to meet the housing needs, this approach is required. The vision of West Horndon (Brentwood lands) is to deliver approximately 900 new homes set within an attractive, landscaped setting defined by new watercourses and water bodies. The development will provide convenient walking and cycling access to West Horndon railway station and a new direct link to Thorndon Country Park in the north. Homes will be centred on a village green which will be fronted by a new primary school, local shops and a care home to provide for everyday needs of new and existing local residents. A new employment area of approximately 4ha in the north-eastern corner of the site will provide much-needed accommodation for local and medium-sized enterprises with visibility and access off the A127. Unfortunately, EASL is unable to support the Council's plan making decisions as they are not currently based on a sound evidence base and do not meet the NPPF's objective to amend Green Belt boundaries in the most sustainable locations. EASL remain committed to working with the Council to address the failings in the Local Plan.